Japan: フロン排出抑制法, the Kigali HFC phase-down and the High Pressure Gas Safety Act
Refrigerant rules in Japan: inspections and leak reports under フロン排出抑制法, disposal with certificates since 2020, HFC phase-down, GWP targets for units and 高圧ガス保安法.
Key points
- Japan is not in the EU, and the EU F-gas Regulation does not apply. Refrigerants are governed by フロン排出抑制法 (Fluorocarbon Emission Control Act), オゾン層保護法 (Ozone Layer Protection Act) and, for safety, 高圧ガス保安法 (High Pressure Gas Safety Act) [1][6][7].
- The owner or person responsible for commercial refrigeration and air conditioning equipment must carry out a simple inspection at least every three months. Units with a compressor motor of 7.5 kW or more also need a periodic inspection by a qualified person, once a year or every three years [1].
- Charging and recovery may only be done by a company registered with the prefecture as a 第一種フロン類充塡回収業者. As a rule, a leak must be repaired before the unit is recharged [4].
- Since 1 April 2020 anyone who disposes of equipment without having the refrigerant recovered can be fined up to 500,000 yen directly, without a prior order. Recovery certificates are kept for three years [2][4].
- Companies that leak 1,000 t CO2e or more per year must report to the government [3]. Since 2019 HFCs have been phased down under the Kigali Amendment to 85 % below baseline by 2036 [6].
The laws and the authorities
Japan has its own refrigerant laws. フロン類の使用の合理化及び管理の適正化に関する法律, usually called フロン排出抑制法, covers the whole life cycle: the GWP targets manufacturers must meet, how equipment is inspected and serviced, and how refrigerant is recovered at disposal [1]. It is administered jointly by the Ministry of the Environment 環境省 (MOE) and the Ministry of Economy, Trade and Industry 経済産業省 (METI), while the prefectures register and supervise service companies [1][4].
オゾン層保護法 controls production and import of ozone-depleting substances and, since 2019, HFCs [6]. Safety in refrigeration plants is governed by 高圧ガス保安法 and its ordinance 冷凍保安規則 (Refrigeration Safety Regulations) [7]. Releasing fluorocarbons into the atmosphere without good reason is prohibited [1].
Which equipment is covered
The law calls commercial air conditioning and commercial refrigeration and freezing equipment that uses fluorocarbons 第一種特定製品 (Class 1 specified products). The owner or person responsible for the equipment is called the 管理者 (operator) and carries the obligations. Equipment that is not running is also covered as long as it contains refrigerant [1].
Inspections: 簡易点検 and 定期点検
The operator must carry out a simple inspection (簡易点検) of all equipment, for example looking for oil traces, corrosion, damage and abnormal noise. Larger units also need a periodic inspection (定期点検) carried out by, or witnessed by, a person with sufficient knowledge (十分な知見を有する者) [1].
| Equipment | Simple inspection | Periodic inspection |
|---|---|---|
| All commercial refrigeration and air conditioning | At least every 3 months | – |
| Refrigeration and freezing, compressor motor 7.5 kW or more | At least every 3 months | At least once a year |
| Air conditioning, compressor motor 50 kW or more | At least every 3 months | At least once a year |
| Air conditioning, compressor motor 7.5–50 kW | At least every 3 months | At least every 3 years |
Inspections must be recorded. The log is kept until three years after the refrigerant was handed over at disposal [1].
Charging, recovery and certificates
Charging and recovery may only be done by a 第一種フロン類充塡回収業者 (registered charging and recovery business). Registration is with the governor of each prefecture where the company works, requires access to recovery equipment and is valid for five years. Knowledge alone is not enough: without registration the work may not be done [1][4].
- If a leak is found it must be located and repaired before the unit is recharged. One emergency charge is allowed if the leak will certainly be repaired within 60 days [4].
- The company must give the operator a charging certificate (充塡証明書) or recovery certificate (回収証明書) within 30 days. Alternatively the quantities are registered electronically in an approved system within 20 days [4].
- The certificates are the basis for the operator's annual leakage calculation [3][4].
Leak reporting from 1,000 t CO2e
The operator calculates its leakage (算定漏えい量) as refrigerant quantity times GWP. If a company leaks a total of 1,000 t CO2e or more in a fiscal year, it must report to the minister responsible for its industry. If a single site reaches 1,000 t, that site is also reported separately. Reports are filed between 1 April and 31 July for the previous fiscal year, and the government publishes the totals [3].
Disposal: stricter since 2020
The amendment that took effect on 1 April 2020 tightened the rules at disposal [2]:
- Anyone who disposes of equipment without having the refrigerant recovered can be fined directly up to 500,000 yen. Previously guidance, a recommendation and an order came first [2].
- Waste and recycling companies may not accept equipment unless recovery of the refrigerant can be shown [2].
- The operator receives a collection certificate (引取証明書) and keeps the original for three years. A copy goes with the equipment to the waste company [2][4].
- The chain is documented with process control forms (行程管理票): the recovery request, the confirmation of entrustment, the approval of re-entrustment and the collection certificate. They are kept for three years [4].
HFC phase-down under オゾン層保護法
Japan is a developed (non-Article 5) country under the Montreal Protocol. An amendment to オゾン層保護法 (Act No. 69 of 2018) added HFCs and has applied since 1 January 2019. HFC production requires a permit from the METI minister and imports require approval under the Foreign Exchange Act [6].
| Year | Reduction from baseline (average 2011–2013) |
|---|---|
| 2019 | 10 % |
| 2024 | 40 % |
| 2029 | 70 % |
| 2034 | 80 % |
| 2036 | 85 % |
GWP targets for manufacturers: 指定製品
Under the 指定製品 (designated products) scheme, manufacturers and importers get a GWP target for each product group and a target year. The target applies to the shipment-weighted average, not to each individual product [5]. For refrigeration the targets include:
| Product group | GWP target | Target year (fiscal) |
|---|---|---|
| Condensing units and stationary refrigeration units, compressor motor above 1.5 kW | 1,500 | 2025 |
| Central refrigeration systems for new cold stores above 50,000 m³ | 100 | 2019 |
Safety: 高圧ガス保安法
A refrigeration plant that compresses or condenses refrigerant counts as production of high-pressure gas. Depending on the plant's daily refrigeration capacity (冷凍能力, in tons) and its refrigerant, it needs a prefectural permit (第一種製造者) or a notification (第二種製造者), and the smallest plants are exempt. The limits are in the Act (Art. 5) and the Enforcement Order 高圧ガス保安法施行令 (Arts. 2 and 4), not in 冷凍保安規則 [9][10]:
| Refrigerant group | Act does not apply below | Notification (第二種製造者) from | Permit (第一種製造者) from |
|---|---|---|---|
| 第一種ガス: CO2, nitrogen, noble gases, air and fluorocarbons that meet the non-flammability criterion | 5 t/day | 20 t/day | 50 t/day |
| Ammonia and fluorocarbons that do not meet the criterion | 3 t/day | 5 t/day | 50 t/day |
| Other gases, such as propane, isobutane and propene | 3 t/day | 3 t/day | 20 t/day |
Which fluorocarbons meet the non-flammability criterion is set in a METI ministerial order that we have not checked. For A2L refrigerants such as R32 and R1234yf, follow METI material [10]. CO2 moved into the first group on 25 July 2017: plants of 20–50 t/day went from permit to notification [10].
- The operator must appoint a 冷凍保安責任者 (refrigeration safety manager) with the licence required for the capacity. This applies to permit holders and to larger notified plants (Act Art. 27-4) [9].
- A permit holder's plant must pass a 保安検査 (safety inspection) once every three years (冷凍保安規則 Art. 40(2)). [7].
Penalties
- Charging or recovering fluorocarbons as a business without registration, or releasing the refrigerant of a specified product into the atmosphere: up to 1 year in prison or a fine of up to 500,000 yen (Art. 103 nos. 1 and 13, with Arts. 27 and 86) [11].
- Disposing of equipment without having the refrigerant recovered: a fine of up to 500,000 yen (Art. 104 no. 2, Art. 41) [11].
- Not filing the leakage report, or filing a false one: an administrative fine of up to 100,000 yen (Art. 109 no. 1, Art. 19) [11].
Under way in 2026
In August 2026 the government's advisory councils published an interim report on further cutting fluorocarbon emissions. It finds that HFC emissions have started to fall but that more is needed. The proposals include less leakage in operation, better recovery at disposal, more reclamation of refrigerant, continuous monitoring in periodic inspections and stricter rules for household air conditioners. The proposals are not yet law [8].
Practical checklist
- Check that the service company is registered in the right prefecture [4].
- Put the three-monthly simple inspections and the periodic inspections in the service contract [1].
- Repair leaks before recharging and keep all certificates for the leakage calculation [3][4].
- Never dispose of equipment without recovery and a collection certificate [2].
- Check permit or notification under 高圧ガス保安法 for new and modified plants, and plan the three-yearly safety inspection [7][9][10].
Calculate it yourself
Terms in this article
Sources
- 環境省・経済産業省 – フロン排出抑制法 FAQ (updated March 2026)
- 環境省 – 機器管理者の皆様へ: フロン排出抑制法の改正（2020年4月1日施行）
- 環境省 – フロン排出抑制法ポータル: 漏えい量の算定・報告（概要）
- 環境省・経済産業省 – 充塡回収業者・引渡受託者・解体工事元請業者・引取等実施者等に関する運用の手引き
- 経済産業省 – 冷蔵機器及び冷凍機器の製造業者等向けガイドライン (指定製品, last updated April 2026)
- 経済産業省 – 特定物質等の規制等によるオゾン層の保護に関する法律（オゾン層保護法）解説
- e-Gov 法令検索 – 冷凍保安規則 (高圧ガス保安法)
- 環境省・経済産業省 – フロン類のさらなる排出抑制に向けた対策の方向性について（中間とりまとめ, August 2026）
- e-Gov Law Search – 高圧ガス保安法 (High Pressure Gas Safety Act, Act No. 204 of 1951)
- e-Gov Law Search – 高圧ガス保安法施行令 (Enforcement Order of the High Pressure Gas Safety Act)
- e-Gov Law Search – フロン類の使用の合理化及び管理の適正化に関する法律 (Fluorocarbons Act, Act No. 64 of 2001)