Owning a refrigeration system: what to arrange at replacement

Are you the operator?

The F-gas Regulation places most obligations on the operator: the undertaking that exercises actual control over the technical functioning of the equipment. In specific cases a Member State can designate the owner instead. In practice the operator is usually the owner or user who makes decisions about the system, not the contractor who services it. You can outsource the work, not the responsibility.

How often must the system be leak checked?

That depends on the refrigerant charge in tonnes of CO2 equivalent: kilograms multiplied by GWP, divided by a thousand. Leak checks are required from 5 tonnes of CO2 equivalent. For R404A (GWP 3,922) that is from about 1.3 kilograms. The frequencies are set in Article 5(6) of Regulation (EU) 2024/573:

• •less than 50 tonnes of CO2 equivalent: at least every 12 months, or every 24 months with a leak detection system;
• •50 to 500 tonnes of CO2 equivalent: at least every 6 months, or every 12 months with a leak detection system;
• •500 tonnes of CO2 equivalent or more: at least every 3 months, or every 6 months with a leak detection system.

For R404A, the 50-tonne threshold is about 12.7 kilograms and the 500-tonne threshold about 127 kilograms. From 500 tonnes of CO2 equivalent, a leak detection system is mandatory for, among others, stationary refrigeration, air conditioning and heat pumps. Hermetically sealed equipment labelled as such does not need leak checks as long as the charge stays below 10 tonnes of CO2 equivalent. HFOs have separate thresholds in kilograms.

If a leak is found, it must be repaired without undue delay. A certified technician then checks that the repair has worked, no earlier than 24 hours and no later than one month after the repair.

What must the logbook contain?

For each system that requires leak checks, you keep records (Article 7). They include:

• •the quantity and type of refrigerant in the system;
• •how much refrigerant was added during servicing or after a leak;
• •for added refrigerant: whether it was recycled or reclaimed, with the name and address of the recycling or reclamation facility and, where applicable, its certificate number;
• •how much refrigerant was recovered;
• •which company installed, serviced, repaired, leak checked, recovered or decommissioned the system, with its certificate number and the technician who did the work;
• •the dates and results of leak checks and repairs;
• •on decommissioning: the measures taken to recover and dispose of the refrigerant.

You keep these records for at least five years.

Who may recover the refrigerant?

Only a certified technician (Article 8). In the Netherlands that means a personal certificate under BRL 200 for the technician and a company certificate under BRL 100 for the contractor. Both are registered in the Central Technical Register (Centraal Register Techniek, CRT), where you can check whether a company or technician is certified and for which work. Some companies also hold a STEK recognition, an additional quality mark. The legal basis is BRL 100.

Once recovered, the refrigerant must be recycled, reclaimed or destroyed. It may not be vented. A cylinder left unaccounted for in a warehouse is not a solution either.

What should you ask your contractor on decommissioning or replacement?

When a system is replaced or stripped out, the entire charge comes out at once. That is often the largest quantity in the system's whole life. Ask beforehand:

1. 01Where is the refrigerant going, and will it be reclaimed or destroyed?
2. 02Under which waste stream number is it being disposed of, and who is named as waste producer on the consignment note?
3. 03Will I receive a copy of the consignment note, with the weighed quantity?
4. 04Will I receive a statement from the processor that the refrigerant has been reclaimed or destroyed?
5. 05How many kilograms were recovered, so I can record it in the logbook?

With those answers your logbook is complete, and in an inspection you can show the refrigerant was disposed of correctly.

What statement do you get from Gaia Cooling?

When Gaia Cooling collects your recovered refrigerant, you receive a statement after processing showing the refrigerant type, the weight in kilograms, the quantity in tonnes of CO2 equivalent and the destination: reclamation or, where reuse is not allowed, destruction. That statement matches what the logbook asks for and fits your waste records.