Swedish refrigerant rules: Ordinance 2016:1128, notification and annual report

The EU regulation applies directly, the Swedish one supplements it

The EU regulation (EU) 2024/573 applies directly in Sweden without being transposed into Swedish law ^[7]. The leak check intervals, the record-keeping requirement, the service bans and the bans on new products therefore come from the EU regulation. The Swedish Ordinance (2016:1128) on fluorinated greenhouse gases adds what the EU regulation leaves to the member states: notification, reporting to the supervisory authority and which authority is competent ^[1]. Ordinance 2016:1128 replaced the earlier Ordinance (2007:846).

The Swedish Environmental Protection Agency (Naturvårdsverket) has proposed how the Swedish ordinances should be adapted to the new EU regulation, and the work is ongoing. During the transition period the annual reporting requirements of the current Ordinance 2016:1128 apply ^[4].

Notification before installation

Anyone who is or will become the operator of stationary refrigeration, air conditioning or heat pump equipment containing 14 tonnes of CO2 equivalent or more must notify the supervisory authority of the installation or conversion before the work is done ^[1][3]. The supervisory authority is normally the municipal environmental or environment and health committee ^[2]. Many municipalities have e-services or forms for the notification.

The 14 tonnes CO2e threshold corresponds to different quantities depending on the GWP of the refrigerant:

Always calculate with the actual charge and refrigerant of the plant. The GWP calculator does the conversion and shows which requirements apply to the quantity.

The annual report

The operator must submit a report to the supervisory authority by 31 March each year if, at any time during the previous calendar year, the operator's installation held 14 tonnes CO2e or more in total (Section 15) ^[1][3][8]. The limit is counted on the sum of all the operator's refrigeration, air conditioning and heat pump units used in the same activity, not unit by unit. Section 4 defines such an installation that way, and the report also covers installations on ships and mobile equipment that are leak-checked. The notification before installation, by contrast, applies per unit of 14 tonnes CO2e or more (Section 14). Neither duty applies to equipment for non-professional use (Section 35) or to equipment used only for research, training and development in refrigeration and heating (Section 43) ^[8]. In Swedish the report is often called kontrollrapport. It is based on the records and shows, among other things, which units there are, the quantity and type of refrigerant, when the checks were carried out and which leaks were repaired. Naturvårdsverket publishes guidance on what the report must contain ^[3].

It is the operator, not the service company, who is responsible for submitting the report. In practice the service company often compiles the information.

Certification in Sweden

People who work on the refrigerant circuit must hold a personal certificate, and companies that carry out the work for others must hold a company certificate. The certificates are issued by certification bodies accredited by Swedac, for example INCERT ^[2]. The minimum requirements for the certificates are the same throughout the EU and are set out in Implementing Regulation (EU) 2024/2215. Swedish rules add time limits: a company certificate may not be older than five years (Section 27), and a personal certificate may not rest on a theory examination older than five years (Section 28). The certificate must come from a body that is accredited and has notified its activity to Naturvårdsverket (Section 22) ^[8]. The ordinance text still refers to the former Regulation (EU) No 517/2014 and the former certification Regulation (EU) 2015/2067 (Section 2), so check the current wording.

In June 2026 the Government sent the memorandum Certificates and attestations under the EU regulation on fluorinated greenhouse gases out for consultation. Among other things, it proposes that certification bodies in some areas should be approved by Naturvårdsverket instead of being accredited. The consultation closed on 28 September 2026 ^[6]. Check what has been decided before relying on the details.

Leak check when work is done on the system

Under Section 10, anyone who installs or converts a refrigerant system, or carries out other work on it, must make sure that a leak check is done in connection with the work. This comes in addition to the periodic checks of the EU regulation. It does not apply to stationary hermetically sealed equipment with less than 5 tonnes CO2e. The check must be done by a person with a personal certificate (Section 16) ^[8].

Supervision and sanction charges

The municipal committee carries out supervision and can request information, carry out inspections and order the operator to correct deficiencies. For certain breaches, for example a notification or report that was not submitted on time or a leak check that was not carried out, an environmental sanction charge is imposed. The charge applies even if the breach was not intentional ^[5]. More serious breaches can lead to penalties under the Environmental Code.

Pressure equipment at work (AFS 2023:11)

Separate from the F-gas rules, the Swedish Work Environment Authority regulation AFS 2023:11 sets duties for employers who use pressurised devices. Vessels and pipes are put in class A or B from the pressure at which the safety device opens (chapter 9, Section 28) ^[8]. The limits that matter in refrigeration:

• Vessels with a flammable gas in group 1a (for example propane, R32) and a volume above 1 litre: class B above 50 bar·litres, class A above 1,000 bar·litres (Section 32, table 3).
• Vessels with a gas in group 2a (for example HFCs and CO2): class A above 1,000 bar·litres. A vessel in a refrigeration or heat pump system with a group 2a gas that would otherwise be class B is not classified at all.
• Pipes are classed by pressure times DN (Section 33, tables 5 and 6). For group 1a gas, pipes from DN 25 upwards can be class B or A.

A device in class A or B may not be pressurised until an inspection body has made an initial inspection (chapter 10, Sections 7 and 9). Breaking this leads to a sanction charge of SEK 15,000 to 300,000 (Section 8). Recurring inspection is a functional test (driftprov) by an inspection body, and for vessels in a refrigeration or heat pump system the basic interval is one year (chapter 10, Section 10 and appendix 7, table 12). Vessels with a refrigerant that does not corrode the pressure-bearing material are exempt from internal and external examination (chapter 10, Section 5). Check the current text of AFS 2023:11 for your case.

Terms that have disappeared

Those who have worked in the trade for a long time remember expressions such as recurring inspection by an accredited inspection body, inspection of plants with more than 3 kg and fixed limits in kilograms. They come from older Swedish rules on F-gas checks. Today the thresholds are expressed in tonnes CO2e under the EU regulation, leak checks are carried out by certified persons and companies, and the intervals depend on the quantity and on whether a leakage detection system is installed. This concerns the F-gas checks only: pressure vessels are still inspected under AFS 2023:11, see the section above.