Vehicle air conditioning: what the F-gas rules ask of a garage

The short answer

There is no single act for vehicle air conditioning. There are two, and most of the confusion on the workshop floor comes from mixing them.

• Directive 2006/40/EC applies to motor vehicles of categories M1 and N1 class I (Article 2). It sets the GWP 150 limit, bans retrofitting and restricts filling (Articles 5 and 6).
• Regulation (EU) 2024/573 applies on top: the ban on intentional release and repair without undue delay (Article 4), recovery (Article 8), the qualification of the person doing the work (Article 10) and the right to buy the gas (Article 11(6)).
• The periodic leak check of Article 5 does not apply to cars inside the scope of the Directive. Article 5(3), point (c), lists heavy duty vehicles, vans, non-road mobile machinery, trains, metros, trams and aircraft, and for those Article 5(5) defers the duty until 12 March 2027.
• Whoever does the work must hold at least a training attestation (Article 4(7), third subparagraph, and Article 10(1), second subparagraph). The minimum requirements now sit in Implementing Regulation (EU) 2025/1893.

Two acts, one vehicle

The first practical question is not what the F-gas Regulation says, but which vehicle you are looking at. The answer moves the duty from one act to the other.

Two absences are worth remembering, because they change the workshop routine. Annex IV to the Regulation, which lists the placing-on-the-market prohibitions, contains no entry for vehicle air conditioning at all: the limit for vehicles comes from the Directive, not from the Annex. And Article 6 of the Regulation, on leakage detection systems, refers only to the stationary equipment listed in Article 5(2), so no vehicle falls under it.

For the general timetable of the Annex IV prohibitions, see the ban timetable.

Which vehicles, and from which date

Article 2 of Directive 2006/40/EC limits the scope to motor vehicles of category M1 and to those of category N1 class I as defined in Annex II to Directive 70/156/EEC. Article 3, point (3), defines an air-conditioning system as any system whose main purpose is to decrease the air temperature and humidity of the passenger compartment, and point (4) separates dual evaporator systems from single evaporator systems.

• Permitted leakage at type-approval. Article 5(2) and 5(3): for systems designed to contain fluorinated greenhouse gases with a GWP higher than 150, the leakage rate may not exceed 40 grams per year for a single evaporator system and 60 grams per year for a dual evaporator system.
• 1 January 2011. Article 5(4): Member States shall no longer grant EC or national type-approval for a type of vehicle fitted with an air-conditioning system designed to contain fluorinated greenhouse gases with a GWP higher than 150.
• 1 January 2017. Article 5(5): for new vehicles fitted with such systems, Member States shall consider certificates of conformity to be no longer valid and shall refuse registration and prohibit sale and entry into service.

Which refrigerants cross the line? R-134a appears in Annex I, Section 1, to Regulation (EU) 2024/573 with a GWP of 1 430, far above 150. R-1234yf appears in Annex II, Section 1, with a GWP of 0,501, below the line. That single figure is why the vehicle fleet split into two generations. The regulatory status of each is set out on the R-134a page and the R-1234yf page.

Retrofitting and refilling: what the workshop may do

Article 6 of the Directive is the text a garage applies every day. It has three paragraphs and each answers a different question.

• Retrofitting — paragraph 1. With effect from 1 January 2011, air-conditioning systems designed to contain fluorinated greenhouse gases with a GWP higher than 150 shall not be retrofitted to vehicles type-approved from that date. With effect from 1 January 2017, such systems shall not be retrofitted to any vehicle. Article 3, point (10), defines retrofitting as installing an air-conditioning system in a vehicle after it has been registered.
• Filling — paragraph 2. Air-conditioning systems fitted to vehicles type-approved on or after 1 January 2011 shall not be filled with fluorinated greenhouse gases with a GWP higher than 150. From 1 January 2017 that prohibition extends to all vehicles, with the exception of refilling of air-conditioning systems containing those gases which have been fitted to vehicles before that date.
• Abnormal loss — paragraph 3. Service providers offering service and repair for air-conditioning systems shall not fill such equipment with fluorinated greenhouse gases if an abnormal amount of the refrigerant has leaked from the system, until the necessary repair has been completed.

The practical consequence is easy to state and often got wrong: an older car running on R-134a may still be refilled with R-134a, because the closing exception in paragraph 2 covers it; the same car may not receive a newly installed air-conditioning system designed for R-134a, because paragraph 1 bans retrofitting from 2017 with no exception.

Paragraph 3 overlaps with Article 4(5) of Regulation (EU) 2024/573, which requires equipment where a leak is detected to be repaired without undue delay. The two duties add up: the Directive forbids filling until the repair, the Regulation demands the repair.

Who may do the work and who may buy the gas

Qualification. Article 4(7), third subparagraph, of Regulation (EU) 2024/573 provides that natural persons carrying out the maintenance or servicing and repair of air-conditioning equipment containing fluorinated greenhouse gases in motor vehicles falling within the scope of Directive 2006/40/EC, and of the mobile equipment listed in Article 5(3), point (c), shall hold at least a training attestation in accordance with Article 10(1), second subparagraph. Point (a) of that subparagraph also covers recovering the gases from such equipment.

Which attestation. The minimum requirements are no longer those of Regulation (EC) No 307/2008: that act was repealed by Article 7 of Implementing Regulation (EU) 2025/1893, which replaces it. Article 2(2) of the new act sets out four types:

Article 2(1), second subparagraph, adds a useful bridge: certificates established under Implementing Regulation (EU) 2024/2215 may be considered as covering the requirements of the new act for the relevant substances. Article 2(3) allows work without an attestation only for persons enrolled in a training course, under the supervision of an attestation holder who is fully responsible for the correct execution, for periods not exceeding 24 months in total. Article 6 provides that holders of attestations issued under Article 3 of Regulation (EC) No 307/2008 may continue to use them only if they update their knowledge and skills to the level of M1, M2 or M4.

Recognition across borders. Article 5 of Regulation (EU) 2025/1893: Member States shall not impose additional assessment procedures or disproportionate administrative requirements on holders of attestations issued in another Member State, but may require a translation. The same rule appears in Article 10(10) of Regulation (EU) 2024/573.

Buying the gas. Article 11(6) of Regulation (EU) 2024/573 reserves the purchase of fluorinated greenhouse gases listed in Annex I or in Section 1 of Annex II to certified natural persons, or to undertakings employing certified persons or persons holding a training attestation required under Article 10(1), second subparagraph, where the purpose is installation, maintenance or servicing, or repair of the equipment concerned. Sellers shall sell or offer for sale such gases exclusively to those undertakings. The second subparagraph makes clear that this does not prevent non-certified undertakings which do not carry out those activities from collecting, transporting or delivering the gas.

Both R-134a (Annex I) and R-1234yf (Annex II, Section 1) fall under this rule. What the seller has to see is set out in who can buy refrigerant gas and in selling to service companies. For the certificate categories that cover stationary equipment, see certificate categories.

Recovery: who does it and what happens to the gas

Article 8(1) of Regulation (EU) 2024/573 requires operators of equipment that contains fluorinated greenhouse gases to ensure that those substances are recovered and, after decommissioning, recycled, reclaimed or destroyed.

For motor vehicles the qualification is dealt with expressly. Article 8(4): for the recovery of fluorinated greenhouse gases from air-conditioning equipment in motor vehicles which fall within the scope of Directive 2006/40/EC and from the mobile equipment referred to in paragraph 3, points (b) and (c), only natural persons holding at least a training attestation in accordance with Article 10(1), second subparagraph, shall be considered to be appropriately qualified.

Article 8(10) covers the rest. Operators of products and equipment not listed in paragraph 2, 3, 8 or 9 shall arrange for the recovery of the gases, unless it can be established that it is not technically feasible or entails disproportionate costs. The second subparagraph adds the specific rule: the recovery of gases listed in Annex I and in Section 1 of Annex II from air-conditioning equipment in road vehicles outside the scope of Directive 2006/40/EC shall be carried out only by persons holding at least a training attestation.

• Recovered gas does not go straight back in. Article 8(6): recovered gases listed in Annex I and in Section 1 of Annex II shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed.
• Intentional release. Article 4(1): intentional release into the atmosphere is prohibited where it is not technically necessary for the intended use. Paragraph 3 requires all necessary precautions to prevent unintentional release, including during transport and storage.
• The emptied container. Article 8(7): an undertaking that uses a container with fluorinated greenhouse gases shall, immediately prior to its disposal, arrange for the recovery of any residual gases.

The mechanics of recovery, and what happens to the gas afterwards, are covered in the recovery obligation, and the difference between reclaimed, recycled and virgin gas in the dedicated page.

Buses, trucks, machinery: what changes

The air conditioning of a bus, of a truck cab, of an agricultural tractor or of a tram is not within the scope of Directive 2006/40/EC. For those, Article 5(3), point (c), of Regulation (EU) 2024/573 applies, listing air-conditioning equipment and heat pumps in heavy duty vehicles, vans, non-road mobile machinery used in agriculture, mining and construction operations, trains, metros, trams and aircraft.

• Thresholds. Article 5(1): leak checks are required at 5 tonnes of CO2 equivalent or more of gases listed in Annex I, or 1 kilogram or more of gases listed in Section 1 of Annex II. At a GWP of 1 430, the 5 tonnes of CO2 equivalent threshold corresponds to a charge of roughly 3,5 kilograms.
• Deferral. Article 5(5): paragraphs 1 and 6 shall not apply to operators of mobile equipment under paragraph 3, points (b) and (c), until 12 March 2027.
• Who checks. Article 5(4): for the mobile equipment referred to in paragraph 3, point (c), the checks shall be carried out by persons holding at least a training attestation.
• Existing inspection regime. Article 5(7), second subparagraph: the obligations are deemed to be fulfilled for mobile air-conditioning equipment and heat pumps under paragraph 3, point (c), provided they are subject to a regular inspection regime that includes leak checks.
• Aircraft. Article 10(6) provides that certification programmes and training concerning aircraft are to be reflected in the specifications issued by the European aviation safety agency under Regulation (EU) 2018/1139.

The records of Article 7(1) follow the check duty: they fall on operators of equipment which is required to be checked under Article 5(1). Their content is described in equipment records, and the intervals in leak check frequency.

Refrigeration units of trucks and trailers are an entirely different category, with their own certification and without the deferral above: see refrigerated transport.

Workshop checklist

• Establish the vehicle categoryM1 or N1 class I falls under Directive 2006/40/EC (Article 2). Everything else falls under Article 5(3), point (c), of Regulation (EU) 2024/573.
• Check the type-approval dateArticle 6(2) of the Directive ties the filling prohibition to the type-approval date, not to the year of manufacture or of registration.
• Do not install new systems above GWP 150Article 6(1) of the Directive bans retrofitting to any vehicle from 1 January 2017.
• Find the leak before fillingArticle 6(3) of the Directive forbids filling where an abnormal amount has leaked, until the repair is completed.
• Keep attestations currentRegulation (EU) 2025/1893, Articles 2 and 6: type M1, M2, M3 or M4, and the knowledge update for older attestations.
• Verify the purchase right before ordering gasArticle 11(6): the seller sells exclusively to undertakings that meet the qualification condition.
• Recover, do not ventArticle 4(1) and Article 8(1), (4) and (7) of Regulation (EU) 2024/573.
• Do not put recovered gas straight backArticle 8(6): only after recycling or reclamation.
• Relabel after a gas changeArticle 12(3), third subparagraph.

Frequently asked questions

Official sources

The texts were read in full in the versions published in the Official Journal. The article numbers on this page point to those texts, not to summaries.

How current this page is, and its limits

General information prepared by EgoLog on the basis of the official texts. It is not legal advice and it does not replace the instructions of the vehicle manufacturer or of the service equipment manufacturer.

Work on the refrigerant circuit is carried out only by personnel holding the qualification required by Article 10 of Regulation (EU) 2024/573 and by Implementing Regulation (EU) 2025/1893. A2L refrigerants are handled in accordance with the applicable safety requirements; see safety classes.