Quick answer
Regulation (EU) 2024/573 does not govern the road transport of dangerous goods. What it does govern, and what applies while the cylinder is moving, is three things: preventing emissions, who is answerable for the cylinder, and what is written on it.
For ADR classification, transport documents, limited quantities and vehicle placarding, the applicable law is a different one: Directive 2008/68/EC on the inland transport of dangerous goods, which applies ADR inside the Union.
It does not contain ADR numeric thresholds — limited quantities, gross masses, transport document obligations or placarding. Those figures have to come from the official text in force, not from a summary. See the dangerous goods section below.
Who is answerable while the cylinder is moving
Article 4(3) is deliberately broad. The duty to take all necessary precautions to prevent the unintentional release of the gases falls on operators and manufacturers of equipment, on operators of facilities, and on undertakings in possession of such equipment during its transport or storage.
In other words, responsibility does not stop at the warehouse door. Whoever has the cylinder in the vehicle at that moment is inside the text.
Article 4(4) goes further and expressly covers production, storage, transport and transfer of the gases from one container or system to another, to equipment or to a facility: the undertaking concerned shall take all necessary precautions to limit release of the gases to the greatest extent possible.
And where a leak is detected, Article 4(5) places on the holder during transport too the duty to ensure repair without undue delay.
Does the carrier need an F-gas certificate?
No, and the regulation says so explicitly. The first subparagraph of Article 11(6) limits the purchase of fluorinated greenhouse gases to certified persons and to undertakings employing them. The second subparagraph then adds:
This paragraph shall not prevent non-certified undertakings that do not carry out the activities referred to in the first subparagraph from collecting, transporting or delivering fluorinated greenhouse gases listed in Annex I and in Section 1 of Annex II.
The distinction is between technically handling the gas and moving it. Installation, maintenance, servicing and repair require certification. Collection, transport and delivery do not.
Mind the edge of that exemption, though: it covers collecting, transporting and delivering, and nothing more. If the driver opens the circuit, connects a cylinder or does anything falling within the Article 3 definition of maintenance or servicing, you are no longer in the second subparagraph.
Training requirements for the transport of dangerous goods are an entirely separate matter, set out in that regime, not here.
The label has to survive the journey
Article 12(1)(g) puts all fluorinated greenhouse gas containers under the labelling requirement. Article 12(4) says what the label has to be:
- Clearly legible and indelible. Not a film that peels, not a marking that rubs off in the back of a van.
- Placed either adjacent to the service ports for charging or recovering the gas, or on that part of the product that contains the gas.
- Written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied.
That last point matters in cross-border movement: the relevant language is that of the commercial destination, not of the origin.
The mandatory content comes from Article 12(3): an indication that fluorinated greenhouse gases are contained, the accepted industry designation, the quantity in weight and in CO2 equivalent, and the GWP. Implementing Regulation (EU) 2024/2174 adds the wording “contains fluorinated greenhouse gases”.
A cylinder arriving with an unreadable label is a non-conformity that shows up immediately in any inspection and that you cannot repair after the fact with an invoice.
The dangerous goods side: where you have to look
Refrigerant gases travel under pressure and as a rule fall inside the dangerous goods regime. The applicable Union framework is Directive 2008/68/EC on the inland transport of dangerous goods, which makes the ADR provisions applicable within the Union for road transport.
What you have to take from there, rather than from a summary:
- The UN number and proper shipping name for the specific product.
- The class, hazard label and classification code.
- The thresholds for limited quantities and for exemptions, where they apply.
- The transport document, the equipment required on board and the vehicle placarding.
- The training requirements for the driver and for the staff involved.
Section 14 of the safety data sheet. The format required by Regulation (EU) 2020/878 puts the UN number, proper shipping name, transport hazard class, packing group and special precautions there. It is the supplier-validated information for the exact product you are carrying.
Do not extrapolate from one refrigerant to another. R-32 and R-134a do not share a transport classification, even though both are fluorinated greenhouse gases.
If you find a leak on the road
Stop safely and ventilate
Immediate safety measures come from sections 4 and 6 of the product safety data sheet, not from the F-gas Regulation.
Do not deliberately empty the cylinder
Article 4(1) prohibits intentional release into the atmosphere where it is not technically necessary for the intended use.
Ensure repair without undue delay
Article 4(5) places this duty on undertakings in possession of the equipment during transport as well.
Record what happened
The quantity lost, when, and the measures taken. If the gas came from equipment subject to Article 5(1), the information belongs in the equipment record under Article 7(1).
Recover what can be recovered
Article 8(1) requires recovery by certified persons. Recovered gas may not be used for refilling unless it has been recycled or reclaimed, under Article 8(6).
Checklist before setting off
- Cylinder closed and protective cap fittedA basic precaution required by Article 4(3) and (4).
- Label legible and undamagedArticle 12(4): clearly legible and indelible.
- Label language matches the destinationArticle 12(4), second subparagraph.
- Safety data sheet accessibleSection 14 for transport, sections 4 and 6 for incidents.
- Dangerous goods classification checked for this productFrom section 14 of the sheet and from the Directive 2008/68/EC regime.
- Documents required by the dangerous goods regime are on boardSet out in that regime, not in the F-gas Regulation.
- You know the consignee and whether they may receive the gasArticle 11(6) for bulk gas, Article 11(7) for non-hermetically sealed equipment.
- Cylinders secured so they cannot strike each otherA technical precaution; the exact requirements come from the dangerous goods regime.
Frequently asked questions
Does my courier firm need an F-gas certificate?
No, where it only collects, transports or delivers. The second subparagraph of Article 11(6) says expressly that the paragraph does not prevent non-certified undertakings which do not carry out installation, maintenance, servicing or repair from doing exactly those things.
Can I carry a cylinder in a private car?
The F-gas Regulation does not prohibit it as such, but it is not the regulation that decides. Carrying gases under pressure falls within the dangerous goods regime under Directive 2008/68/EC, and the conditions, exemptions and limits are set there. Check them in the official text and in section 14 of the safety data sheet first.
What if the label is damaged in transit?
Article 12(4) requires the label to be clearly legible and indelible. A destroyed label has to be reinstated with the correct information before the cylinder is made available onwards. Accompanying paperwork does not make up for a missing label.
Do I have to keep records of the cylinders I move?
The regulation requires records of the sale: Article 7(3) obliges undertakings supplying Annex I or Section 1 Annex II gases to record each purchaser's certificate number and the quantities, for at least 5 years. There is no separate transport register in the regulation.
Do empty cylinders carry the same duties?
An “empty” cylinder almost always holds residual gas. Article 8(7) requires an undertaking using a container to arrange, immediately prior to its disposal, for the recovery of any residual gases so they are recycled, reclaimed or destroyed. Until then, the Article 4(3) precautions still apply.
Where do I find the product's UN number?
In section 14 of the safety data sheet, in the format required by Regulation (EU) 2020/878. It is the supplier-validated source for the exact product you have.
Official sources
Articles 4, 7, 8, 11 and 12 were read directly in the Official Journal text. The dangerous goods side is pointed to through the applicable act, without reproducing its numeric thresholds.
Currency of this page and limits of responsibility
This page covers the duties under the F-gas Regulation. It does not replace dangerous goods law and does not carry its numeric thresholds. For classification, documents and placarding, use the official text in force and section 14 of the safety data sheet.
General information prepared by EgoLog from the regulation and official Commission material. It is not legal advice.
Pressure equipment verification and periodic testing of cylinders fall under other acts. Confirm those requirements with your supplier and your national competent authority.