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Portugal: refrigerant rules – Decreto-Lei 145/2017, APA certification and reporting

What applies in Portugal in addition to the EU F-gas Regulation: Decreto-Lei 145/2017, certification of technicians and companies, annual reporting to APA and registration fees.

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Key points

  • The EU Regulation 2024/573 applies directly in Portugal. The national law is Decreto-Lei n.º 145/2017 of 30 November 2017, and the competent authority is the Agência Portuguesa do Ambiente (APA) [1][2].
  • Technicians are certified under Implementing Regulation (EU) 2024/2215 by certification bodies recognised by APA, among others in the categories A1, A2 and E [2][7].
  • Companies that install and service refrigeration, air-conditioning and heat pump equipment for others must be certified [4].
  • Operators report to APA every year by 31 March, and purchases and sales of F-gas are reported by 30 June of the following year [5][8].
  • According to APA, Decreto-Lei 145/2017 is being revised to follow the new EU regulation (as of December 2025) [6].

The EU regulation applies directly

The EU Regulation (EU) 2024/573 on fluorinated greenhouse gases applies directly in Portugal [1]. It sets the requirements for leak checks, records, recovery, and the EU bans on new products and on certain refrigerants for servicing [1].

Leak checks are required for systems with 5 tonnes CO2e or more, and 10 tonnes CO2e for hermetically sealed systems. The intervals depend on the charge in tonnes CO2e [1]:

Charge (tonnes CO2e)Without leak detectionWith leak detection
5 to under 50every 12 monthsevery 24 months
50 to under 500every 6 monthsevery 12 months
500 or moreevery 3 monthsevery 6 months

Systems with 500 tonnes CO2e or more must have a leak detection system. After a leak has been repaired, a certified person must check the system again within one month [1].

Since 1 January 2025, F-gases with a GWP of 2500 or more may not be used to service any refrigeration equipment; military equipment and equipment cooling products below −50 °C are exempt. Reclaimed or recycled refrigerant may be used until the end of 2029 [1].

The national law: Decreto-Lei 145/2017

Decreto-Lei n.º 145/2017 (decree-law no. 145/2017) of 30 November 2017 implements the EU F-gas rules in Portugal. It has applied since 1 January 2018 and replaced Decreto-Lei n.º 56/2011 [2]. It was corrected by Declaração de Retificação n.º 3-A/2018 [8].

The decree-law was written for the old Regulation (EU) No 517/2014. APA now applies it together with 2024/573, and in a document from December 2025 APA states that the decree-law is being revised [2][6][8].

The competent authority is the Agência Portuguesa do Ambiente (APA, Portuguese Environment Agency). In the Azores, the regional environment authority Direção Regional do Ambiente e Ação Climática (DRAAC) provides information on the rules [2][8].

Certification of technicians

Technicians who work on the refrigerant circuit must be certified. Certificates are issued by certification bodies recognised by APA, and recognition is applied for electronically [2]. The basis today is Implementing Regulation (EU) 2024/2215, which replaced (EU) 2015/2067 [7].

  • A1: technicians for F-gases and hydrocarbons [7].
  • A2: equipment with less than 3 kg, or hermetically sealed systems with less than 6 kg [7].
  • E: leak checks without breaking into the refrigerant circuit [7].

If you hold a certificate from another EU country, APA can recognise it. APA has a specific procedure for persons and companies who want to work in Portugal with a certificate from another Member State [6].

Certification of companies

Companies that install, repair, maintain or decommission stationary refrigeration, air-conditioning and heat pump equipment containing F-gases must be certified under 2024/2215. The requirement in Article 13(1) of Decreto-Lei 145/2017 only applies when the company provides services to others [4].

Companies are certified by four certification bodies, CERTIF, eiC, SGS and APCER, using technical specifications published by APA [4].

Buying and selling refrigerant

According to APA, F-gases may only be sold to and bought by companies holding the relevant certificates, or companies with certified staff [5]. The seller must keep records of buyers, with certificate numbers and quantities bought [1][5].

Purchases and sales are reported to APA once a year. The data for a calendar year must be submitted by 30 June of the following year [5].

Annual reporting and fees

Operators of equipment containing F-gases report to APA every year through the electronic platform SILiAmb. The data for the previous year must be submitted by 31 March [8].

Portaria n.º 92/2020 (ministerial order) sets the fees for the platform. Registering, for example, stationary air-conditioning equipment and heat pumps costs EUR 17, and registering purchases and sales costs EUR 24. APA collects the fees [3].

The fees in Portaria 92/2020 date from 2020, and Decreto-Lei 145/2017 is being revised. Check current amounts and rules with APA before you quote or report [3][6].

Changes 2024–2026

  • 11 March 2024: the EU Regulation 2024/573 entered into force [1].
  • 1 January 2025: ban on F-gases with a GWP of 2500 or more for servicing any refrigeration equipment [1].
  • December 2025: APA publishes a new procedure for recognising certificates from other EU countries and states that Decreto-Lei 145/2017 is being revised [6].
  • 31 March 2026: deadline for operators' report on 2025 [8].
  • 30 June 2026: deadline for the report on purchases and sales in 2025 [5].

Practical checklist

  1. Convert the charge to tonnes CO2e to see whether the system needs leak checks and leak detection [1].
  2. Make sure technicians hold a 2024/2215 certificate in the right category, and that foreign certificates are recognised by APA [6][7].
  3. If the company works for customers, it must be certified by one of the recognised certification bodies [4].
  4. Only buy and sell refrigerant to and from certified companies, and keep the data for the 30 June report [5].
  5. Report equipment data in SILiAmb by 31 March [8].
  6. After every leak repair, make sure a new check is done within one month [1].
Read the current legal text on diariodarepublica.pt and APA's pages on gases fluorados (apambiente.pt). The revised decree-law will also be published there when it is ready [2][4][5][6].

Calculate it yourself

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Terms in this article

F-gases (fluorinated greenhouse gases)CO2 equivalent (CO2e)GWP (global warming potential)Leak checkLeakage detection systemF-gas certificateOperatorRefrigerant recoveryHFC (hydrofluorocarbons)HFC phase-down

Sources

  1. Regulation (EU) 2024/573 on fluorinated greenhouse gases – EUR-Lex
  2. Diário da República – Decreto-Lei n.º 145/2017, de 30 de novembro (gases fluorados com efeito de estufa)
  3. Diário da República – Portaria n.º 92/2020 (taxas da plataforma de gases fluorados)
  4. Agência Portuguesa do Ambiente (APA) – Certificação de Empresas (AVACR)
  5. Agência Portuguesa do Ambiente (APA) – Compra e Venda de Gases Fluorados
  6. Agência Portuguesa do Ambiente (APA) – Procedimento para o reconhecimento da certificação obtida noutro Estado-Membro (dezembro 2025)
  7. IPAC – Procedimento de certificação de técnicos de gases fluorados (Regulamento de Execução (UE) 2024/2215)
  8. Direção Regional do Ambiente e Ação Climática (Açores) – Gases Fluorados com Efeito de Estufa
Disclaimer: This text is guidance, not legal advice. It summarises regulations and standards and does not replace the official text. Always check the version in force and local requirements.

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