Switzerland refrigerant rules: ChemRRV Annex 2.10, refrigerant licence and reporting
What applies in Switzerland: its own rules in ChemRRV Annex 2.10 instead of the EU F-gas Regulation, the Fachbewilligung, Wartungsheft, reporting duty and new bans from 2027.
Key points
- Switzerland is in neither the EU nor the EEA. The EU F-gas Regulation (EU) 2024/573 therefore does not apply. Refrigerants are regulated in the Chemikalien-Risikoreduktions-Verordnung (ChemRRV, SR 814.81), Annex 2.10, and BAFU is the competent federal authority [1][2].
- Professional work with refrigerants requires a Fachbewilligung (refrigerant licence). Since 1 March 2020 a new licence covers one area: vehicle air conditioning or stationary equipment [4][8].
- Systems with more than 3 kg of refrigerant need a Wartungsheft (maintenance log) and must be reported to BAFU's reporting office at commissioning and decommissioning [5][6].
- Refilling with new refrigerant with a GWP of 2500 or more is banned in all systems. According to BAFU, refilling with such refrigerants is banned entirely from 1 January 2030 [7].
- On 29 October 2025 the Federal Council adopted tighter rules in Annex 2.10 modelled on the EU. The new rules on placing systems on the market apply from 1 January 2027 [2][3].
Own rules, not the EU F-gas Regulation
Switzerland is not a member of the EU or the EEA. The EU F-gas Regulation (EU) 2024/573 therefore does not apply in Switzerland, neither directly nor through an agreement. Instead, the rules for refrigerants are in the Chemikalien-Risikoreduktions-Verordnung (ChemRRV, Chemical Risk Reduction Ordinance, SR 814.81), Annex 2.10 [1]. The annex covers ozone-depleting substances and substances that are stable in air (in der Luft stabile Kältemittel), which include HFCs [1][2].
BAFU (Bundesamt für Umwelt, the Federal Office for the Environment, FOEN) is responsible for the rules, publishes guidance (Vollzugshilfen) and can grant exemptions from the bans on request when compliance is not possible according to the state of the art (Stand der Technik) [1][2]. Several revisions have aligned the rules with the EU, but thresholds, dates and terms differ [3].
Bans on placing systems on the market
Since 1 December 2013, stationary refrigeration and air-conditioning systems and heat pumps using refrigerants stable in air may only be placed on the market below certain cooling capacity limits. Since 1 January 2020 there have also been limits on the GWP of the refrigerant. The bans include imports [1][2]. The limits differ between, among others, medium-temperature and low-temperature refrigeration, comfort cooling and heat pumps, and have been tightened several times, most recently on 1 January 2025 for heat pumps among others [2][6].
The limits change often. Read the current values in Annex 2.10 section 2.1 and in BAFU's graphic summary before you choose a refrigerant for a new system [1][2]. In the version of 16 July 2026, Annex 2.10 defines medium-temperature refrigeration (Pluskühlung) as 0 °C or above, low-temperature (Minuskühlung) as down to −25 °C, and freezing (Tiefkühlung) as below −25 °C. For food refrigeration with HFCs, it bans among other things low-temperature and freezing systems above 30 kW and medium-temperature systems above 40 kW, refrigerants with a GWP above 1,500, and self-contained appliances with a GWP of 150 or more.
Refilling existing systems
Existing systems may still be operated, serviced and repaired. Refilling, however, is restricted [2][7]:
- Refilling with new refrigerant that is stable in air and has a GWP of 2500 or more is banned in all systems. Only reclaimed refrigerant may be used [7].
- From 1 January 2030, refilling with refrigerants with a GWP of 2500 or more is banned even with reclaimed refrigerant; reclaimed refrigerant may be used until 31 December 2029 (Annex 2.10 section 7(4)(c), version of 1 January 2027) [9].
- Ozone-depleting refrigerants such as R11 and other CFCs may not be placed on the market or refilled [7].
Wartungsheft, leak checks and reporting
Annex 2.10 places duties on the owner (Inhaber) of the system. BAFU explains them in guidance UV-0615 [1][6]:
| Duty | Applies to | Content |
|---|---|---|
| Wartungsheft (maintenance log) | Systems and appliances with more than 3 kg of refrigerant, of any type | Leak checks, repairs and refills are recorded |
| Dichtigkeitskontrolle (leak check) | More than 3 kg of ozone-depleting or air-stable refrigerants, e.g. HFCs | Regularly, at least at every intervention and every service; leaks repaired immediately |
| Meldepflicht (reporting duty) | Stationary systems with more than 3 kg of refrigerant, of any type | Report at commissioning, recommissioning and decommissioning |
In cascade systems the refrigerant quantities are added together when deciding whether the 3 kg limit is exceeded [6]. The reporting office is run by the company Lombardi SA on behalf of BAFU. BAFU recommends reporting electronically via cooling-reg.ch. Paper forms are still accepted [5]. Older material names other reporting offices. Use the details on BAFU's page [5]. According to the version of 16 July 2026, leak checks are required for systems with more than 3 kg or more than 5 t CO2e, and systems with 500 t CO2e or more must have a leak detection system (transition period until 31 December 2026).
Fachbewilligung for refrigerants
Anyone who professionally manufactures, installs, services or disposes of refrigeration, air-conditioning or heat pump systems with refrigerants must hold a Fachbewilligung für den Umgang mit Kältemitteln (licence for handling refrigerants) or a recognised equivalent qualification. The requirements are set out in the Verordnung des UVEK über die Fachbewilligung für den Umgang mit Kältemitteln (VFB-K, SR 814.812.38) [4].
Since 1 March 2020 the licence is issued for one of two areas: vehicle air conditioning, or other stationary refrigeration, air-conditioning and heat pump systems [4][8]. A company working with refrigerants must have at least one responsible person licensed for the relevant area [8].
Changes 2024–2026 and from 2027
On 1 January 2025 a revision of Annex 2.10 entered into force. It tightened the refill ban and introduced new restrictions on placing heat pumps, among others, on the market [2][6].
On 29 October 2025 the Federal Council adopted the next amendment of Annex 2.10. According to the explanations from BAFU and UVEK it includes [2][3]:
- Tighter rules on placing stationary systems with air-stable refrigerants on the market, modelled on Regulation (EU) 2024/573. They apply from 1 January 2027 [2][3].
- For heat pumps, heating capacity becomes the decisive quantity, so that the capacity limits match those of the EU [3].
- New rules for systems with HFO refrigerants, including leak checks for systems with more than 3 kg of HFO, to reduce emissions of HFOs and the formation of TFA [3].
- From 1 January 2032 the refill ban is tightened: refrigerants with a GWP of 750 or more may only be refilled as reclaimed refrigerant in commercial and industrial refrigeration for food and perishables, industrial process cooling and artificial ice rinks; until 31 December 2031 virgin refrigerant may still be used. Systems with a secondary circuit, systems serving safety in nuclear power plants, and systems below −50 °C when no reclaimed refrigerant is available are exempt, and the ban does not cover building air conditioning or heat pumps [3][9].
The version that applies from 1 January 2027 (Stand am 1. Januar 2027) sets the following bans on placing new stationary systems with air-stable refrigerants on the market [9]:
| System | Banned from 1 January 2027 |
|---|---|
| Comfort cooling and process cooling | Above 200 kW; GWP 750 or more; GWP 150 or more at 12 kW or less, in self-contained units and with direct expansion |
| Food refrigeration, medium temperature (Pluskühlung, 0 °C or above) | Above 12 kW, or GWP 750 or more |
| Food refrigeration, low temperature (Minuskühlung, down to −25 °C) | Above 8 kW, or GWP 750 or more |
| Food refrigeration, freezing (Tiefkühlung, below −25 °C) | Above 8 kW, or GWP 1,500 or more |
| Food refrigeration, self-contained or with a secondary circuit | GWP 150 or more |
| Heat pumps | Above 250 kW heating capacity; GWP 750 or more; GWP 150 or more at 12 kW or less and in self-contained units |
| Ice rinks | Permanent rinks always; temporary rinks at GWP 750 or more |
| Air-cooled condensers | From 50 kW (previously 100 kW) charge limits per kW apply, with the GWP limit 750 (previously 1,900) |
| Cascade systems below −50 °C | High-pressure stage GWP up to 750, low-pressure stage GWP up to 150 |
The same version also regulates refilling: refrigerants with a GWP of 2,500 or more may be refilled only as reclaimed refrigerant until 31 December 2029 and not at all from 2030, and refrigerants with a GWP of 750 or more in food refrigeration, industrial refrigeration and ice rinks may be refilled as virgin refrigerant until 31 December 2031 (section 7(4)(c) and 7(5)). For systems with HFO refrigerants, leak checks are required above 3 kg and a leak detection system above 250 kg, and domestic refrigerators with HFOs are banned. The definitions of medium-temperature, low-temperature and freezing are unchanged [9].
Transitional rules in section 7 postpone several of the new bans [9]:
- Until 31 December 2028: split systems with direct expansion and a GWP of 750 or less are exempt from the bans for comfort cooling and heat pumps, so a split air conditioner with R32 (GWP 675) remains allowed; split heat pumps above 12 kW heating capacity with a GWP of 2,100 or less are also exempt (section 7(3)) [9].
- Until 31 December 2029: factory-built direct-expansion systems above 50 kW cooling capacity with a GWP of 750 or less, and factory-built heat pumps above 50 kW heating capacity with a GWP of 2,100 or less, are exempt from some of the bans (section 7(4)(a)–(b)) [9].
- Until 31 December 2032: VRF systems above 12 kW with a GWP of 750 or less are exempt (section 7(6)) [9].
- Until 30 June 2027: for transfer to third parties, the bans in the version of 31 May 2024 still apply, subject to the exemptions above (section 7(2)) [9].
Pressure equipment: notification to SUVA
Separate from the refrigerant rules, the Druckgeräteverwendungsverordnung (SR 832.312.12) sets occupational safety duties for pressure equipment used at work. It covers, among other things, vessels with gaseous contents that are not at risk of overheating, with a design pressure (PC) above 2 bar and a pressure–volume product above 3,000 bar·l (Art. 1(2)(b)), so large receivers and similar vessels in a refrigeration plant can fall under it [10].
The company must notify SUVA in writing before commissioning, and before any significant change (Art. 11). The equipment must be inspected regularly by the specialist organisation appointed under the accident insurance act (Art. 12 and 14), and SUVA can exempt equipment on request (Art. 13) [10]. The archived text is the version of 19 July 2016, so check the current text on Fedlex before relying on the details.
Practical checklist
- Start from ChemRRV Annex 2.10, not from the EU F-gas Regulation [1].
- Check that you and your company hold a Fachbewilligung for the right area [4][8].
- Keep a Wartungsheft for every system with more than 3 kg of refrigerant [6].
- Report commissioning and decommissioning via cooling-reg.ch [5].
- Check whether a large vessel exceeds 3,000 bar·l and must be notified to SUVA before commissioning [10].
- Do not refill new refrigerant with a GWP of 2500 or more; reclaimed refrigerant is allowed until the end of 2029 [7][9].
- Check the cooling capacity and GWP limits from 2027 before you choose a refrigerant [2][3].
Calculate it yourself
Terms in this article
Sources
- Fedlex – Chemikalien-Risikoreduktions-Verordnung (ChemRRV), SR 814.81
- BAFU – Kältemittel
- UVEK/BAFU – Erläuterungen zur Änderung der ChemRRV (Bundesratsbeschluss vom 29. Oktober 2025)
- BAFU – Fachbewilligung für den Umgang mit Kältemitteln
- BAFU – Meldung von Kälteanlagen und Wärmepumpen
- BAFU – Vollzugshilfe: Anlagen mit Kältemitteln – Wartungsheft, Dichtigkeitskontrolle und Meldepflicht (UV-0615)
- BAFU – Übersicht über die wichtigsten Kältemittel
- SVK – Fachbewilligung: Anwendungsbereiche
- Fedlex – ChemRRV (SR 814.81), Stand am 1. Januar 2027
- Fedlex – Druckgeräteverwendungsverordnung, SR 832.312.12