Norway refrigerant rules: EEA, produktforskriften, HFC tax and certification

The EU rules apply via the EEA Agreement

Norway is not an EU member, but the EU F-gas rules apply through the EEA Agreement. An EU regulation does not apply directly in Norway. It must first be incorporated into the EEA Agreement by a decision of the EEA Joint Committee and then implemented in Norwegian law. Regulation (EU) No 517/2014 has been incorporated into the EEA Agreement with adaptations and applies in Norway through a reference in produktforskriften (forskrift om begrensning i bruk av helse- og miljøfarlige kjemikalier og andre produkter, the Product Regulations) § 6a-1 ^[1][2]. Chapter 6a of produktforskriften covers fluorinated greenhouse gases.

The new EU Regulation (EU) 2024/573 has applied in the EU since 11 March 2024. According to the Government's EEA note from February 2026 it had not yet been incorporated into the EEA Agreement. It is considered EEA-relevant, but Norway needs adaptations, among other things to the dates of the bans on placing certain products on the market (Article 11). Once incorporated, it is to be implemented in produktforskriften § 6a-1 ^[2]. Miljødirektoratet writes that the changes to Norwegian law will first go out for national consultation and that it cannot yet say when ^[1].

Authority and enforcement

Miljødirektoratet (the Norwegian Environment Agency) is responsible for the Product Regulations and the Waste Regulations as regards F-gases, publishes guidance and designates the certification bodies ^[1][3]. So a national authority, not the municipality as in Sweden, is the main actor. Skatteetaten (the Norwegian Tax Administration) administers the HFC/PFC tax ^[4].

Leak checks and records

Because 517/2014 still applies in Norway, leak checks depend on the quantity in tonnes CO2e under that regulation ^[6]:

Hermetically sealed systems with less than 10 t CO2e do not need leak checks if they are labelled as hermetically sealed. The operator must keep records of, among other things, the quantity and type of refrigerant, quantities added and recovered, and the results of the checks ^[6]. Since 2020 it has been prohibited to use F-gases with a GWP of 2500 or more to service refrigeration systems with 40 t CO2e or more ^[7].

Certification of persons and companies

Anyone who installs, services, leak checks or recovers refrigerant from stationary refrigeration, air conditioning and heat pump equipment must hold a personal F-gas certificate, and companies that carry out the work for others must hold a company certificate. This also applies to a sole trader working for third parties ^[3]. Miljødirektoratet designates the certification bodies. Isovator AS certifies persons and companies for refrigeration and heat pumps, while Incert AB certifies personnel for electrical switchgear containing F-gases ^[3]. Isovator runs a web service where retailers can check which persons and companies are certified ^[3].

A Norwegian special rule is that certificates are valid for five years. Since 1 July 2022, personal and company certificates older than five years must be renewed. Training attestations (opplæringsbevis) have no time limit ^[3].

Tax on HFCs and PFCs

Norway levies an excise duty, avgift på hydrofluorkarboner (HFK) og perfluorkarboner (PFK) (tax on hydrofluorocarbons and perfluorocarbons). It covers imports and production of the gases in bulk, and also imports of mixtures and products in which the gases are a component, for example air conditioning units ^[4]. In 2026 the rate is NOK 1.639 per kg of gas multiplied by the GWP of the gas, which equals NOK 1,639 per tonne CO2e. In 2025 it was NOK 1,405 per tonne CO2e ^[4][8]. Recycled HFCs and PFCs are among the exemptions ^[4].

Refund on destruction

Anyone who hands in HFCs or PFCs to an approved reception facility for destruction receives a refund. From 1 January 2026 the rate is NOK 1.405 per kg of destroyed gas times the GWP of the gas. The rate was frozen at the 2025 level and is set in avfallsforskriften (the Waste Regulations) § 8-3. The decision is based on a 2024 evaluation which found that higher rates did not increase the amount of gas collected, and Miljødirektoratet is continuing with an overall review of the scheme ^[5].

Worked example with GWP values from 517/2014 (rounded, NOK per kg) ^[4][5][6]:

The tax makes high-GWP HFCs expensive to top up. It is one important reason why CO2 (R744), ammonia and hydrocarbons are common in Norwegian plants. Always check the GWP values and rates that Skatteetaten publishes for the current year.

Practical checklist

• Work from 517/2014 and produktforskriften chapter 6a until 2024/573 is incorporated into the EEA Agreement ^[1][2].
• Check that your personal certificate and the company certificate are not older than five years ^[3].
• Calculate the leak check interval in tonnes CO2e, not in kg ^[6].
• Hand in used refrigerant to an approved facility so that the tax can be refunded ^[5].
• Include the tax in the cost estimate when you choose the refrigerant for a new plant ^[4].