France: refrigerant rules, attestation de capacité and fiche d'intervention

The EU regulation applies directly, the Environmental Code supplements it

The EU regulation (EU) 2024/573 on fluorinated greenhouse gases applies directly in France ^[1]. The leak check intervals, record keeping, bans and phase-down therefore come from the EU regulation. How often checks are made depends, among other things, on whether a leakage detection system is installed (Article 5 of the regulation) ^[1][3].

The French rules are in the Code de l'environnement (Environmental Code), in the section on refrigerants used in thermodynamic equipment, articles R543-75 to R543-123 ^[2]. They set the requirements for company and technician attestations, the service record, the annual declaration and the rules for selling refrigerants. The responsible ministry is the Ministère de la Transition écologique (Ministry of Ecological Transition). Its risk prevention directorate DGPR publishes a question-and-answer guide on fluorinated refrigerants, last updated in 2024 ^[4].

Attestation de capacité for the company

A company (opérateur) that installs, services, leak checks or recovers refrigerant from refrigeration, air conditioning or heat pump equipment must hold an attestation de capacité (capacity attestation) under article R543-99 ^[2]. It is issued by an organisme agréé, a certification body approved by the ministry, for the establishment (établissement) that applied ^[5]. The company must have staff with the right personal attestation and the equipment required for the category ^[2][4].

Anyone selling refrigerants must check that the buyer holds a valid attestation de capacité ^[3]. A company that sells refrigerant on to another company takes on the obligations of a distributor ^[4].

Attestation d'aptitude for the technician

Under article R543-106 the company must make sure that the people doing the work hold an attestation d'aptitude (personal attestation) for the type of work and equipment concerned, or an equivalent certificate from another EU country ^[2][4]. A certificate from, for example, Sweden can therefore be accepted, but it must cover the right category.

New categories from 2027

Two arrêtés (ministerial orders) of 21 November 2025 replace the rules from 2008. The order on company attestations was published in the Journal officiel on 6 December 2025 and the one on personal attestations on 10 December 2025 ^[5][6]. The old order of 30 June 2008 ceases to apply on 31 December 2026. Until then attestations can still be issued under the old rules, and from 1 January 2027 the new system applies ^[5].

Technicians with an older attestation d'aptitude in categories I to IV must complete refresher training by 12 March 2029 ^[6]. Company attestations issued after 12 March 2024 are valid until 12 March 2029 at the latest ^[5].

Fiche d'intervention: the service record

The company fills in a fiche d'intervention for every operation that involves handling the refrigerant ^[2]. The current form is **CERFA 15497*04**, in use since July 2024, which adds the new requirements of the EU regulation, among them leak checks of equipment that contains only HFOs ^[7]. The record may be kept electronically (article R543-83) ^[2].

Above certain thresholds, more than 3 kg of HCFC or more than 5 tonnes CO2e of HFC or PFC, the holder of the equipment (détenteur) also signs. Both the company and the holder keep a copy for at least five years and make it available to later service companies and to the authorities (article R543-82) ^[2].

Annual declaration

Every year the company sends a declaration for the previous calendar year to the organisme agréé that issued its attestation. For each refrigerant it states the quantities acquired, charged, recovered and transferred, and the stock on 1 January and 31 December (article R543-100) ^[2][4]. Check the submission deadline with your organisme agréé.

Supervision

The organisme agréé checks that companies meet the requirements and can withdraw an attestation de capacité ^[5]. Plants that are classified industrial installations (installations classées) under heading 1185 also have labelling and inventory requirements ^[3]. Such plants are inspected by the regional environmental authority DREAL, which can also review attestations and declarations.

The HFC tax that never came

The 2019 finance law contained a tax on HFCs (article 302 bis F of the Code général des impôts) due to start on 1 January 2025. It was postponed several times and finally repealed retroactively by the 2025 finance law, promulgated in February 2025. There is therefore no French HFC tax (as of 2026) ^[8]. The EU fee on HFC quotas is paid by producers and importers, not by the service company ^[1].

Practical checklist

• Check that the company holds a valid attestation de capacité for the right category and that it covers the period after 12 March 2029 ^[5].
• Plan refresher training for technicians with older attestations before 12 March 2029 ^[6].
• If you work with CO2 or ammonia: the new categories B and C apply from 2027 ^[6].
• Use CERFA 15497*04 and keep the service records for at least five years ^[2][7].
• Keep running records of refrigerants by type, so that the annual declaration matches the stock ^[2].