Poland: refrigerant rules – the F-gas Act, the CRO register and UDT certification

The EU regulation applies directly, the Polish act complements it

The EU Regulation (EU) 2024/573 on fluorinated greenhouse gases has applied directly in Poland since 11 March 2024 ^[1][3]. The requirements on leak checks, records, recovery and the EU bans on new products and servicing come from it ^[1].

The national law is the Ustawa o substancjach zubożających warstwę ozonową oraz o niektórych fluorowanych gazach cieplarnianych (Act on ozone-depleting substances and certain fluorinated greenhouse gases) of 15 May 2015, Dz.U. 2015 poz. 881. The latest consolidated text is Dz.U. 2020 poz. 2065 ^[2]. Dz.U. 2025 poz. 1863 amended the act with effect from 13 January 2026. We have not verified its content, so check the current wording in ISAP before relying on the details ^[2]. The act was written for the earlier EU regulations and covers certification, the CRO register, annual reporting and penalties ^[2]. The responsible ministry is the Ministerstwo Klimatu i Środowiska (Ministry of Climate and Environment) ^[3][4].

Leak checks under 2024/573

Leak checks are required for systems with 5 tonnes CO2e or more of F-gas, and 10 tonnes CO2e for labelled hermetically sealed systems ^[1]. The regulation now also covers HFOs and other gases in Annex II, with limits in kg instead of tonnes CO2e ^[1][3].

Systems with 500 tonnes CO2e or more must have a leak detection system ^[1]. After a leak has been repaired, the system must be checked again at the earliest after 24 hours of operation and no later than one month after the repair ^[1].

The 5 tonne CO2e limit corresponds, for example, to about 1.3 kg R404A, 2.4 kg R410A, 3.5 kg R134a and 7.4 kg R32. Always calculate with the system's actual refrigerant and charge, for example with the GWP calculator.

Equipment records in the CRO register

Poland's special feature is the Centralny Rejestr Operatorów (CRO) (Central Register of Operators). The operator must create a Karta Urządzenia (equipment record) for stationary refrigeration and air-conditioning equipment and heat pumps with at least 5 tonnes CO2e of F-gas or at least 3 kg of ozone-depleting substances. The records are kept electronically in the CRO ^[2][4].

• The record must be created within 15 working days of the equipment being delivered to its place of operation ^[2].
• Leak checks, top-ups, recovery and other work on the refrigerant circuit must be entered within 15 working days of the work ^[2].
• The operator must make sure the entries are made by a person holding a personnel certificate ^[2].
• The operator opens a CRO account with a registration form. The person filling in the form becomes the account administrator ^[4].
• The register blocks entries with obvious errors or incomplete data ^[4].

Failing to make an entry in the record on time is listed in the act as an infringement that can lead to an administrative fine (kara pieniężna) ^[2].

Certification: UDT

Urząd Dozoru Technicznego (UDT) (Office of Technical Inspection) is the certification body for F-gases and ozone-depleting substances ^[5][6]. There are two kinds of certificate:

• Certyfikat dla personelu (personnel certificate): required for anyone doing leak checks, recovery, installation, repair, maintenance or servicing and decommissioning of stationary refrigeration, air-conditioning and heat pump equipment, and refrigeration units on trucks and trailers. You pass an exam at an assessment body approved by UDT and then apply to UDT. The certificate has no expiry date ^[5].
• Certyfikat dla przedsiębiorców (company certificate): required for companies that install, repair, maintain or decommission such equipment. It has no expiry date, but UDT inspects the company at least once every seven years ^[6].

Personnel certificates are divided into categories I to IV. Category I covers all activities, while the other categories have a limited scope, for example leak checks only ^[5]. Certificates from other EU countries are accepted in Poland with a sworn translation and within the scope and validity for which they were issued ^[5].

Pressure equipment: safety valves

Refrigeration systems with fixed pressure vessels are also covered by the technical supervision rules in Dz.U. 2022 poz. 68 (regulation of the Minister of Development and Technology). Under § 56(1) the operator must maintain the safety valves and check that they work at the intervals set in the operating instructions, but at most every 6 months in ammonia systems and at most every 12 months in other refrigeration systems. The checks are recorded in a logbook. The operator must hold at least one spare safety valve of each valve type used in the system (§ 56(2)). Technical supervision of the equipment is carried out by the technical supervision body, which in Poland is the UDT ^[9].

Annual report to the BDS

Companies that import or export F-gas or products containing F-gas, use it in manufacturing, installation, servicing or maintenance, or recover, reclaim or destroy it must report once a year to the Baza Danych Sprawozdań (BDS) (reporting database). The report is submitted electronically by 28 February for the previous year ^[7].

Changes 2024–2026

• 11 March 2024: the EU Regulation 2024/573 started to apply, with new obligations for operators and HFOs included in leak checks ^[1][3].
• 29 September 2024: Implementing Regulation (EU) 2024/2215 on certification for stationary refrigeration, air-conditioning and heat pump equipment entered into force ^[8].
• May 2026: the draft new Polish F-gas act had not yet been published. Consultation was planned for the second quarter of 2026 and the legislative process was to be completed by the end of 2026 ^[8].

Practical checklist

1. Convert the charge to tonnes CO2e and check whether the system needs leak checks and an equipment record ^[1][2].
2. Create the Karta Urządzenia in the CRO within 15 working days of delivery and enter each intervention within 15 working days ^[2].
3. Make sure the technician holds a personnel certificate and the company a company certificate from UDT ^[5][6].
4. Schedule a new leak check within one month after every leak repair ^[1].
5. Submit the BDS report by 28 February ^[7].
6. Follow the work on the new F-gas act and the new certification rules ^[8].