Denmark: refrigerant rules – HFC ban, HFC tax and KMO certification

The EU regulation applies directly, the Danish order goes further

The EU regulation (EU) 2024/573 on fluorinated greenhouse gases applies directly in Denmark ^[1]. The requirements for leak checks, records, recovery and the EU bans on new products and servicing come from there. Leak checks are required for systems with 5 tonnes CO2e or more, and 10 tonnes CO2e for hermetically sealed systems ^[1][3].

Denmark has long had its own, stricter rule: Bekendtgørelse om regulering af visse industrielle drivhusgasser (executive order regulating certain industrial greenhouse gases), currently BEK no. 1511 of 1 December 2025 ^[2]. It replaced BEK no. 1013 of 13 May 2021. The competent authority is Miljøstyrelsen (the Danish Environmental Protection Agency) ^[3].

The basic rule: HFC is banned

The order covers HFC, PFC and SF6, both as pure substances and in mixtures. Import, sale and use are banned as a general rule. What is allowed is listed as exemptions in the annexes to the order ^[2][3]. HFOs (hydrofluoroolefins) are excluded from the order ^[2][4].

For new refrigeration and heat pump systems the exemptions include the following ^[2][3]:

The 5 tonnes CO2e limit corresponds, for example, to about 1.3 kg R404A, 2.4 kg R410A, 3.5 kg R134a and 7.4 kg R32. Always calculate with the actual refrigerant and charge of the system, for example with the GWP calculator.

Miljøstyrelsen states that heat recovery systems installed to meet the building regulations (bygningsreglementet) are covered by the 50 kg exemption ^[4]. Servicing of existing refrigeration and heat pump systems is also exempt ^[3]. Annex 1 also exempts, among other goods, vaccine coolers, mobile refrigeration systems, air conditioning in vehicles and aircraft, low-temperature freezers below −50 °C, laboratory equipment, test facilities for refrigeration equipment, military goods and goods for use on board ships ^[2]. Under section 5(4)–(5), goods acquired in breach of the F-gas regulation can be confiscated, seized or withdrawn from the market, and a serious or repeated breach can lead to a temporary ban ^[2].

If more HFC is needed than the exemptions allow, a dispensation can be requested from Miljøstyrelsen. It can be granted if there are no alternatives, the alternatives cannot be used, they are unreasonably expensive or they cause higher greenhouse gas emissions. Among other things, the application must set out the costs of both the F-gas solution and the alternatives ^[3].

Breaching the order can lead to a fine, and in more serious cases imprisonment for up to two years ^[2].

The tax on HFC

HFC, PFC and SF6 are taxed under the cfc-afgiftsloven (act on tax on ozone-depleting substances and certain industrial greenhouse gases), currently LBK no. 387 of 3 April 2025 ^[6]. Companies that commercially produce or import taxable substances must register with the tax authority ^[6].

The rates are the same in 2025 and 2026 ^[7]:

The rates follow the GWP of the refrigerant. The Ministry of Taxation publishes the full table ^[7].

Certification: KMO

Kølebranchens Miljøordning (KMO) (the refrigeration industry's environmental scheme) approves persons and companies working with refrigerants. The basis is the EU regulation 2024/573, Implementing Regulation (EU) 2024/2215 and Danish orders, including the Working Environment Authority's BEK no. 498 of 22 May 2024 on the use of pressure equipment ^[8].

• A1: F-gas and flammable refrigerants in all quantities in stationary systems ^[8].
• A2: F-gas up to 3 kg and flammable refrigerants up to 1 kg ^[8].
• B: CO2 (R744) ^[8].
• C: ammonia (R717) ^[8].

Personal approvals under the new rules are normally valid for seven years. After that a refresher course is required ^[8]. The old categories I and II can no longer be obtained after 28 September 2025, and holders must upgrade to A1 or A2 within the transition period ^[8]. A company's approval normally follows its highest certified employee, but is limited to systems up to 5 kg if the company is not certified to ISO 9001 ^[8].

Pressure equipment in refrigeration systems: BEK 498/2024

The Working Environment Authority's order BEK no. 498 of 22 May 2024 on the use of pressure equipment has a special annex 7 for refrigeration and heat pump systems ^[9]. The main points:

• Service inspection (eftersyn): at least every 24 months for systems with more than 3 kg and up to 5 kg of refrigerant, and at least every 12 months above 5 kg. It comes in addition to the periodic examination of vessels and piping (annex 7, point 5) ^[9].
• Machinery room: a system with more than 25 kg installed in a building must have compressor, receiver and oil separator in a machinery room without fixed workplaces (point 3). A machinery room below ground may hold at most 250 kg per independent refrigeration unit in each fire cell (point 4.1) ^[9].
• Who may work on it: installation, commissioning, repair, maintenance, inspection and decommissioning of systems above 5 kg may only be done by a sagkyndig virksomhed (qualified company) (point 6.2). Under section 2(2) no. 11 of the order that is a company with a quality system certified to DS/EN ISO 9001:2015 for the activity. The persons doing the work need training and a certificate (point 6.1) ^[9].

Changes 2024–2026

• 11 March 2024: the EU regulation 2024/573 entered into force ^[1].
• 28 September 2025: the new certificates under 2024/2215 apply, and the old categories can no longer be obtained ^[8].
• 27 October–21 November 2025: consultation on updated orders on ozone-depleting substances and industrial greenhouse gases, aligned with the new EU regulations. The planned entry into force was 1 January 2026 ^[5].
• 1 December 2025: BEK no. 1511 was issued and replaced BEK no. 1013 of 2021 ^[2].

Practical checklist

1. Check that the system fits an exemption in BEK no. 1511; otherwise a dispensation or a natural refrigerant is needed ^[2][3].
2. Convert the charge to tonnes CO2e for the 5 tonne limit and for the EU leak check requirements ^[1][2].
3. Include the HFC tax in the cost of charging and servicing ^[7].
4. Make sure both the technician and the company hold the right KMO certificate, and that old certificates are upgraded in time ^[8].
5. For systems above 5 kg: check the ISO 9001 requirement for the company, the 12 or 24 month service inspection and the machinery room rules in BEK 498/2024 ^[8][9].