Germany refrigerant rules: ChemKlimaschutzV 2026, certificates and leakage limits

The EU regulation applies directly, ChemKlimaschutzV supplements it

The EU Regulation (EU) 2024/573 on fluorinated greenhouse gases has applied in Germany since 11 March 2024 without being transposed into German law ^[3]. Leak checks, records, service bans and bans on new products therefore come from the EU regulation. The German Chemikalien-Klimaschutzverordnung (ChemKlimaschutzV, Chemicals Climate Protection Ordinance) adds national rules and implements the EU regulation ^[1].

The new ChemKlimaschutzV is dated 14 April 2026 (BGBl. 2026 I No. 100) and entered into force on 17 April 2026. It replaced the ordinance of 2008 ^[1][2]. The Bundestag approved the final version on 26 March 2026, after an addition requested by the Bundesrat on 30 January 2026 ^[4]. In addition, the fifth amendment of the Chemikaliengesetz (ChemG, Chemicals Act) entered into force on 2 April 2026. Among other things, it allows the authorities to temporarily ban trading by anyone who seriously or repeatedly breaks the rules ^[2].

German limits on refrigerant losses

A German special rule is that the operator must ensure that the specific refrigerant loss in normal operation does not exceed certain percentages per year. Losses from sudden, exceptional events are not counted. For self-contained units (Kältesätze) with at least 3 kg of refrigerant the limit is 1 percent per year. For systems erected on site the limit depends on the charge and the year of installation ^[1]:

Where technically feasible and reasonable, the operator must also keep all detachable connections accessible. Hermetically sealed, labelled products are exempt ^[1]. These limits apply in addition to the leak check requirements of the EU regulation, which are expressed in tonnes CO2e.

Take-back of refrigerant

Manufacturers and distributors of fluorinated greenhouse gases must take the gases back after use, or ensure that a third party they designate does so. Whoever takes the gases back must keep records of the type, the quantity and where they went. The records must be kept for at least five years and shown to the authority on request ^[1][2].

Personal certificate: Sachkundebescheinigung

Anyone who installs, maintains, repairs, leak checks, recovers refrigerant from or decommissions refrigeration, air conditioning and heat pump equipment needs a Sachkundebescheinigung (certificate of competence). The new ordinance extends the requirement to equipment with alternative refrigerants such as propane, carbon dioxide, ammonia and HFOs ^[5].

• The old category I, known in the trade as Kälteschein, corresponds to certificate A1 once its holder has updated their knowledge and skills; category II corresponds to A2 in the same way. Certificates B (CO2) and C (ammonia) have their own knowledge requirements and are not covered by a category I certificate. Under section 7(1) the new Sachkundebescheinigung is issued on application after a refresher course for the activity concerned ^[1][9].
• New certificates are issued under section 6(1) to people who show a completed technical or craft vocational training and have passed a theoretical and practical exam. Exceptions exist, for example for people who are entered in the Handwerksrolle or can show a comparable qualification (section 6(4)–(5)) ^[1].
• Certificates under the previous rules remain valid until 12 March 2029. To continue working after that date, an approved refresher course is required ^[5].
• Refresher courses must then be taken at least every seven years ^[5].

Certificates are issued by, among others, the chambers of industry and commerce (IHK), the chambers of crafts (HWK) and approved training providers ^[5]. The minimum requirements are the same throughout the EU and are set out in Implementing Regulation (EU) 2024/2215.

Company certificate: Betriebszertifizierung

Companies that install, maintain or repair such equipment for others must be certified. The company must show that it employs enough certified people for the expected volume of work and that they have access to the necessary tools and procedures. The certificate is issued by the authority of the federal state, in Hesse for example the Regierungspräsidium Darmstadt ^[6]. Which authority is competent differs between the federal states. Company certificates issued under the old rules remain valid until 12 March 2029 (section 17(5)); if a new application is filed before that date, the company may rely on the old certificate for nine months from the application (section 10(6)) ^[1].

Labelling and language

Anyone who places labelled products or equipment on the German market must make sure that the information required by Article 12(3) and (5) of Regulation (EU) 2024/573 is given in German in the instructions for use and in advertising material (section 13(1)). For equipment commissioned in Germany, the safety requirements for the site in the label under Implementing Regulation (EU) 2024/2174 must also be in German (section 13(2)) ^[1]. For mobile equipment under Article 5(3)(b)–(c) of the EU regulation, sections 5, 10 and 14 apply from 13 March 2027 (section 17(6)) ^[1].

Authorities, enforcement and penalties

The Umweltbundesamt (UBA, German Environment Agency) provides information on the rules and publishes frequently asked questions on the F-gas Regulation. Enforcement is carried out by the authorities of the federal states. A list of them is kept by the Bund/Länder-Arbeitsgemeinschaft Chemikaliensicherheit (BLAC) ^[2][3].

Breaches of the F-gas Regulation and the ChemKlimaschutzV can lead to fines (Ordnungswidrigkeit) or in some cases criminal penalties under the Chemicals Act. Which breaches are covered is set out in the Chemikalien-Sanktionsverordnung (ChemSanktionsV). It has been adapted to 2024/573, among other things so that buying F-gases or filled products without a certificate can be penalised ^[7].

Anyone who supplies HFCs must also submit a declaration that the quota obligation is met under section 12j of the Chemicals Act ^[2].

Pressure equipment: Betriebssicherheitsverordnung

Refrigeration systems count as pressure installations that must be inspected under the Betriebssicherheitsverordnung (BetrSichV, Industrial Safety Regulation). If the governing pressure vessel has a pressure–volume product above 200 bar·l, an approved inspection body (zugelassene Überwachungsstelle, ZÜS) must inspect the system before commissioning. Smaller systems can be inspected by a competent person (befähigte Person). Where the ordinance sets no intervals, the employer sets the type, scope and interval of periodic inspections in the risk assessment, but the maximum intervals of the ordinance may not be exceeded (section 3(6), Annex 2 section 4 no. 7 table 12, no. 7.2). For closed circuits with fluid group 1 the external check is due at the latest after 5 years if done by a ZÜS or after 10 years if done by a competent person; for other fluids it is 10 years. No internal check is required, and a strength test is needed only when a part is taken out of service for repair. For vessels between 200 and 1,000 bar·l, the periodic checks may be done by a competent person; a ZÜS is required for them only above 1,000 bar·l (tables 3 and 4). Piping for flammable gases (H220, H221) with DN above 25 and PS·DN above 2,000 bar·mm must be checked by a ZÜS (table 8) ^[10].

Practical checklist

1. Check that your certificates are valid after 12 March 2029 and book a refresher course in time ^[5].
2. Work out the system's annual loss and compare it with the German percentage limits, not only with the EU leak check intervals ^[1].
3. Return used refrigerant to the manufacturer or distributor and keep receipts and records for at least five years ^[1].
4. Ask the authority of the federal state about company certification and enforcement ^[3][6].
5. Plan the BetrSichV inspection before commissioning, especially for larger vessels, and keep to the maximum intervals ^[8][10].