United Kingdom: the F-gas rules after Brexit for refrigeration and heat pumps
What applies to refrigerants in the UK: Great Britain follows retained Regulation 517/2014, Northern Ireland the EU's 2024/573. Leak checks, certificates, service bans and quotas.
Key points
- In Great Britain (England, Scotland and Wales), EU Regulation 517/2014 applies in the version retained after Brexit, together with The Fluorinated Greenhouse Gases Regulations 2015 [1][2].
- In Northern Ireland the new EU Regulation 2024/573 applies instead [5].
- Leak checks are required from 5 tonnes CO2e at intervals of 12, 6 and 3 months. With a leakage detection system the intervals are doubled [1].
- Since 2020, virgin gas with a GWP of 2,500 or more may not be used to service refrigeration systems with 40 tonnes CO2e or more. Reclaimed or recycled gas may be used until the end of 2029 [1].
- The HFC phase-down reaches 21 % of the baseline in 2030. Defra is considering a faster phase-down but will not change the 2027 step [4].
Two sets of rules in one country
When the United Kingdom left the EU, F-gas Regulation (EU) No 517/2014 was retained as UK law in Great Britain, that is England, Scotland and Wales [1]. It is supplemented by The Fluorinated Greenhouse Gases Regulations 2015 (SI 2015/310), which among other things designate the authorities, regulate the certification bodies and set out penalties [2]. The new EU Regulation 2024/573 therefore does not apply in Great Britain.
Northern Ireland follows EU rules on goods under the Windsor Framework, and EU Regulation 2024/573 applies there [5]. A service company that works on both sides of the Irish Sea therefore needs to know both sets of rules.
Leak checks and records
The requirements are similar to the old EU rules. The operator must ensure that equipment with 5 tonnes CO2e or more is checked for leaks. GWP is calculated with the values in the retained regulation [1][3].
| Charge | Without leakage detection system | With leakage detection system |
|---|---|---|
| 5 to less than 50 t CO2e | every 12 months | every 24 months |
| 50 to less than 500 t CO2e | every 6 months | every 12 months |
| 500 t CO2e or more | every 3 months | every 6 months |
From 500 tonnes CO2e a leakage detection system is required. Labelled hermetically sealed equipment below 10 tonnes CO2e is exempt. Pure HFOs are not subject to leak checks in the GB version because they are not listed in Annex I of the regulation [1]. The operator must keep records of refrigerant quantities, additions, checks and measures, and keep them for at least five years [1][3].
Certificates for technicians and companies
Technicians who install, service, leak-check or recover refrigerant from refrigeration, air conditioning and heat pump equipment must hold an F-gas certificate, for example City & Guilds 2079 or equivalent. Companies that carry out the work for others must hold a company certificate from an approved certification body [3]. Personal certificates come in four categories:
- Category I: all activities on all sizes of system.
- Category II: installation, servicing and recovery on systems below 3 kg (below 6 kg if hermetically sealed), and leak checks on all systems without breaking into the circuit.
- Category III: recovery of refrigerant from systems below 3 kg (below 6 kg if hermetically sealed).
- Category IV: leak checks without breaking into the circuit.
Service bans and bans on new products
Since 1 January 2020, virgin gas with a GWP of 2,500 or more may not be used to service refrigeration systems with 40 tonnes CO2e or more. Reclaimed or recycled gas may be used until 31 December 2029 [1]. For R404A, 40 tonnes CO2e corresponds to about 10 kg.
Annex III of the retained regulation bans certain new products, for example stationary refrigeration equipment with a GWP of 2,500 or more (since 2020), hermetically sealed commercial refrigerators and freezers with a GWP of 150 or more (since 2022), centralised refrigeration systems (multipack) of 40 kW or more with a GWP of 150 or more (since 2022, with an exemption for the primary circuit of cascade systems) and single split air conditioning systems below 3 kg with a GWP of 750 or more (since 2025) [1].
Quotas and phase-down
The United Kingdom has its own HFC quota system. From 1 January 2027 production and imports may amount to 24 % of the baseline and from 2030 to 21 %, which is currently the final step [4]. Defra has proposed a faster and longer phase-down, but after the consultation it announced that it will not change the 2027 step through new legislation in 2026. A response to the consultation and next steps are to be published later [4].
Pressure systems: written scheme of examination
Refrigeration systems are also pressure systems under the Pressure Systems Safety Regulations 2000 (PSSR, SI 2000/128) [6]. Under regulation 8 the user must not operate an installed system unless there is a written scheme for the periodic examination of its protective devices, vessels and pipework by a competent person. The scheme must be drawn up or certified by a competent person and must state the nature and frequency of the examinations [6]. Two exclusions matter for refrigeration:
- A vapour compression refrigeration system with a total installed compressor motor power of 25 kW or less is excluded from all the regulations (Schedule 1, Part I, paragraph 18) [6].
- A system in which the pressure times the internal volume of each pressure vessel is below 250 bar litres is excluded from regulations 8 to 10 (Schedule 1, Part II, paragraph 2) [6].
The same 25 kW exclusion is in the Northern Ireland regulations, the Pressure Systems Safety Regulations (Northern Ireland) 2004 [7]. In Ireland, Part 10 of S.I. 299/2007, inserted by S.I. 445/2012, has both exclusions in Part A of Schedule 12 (paragraphs 22 and 27) [8].
What does it mean in practice?
- Check whether the plant is in Great Britain or Northern Ireland: that decides which rules apply.
- Calculate the charge in tonnes CO2e and plan the leak check intervals accordingly.
- Avoid refrigerants with a GWP of 2,500 or more in new projects. The ban on virgin service gas and the limited quota make them expensive and hard to obtain.
- Keep records and certificate numbers. They are requested during inspections.
Calculate it yourself
Terms in this article
Sources
- Regulation (EU) No 517/2014 as retained in Great Britain – legislation.gov.uk
- The Fluorinated Greenhouse Gases Regulations 2015 (SI 2015/310) – legislation.gov.uk
- GOV.UK – F gas in refrigeration, air conditioning and fire protection systems
- Defra – F gas Regulation in Great Britain: reform of the HFC phasedown (consultation)
- Regulation (EU) 2024/573 on fluorinated greenhouse gases – EUR-Lex
- legislation.gov.uk – The Pressure Systems Safety Regulations 2000 (SI 2000/128)
- legislation.gov.uk – Pressure Systems Safety Regulations (Northern Ireland) 2004 (SR 2004/222)
- Irish Statute Book – S.I. No. 445/2012, Safety, Health and Welfare at Work (General Application) (Amendment) Regulations 2012