Quick answer
Fluorinated refrigerant gas is not an ordinary product. Under Article 11(6) of Regulation (EU) 2024/573, only two kinds of buyer may purchase gases listed in Annex I or Section 1 of Annex II for the purpose of installing, maintaining, servicing or repairing equipment:
- a natural person who holds a certificate required under Article 10(1), first subparagraph, point (a); or
- an undertaking that employs such a certified person, or a person holding the training attestation required under Article 10(1), second subparagraph.
The same paragraph binds the other side of the counter: sellers shall sell or offer for sale, directly or indirectly, such gases exclusively to those undertakings. That is why a legitimate supplier will not release a cylinder against a company name alone.
A seller who supplies uncertified buyers is in breach in their own right. Article 31 requires Member States to lay down effective, proportionate and dissuasive penalties.
What Article 11(6) actually says
The restriction is tied to a purpose and to a list of equipment, not to the gas alone.
| Element | Detail |
|---|---|
| Which gases | Fluorinated greenhouse gases listed in Annex I or in Section 1 of Annex II. |
| For what purpose | Installation, maintenance or servicing, or repair of equipment containing those gases or whose functioning relies on them. |
| Which equipment | The equipment in Article 5(2), points (a) to (f), and Article 5(3), points (a) and (b). |
| Who may buy | Certified natural persons, or undertakings employing certified persons or holders of a training attestation. |
| Who is bound to check | The seller, directly and indirectly. |
Article 5(2) covers stationary refrigeration, air conditioning equipment, heat pumps, fire protection equipment, organic Rankine cycles and electrical switchgear. Article 5(3)(a) and (b) cover the refrigeration units of refrigerated trucks and trailers, and of refrigerated light-duty vehicles, intermodal containers including reefers, and train wagons.
Where the rule stops — logistics and transport
The second subparagraph of Article 11(6) makes an explicit carve-out. The restriction does not prevent non-certified undertakings that do not carry out those activities from collecting, transporting or delivering gases listed in Annex I and Section 1 of Annex II.
So a haulier, a courier or a warehouse does not need a certificate to move a cylinder. The condition is that they are not the ones installing, servicing or repairing. The moment a driver connects a hose, the exception no longer describes what they are doing.
The exception is about who handles the goods in transit, not about who the goods end up with. The buyer at the end of the chain still has to meet Article 11(6), and the seller still has to have checked.
Selling equipment that is already charged
A second restriction sits next to the gas rule and is missed far more often. Under Article 11(7), non-hermetically sealed equipment charged with gases listed in Annex I and Section 1 of Annex II may only be sold to an end user where evidence is provided that the installation is to be carried out by an undertaking certified in accordance with Article 10.
In practice this affects anyone selling split systems, condensing units or charged assemblies to a customer who is not themselves a certified installer. The seller has to hold evidence of who will install it — and Article 7(4) requires those records to be kept.
Hermetically sealed equipment is outside this restriction, which is why a plug-in unit can be sold over the counter and a split system cannot.
What the seller has to record
Article 7 turns the sales restriction into a paper trail. Two separate record duties apply to sellers.
| Record | Content | Kept for |
|---|---|---|
| Bulk gas sales — Article 7(3) | The certificate number of each purchaser, and the respective quantities of gases purchased. | At least 5 years |
| Charged equipment sales — Article 7(4) | The equipment sold, and the certified undertakings that will carry out the installation. | At least 5 years |
Both sets have to be made available on request — the Article 7(3) records to the competent authority of the Member State concerned or to the Commission, the Article 7(4) records to the competent authority.
The regulation asks for the certificate number, because that is what lets an inspector verify the certificate against the issuing body's own register. A scan of a card without a legible number does not do the job.
Who may place bulk gas on the EU market at all
Buying is one question; being the undertaking that first supplies the gas in the Union is another. Article 11(8) restricts that too: only undertakings with an establishment within the Union, or that have appointed an only representative established in the Union who assumes full responsibility for compliance with the regulation, may place bulk fluorinated greenhouse gases on the market and subsequently supply them.
The regulation allows that only representative to be the same representative appointed under Article 8 of Regulation (EC) No 1907/2006 — the REACH only representative.
Alongside this sit the F-gas Portal registration, the licence and, for hydrofluorocarbons, quota. Those are covered separately in the guides on portal registration and on importing HFCs.
The container itself: refillable only
Even a properly certified buyer cannot lawfully accept gas in any container. Article 11(3) prohibits the import, any subsequent supply or making available to others in the Union, use or export of non-refillable containers for gases listed in Annex I and Section 1 of Annex II — empty, partially filled or fully filled. Such containers may only be stored or transported for subsequent disposal. Laboratory and analytical uses are excluded.
The regulation defines non-refillable in two ways: containers that cannot be refilled without being adapted for that purpose, and containers that could be refilled but are imported or placed on the market without provision having been made for their return for refilling.
The second limb is the one that catches people out. A cylinder that is technically refillable but sold with no return arrangement is treated as non-refillable. Annex IV, point 1, has prohibited the placing on the market of non-refillable containers since 4 July 2007.
Under Article 11(4), an undertaking that places refillable containers on the market has to produce a declaration of conformity with evidence of binding return arrangements — naming the actors, their obligatory commitments and the logistics. It has to be kept for at least five years. Suppliers to end users have to keep evidence of compliance with those arrangements for five years as well.
What a buyer should be ready to present
The certificate itself
Issued under Article 10 for the relevant activity and equipment. The certificate states the type and what the holder may do.
The certificate number
This is the field the seller has to record under Article 7(3). Make sure it is legible on whatever you send.
Who the certificate belongs to
For a company purchase, the certified natural person is an employee of the buying undertaking. The seller records the purchaser.
The intended purpose
The restriction applies to purchases for installation, maintenance, servicing or repair of the covered equipment.
For charged equipment, the installer
Where the purchase is non-hermetically sealed charged equipment, evidence of which certified undertaking will install it.
Current validity
Certificates issued under Regulation (EU) No 517/2014 remain valid on their original conditions, but refresher training obligations now apply.
Buying from a supplier in another Member State
A certificate issued in one Member State is valid in the others. Article 10(10) requires Member States to recognise certificates and training attestations issued elsewhere in the Union, and not to restrict the freedom to provide services or the freedom of establishment because a certificate came from another Member State.
Implementing Regulation (EU) 2024/2215 sets the conditions. Mutual recognition applies to certificates issued in accordance with its Article 4 for natural persons and Article 6 for legal persons, for the activities specified in them. Member States may not impose extra evaluation or disproportionate administrative requirements on the holder — but they may ask for a translation of the certificate into another official language of the Union.
A Romanian supplier cannot refuse a valid Spanish certificate as such. It can ask for a translation, and it still has to record the certificate number.
Common mistakes
- Assuming a company registration is enough. Article 11(6) is about certification, not about being a registered business.
- Thinking only the buyer is exposed. The seller is bound by the same paragraph and has to hold the records.
- Treating a delivery driver as a purchaser. Transport is carved out, but the person who eventually receives the gas for servicing is not.
- Selling a charged split system to an end user without asking who installs it. Article 11(7) requires evidence, and Article 7(4) requires it on file.
- Accepting a “refillable” cylinder with no return arrangement. Without provision for return, the regulation treats it as non-refillable.
- Recording the buyer's name instead of the certificate number. Article 7(3) asks for the number.
- Discarding sales records after a year. Five years is the minimum on both record sets.
Checklist
- Certificate held for the activity and equipmentIssued under Article 10 and covering what you actually do.
- Certificate number available to the sellerLegible, and matching the certified person employed by the purchasing undertaking.
- Seller records set upPurchaser certificate numbers and quantities, kept five years.
- Charged-equipment sales documentedEvidence of the certified undertaking that will install, kept five years.
- Cylinders are refillable with a return arrangementNot merely refillable in principle.
- Declaration of conformity on fileFor anyone placing refillable containers on the market, with the binding return arrangements.
- Establishment or only representative in placeFor undertakings placing bulk gas on the Union market.
- Cross-border certificates acceptedRecognised across Member States; a translation may be requested.
Frequently asked questions
Why does the supplier want my certificate number?
Because Article 11(6) allows the sale only to certified buyers, and Article 7(3) requires the seller to record the certificate number of each purchaser together with the quantities purchased, and to keep those records for at least five years.
Can I buy gas as a company without a certified employee?
Not for installation, maintenance, servicing or repair of the covered equipment. Article 11(6) requires the undertaking to employ a person holding the relevant certificate, or a training attestation where that is the applicable qualification.
Does a transport company need a certificate?
No. Article 11(6), second subparagraph, allows non-certified undertakings that do not carry out those activities to collect, transport or deliver the gases.
Can I sell a charged split system to a private customer?
Only where evidence is provided that the installation will be carried out by an undertaking certified in accordance with Article 10. That applies to non-hermetically sealed equipment charged with the listed gases, under Article 11(7).
Is my certificate from another Member State valid here?
Yes. Article 10(10) requires mutual recognition, and Implementing Regulation (EU) 2024/2215 sets the conditions. A translation into another official language of the Union may be requested, but no additional evaluation may be imposed.
Are disposable cylinders allowed for professional use?
No. Article 11(3) prohibits the import, supply, making available, use and export of non-refillable containers for the listed gases, and Annex IV point 1 has prohibited placing them on the market since 4 July 2007.
Do certificates issued under the old regulation still work?
Yes. Article 10(9) provides that existing certificates and training attestations issued under Regulation (EU) No 517/2014 remain valid in accordance with the conditions under which they were issued. Refresher training obligations now apply on top.
Can a company outside the EU supply bulk gas directly?
Not on its own. Article 11(8) allows only undertakings established in the Union, or those that have appointed an only representative established in the Union assuming full responsibility for compliance, to place bulk fluorinated greenhouse gases on the market and supply them.
Official sources
Articles 7, 10 and 11 were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
Certification schemes are run nationally and the practical documentation a supplier asks for can vary between Member States. The article references here were checked on the verification date shown at the top of the page.
This is general information prepared by EgoLog from the regulation and official Commission material. It is not legal advice.
Whether a specific purchase falls under Article 11(6) depends on the gas, the equipment and the purpose. Where it is unclear, ask your national competent authority before ordering.