F-Gas: what the regulations actually cover, in plain English

What the regulations are for

Fluorinated greenhouse gases are used as refrigerants because they have excellent thermodynamic properties. They are also, molecule for molecule, extremely potent greenhouse gases – some thousands of times more so than carbon dioxide.

The regulatory response has two strands:

1. Contain what is already installed. Prevent leaks, find them quickly when they occur, and recover refrigerant at end of life rather than letting it escape.
2. Reduce what goes in in future. A phase-down quota progressively restricting the quantity of high-GWP refrigerant placed on the market, pushing the industry toward lower-GWP alternatives.

Everything in the regime follows from those two objectives, which makes the individual obligations easier to remember than a list of rules.

What equipment is covered

• Air conditioning – splits, multi-splits, VRF, cassettes, ducted systems, close control.
• Refrigeration – commercial cold rooms, display cabinets, cellar cooling, process refrigeration.
• Heat pumps, including air source heat pumps.
• Chillers.
• Some fire protection systems and certain other applications.
• Not systems using non-fluorinated refrigerants such as propane, ammonia or CO2 – though those have their own safety regimes.

The scope surprises people. Cellar cooling in a pub, display fridges in a shop, and a comms room split unit are all covered exactly as a VRF system is, and they are frequently overlooked because nobody thinks of them as ‘F-Gas equipment’.

Who the duty falls on

The regulations place obligations on the operator – defined as the person or business with actual control over the technical functioning of the equipment.

In practice that is normally the occupier or the building owner, not the maintenance contractor. The distinguishing question is who can decide whether the equipment runs, who pays for its maintenance, and who would decide to replace it.

What the operator must do

The one that trips people up is the re-check after repair. Repairing a leak is not the end of the obligation – the system must be verified afterwards within a defined period to confirm the repair was effective.

CO2e: the number everything hangs on

Almost every threshold in the regime is expressed in tonnes of CO2 equivalent, not in kilograms of refrigerant.

CO2e = refrigerant charge in kilograms x that refrigerant’s global warming potential.

The consequence is that two physically similar systems can have completely different obligations, because their refrigerants have very different GWPs. A system charged with a high-GWP refrigerant reaches a threshold at a much smaller physical quantity than one using a low-GWP alternative.

This is why the first practical step in any F-Gas compliance exercise is establishing, for every system, what refrigerant it contains and how much. Both are on the nameplate, and both should be in the commissioning records. Without them, nothing else can be calculated.

The thresholds and the resulting frequencies are worked through in leak check frequency.

Hermetically sealed equipment

A useful distinction worth knowing. Equipment described as hermetically sealed – where the refrigerant circuit is sealed by welding, brazing or a similar permanent joint, with no serviceable connections, and labelled as such – has a higher CO2e threshold before leak checking applies.

The logic is that a circuit with no serviceable joints has a much lower leak risk than one with flare connections and service valves. Many small self-contained units fall into this category.

Two cautions: the equipment must actually be labelled as hermetically sealed, and the higher threshold applies only to the leak checking obligation – the handling, certification, recovery and record obligations are unaffected.

What to do if you have never thought about this

1. Find every systemAir conditioning, refrigeration, cellar cooling, comms room cooling, chillers, heat pumps. Walk the building, including the roof and anywhere plant might be hiding.
2. Record refrigerant type and charge for eachFrom the nameplate. Photograph them.
3. Calculate CO2e for eachCharge multiplied by GWP.
4. Establish the resulting obligationsLeak check frequency, and whether automatic leak detection is required.
5. Set up recordsA logbook per system, held by you as operator – not only by your contractor.
6. Confirm your contractor’s certificationIndividual qualifications and company certification. Ask for evidence.
7. Start the scheduleYou cannot recreate past checks. A site that is compliant going forward is in a very different position from one that still is not.