Netherlands: refrigerant rules – F-gas Besluit, BRL 100, BRL 200 and STEK

The EU regulation applies directly, the Dutch rules complement it

The EU Regulation (EU) 2024/573 on fluorinated greenhouse gases has applied directly in the Netherlands since 11 March 2024 ^[1]. The requirements for leak checks, records, recovery, labelling and the EU bans on new products and servicing come from it. Leak checks are required for systems with 5 tonnes CO2e or more, and 10 tonnes CO2e for hermetically sealed systems ^[1].

The national basis is the Besluit gefluoreerde broeikasgassen en ozonlaagafbrekende stoffen (decree on fluorinated greenhouse gases and ozone-depleting substances) ^[2]. It is detailed in the Regeling gefluoreerde broeikasgassen en ozonlaagafbrekende stoffen (ministerial regulation of the same name) ^[3]. The Besluit was amended by a decree of 14 July 2025, published in Staatsblad 2025, 199, to implement (EU) 2024/573 and Regulation (EU) 2024/590 on ozone-depleting substances ^[4].

Enforcement lies with the Inspectie Leefomgeving en Transport (ILT, Human Environment and Transport Inspectorate). Among other things, the ILT checks that technicians and companies hold the right certificates. Anyone who suspects that someone works with refrigerants without a valid certificate can report it to the ILT ^[5].

Two certificates: person and company

The Netherlands distinguishes between personal certificates and company certificates. The requirements are set out in two assessment guidelines (beoordelingsrichtlijnen, BRL) referred to by the Regeling and issued by Rijkswaterstaat ^[3]:

Technicians obtain their personal certificate from an examination body. Certified persons and companies are listed in the Centraal Register Techniek (CRT), where clients can check them ^[5].

New from 2025: natural refrigerants too

The new EU regulation extends the training and certification requirements to work with alternatives to F-gases ^[1]. In the Netherlands, personal certification has been required since 29 September 2025 also for work with hydrocarbons, carbon dioxide (R744) and ammonia (R717) ^[6].

The new system has the certificate categories A1, A2, B, C, D and E. Since 29 March 2026 exams are held under BRL 200 version 2.0, and the transition period in BRL 200 applies only to the NH3 and CO2 exams. For those, an extended transition applied until 1 July 2026 ^[6].

Existing certificates remain valid under the conditions on which they were issued, but no later than 12 March 2029. By then every technician must hold a new certificate in the right category. The new certificates are valid for seven years ^[6].

The company certificate BRL 100 version 3.0

BRL 100 version 3.0 formally enters into force on 31 August 2026. Until then, certification bodies may only audit and issue certificates under version 2.0 ^[7]. Under Article 13b of the Regeling (in force 10 October 2026), a company certificate issued before 1 September 2026 under BRL 100 version 2.0 remains valid until a certification body has decided whether the company meets the requirements ^[3]. The BRL transition rules set 31 August 2028 as the latest date ^[7]. During the transition, staff working on systems must meet the requirements of BRL 200 version 2.0 ^[7].

STEK (the industry certification scheme for refrigeration and air-conditioning companies) becomes a stand-alone scheme alongside BRL 100. The STEK requirements in the version of 19 March 2026 enter into force on 1 September 2026. New applications after that date are assessed only against that version ^[8].

Key dates

Leak checks and records

Leak checks follow the EU regulation directly. The interval depends on the refrigerant charge in tonnes CO2e and is extended if the system has a leak detection system ^[1]. After a repair, the system must be checked again at the earliest after 24 hours of operation and no later than one month after the repair ^[1]. Leak checks may only be carried out by persons holding the right certificate ^[1][5].

Pressure equipment: inspection before use and re-inspection

Refrigeration systems are also pressure equipment. Under the Warenwetbesluit drukapparatuur 2016, equipment designated by ministerial regulation must be inspected before first use (keuring voor ingebruikneming) and after each installation at a new location, and re-inspected later (herkeuring) ^[10]. Article 2 of the Warenwetregeling drukapparatuur 2016 designates, among others ^[9]:

• vessels with a gas of fluid group 1 in category III and IV (and category I and II if the gas is unstable, very toxic or explosive);
• vessels with a gas of fluid group 2 in category III and IV;
• piping with a gas of fluid group 1 in category II and III;
• piping with a gas of fluid group 2 in category III.

The categories follow from the classification under the Pressure Equipment Directive. Vessels and piping with liquids are designated at certain categories as well. The inspections are done by an NL-conformiteitsbeoordelingsinstantie (Dutch conformity assessment body) ^[9][10].

Practical checklist

1. Check in the Centraal Register Techniek that both the technician (BRL 200) and the company (BRL 100) are certified ^[5].
2. Make sure technicians working with CO2, ammonia or hydrocarbons hold a certificate in the right category ^[6].
3. Plan renewal of old personal certificates before 12 March 2029 ^[6].
4. Prepare the company for audits under BRL 100 version 3.0 from 31 August 2026 ^[7].
5. Convert the charge into tonnes CO2e to set the leak check interval, for example with the GWP calculator ^[1].