The European F-Gas Regulation is no longer a future concern — it is a present reality affecting any business operating refrigeration, air conditioning or heat pump equipment that uses fluorinated gases. The tightened regulation adopted in 2024 has significantly accelerated the HFC phase-down calendar, and both documentation and maintenance obligations have been reinforced.
This article provides a practical summary of what businesses need to do in 2026 to stay compliant, which deadlines are critical and what the consequences of non-compliance look like.
What is the F-Gas Regulation and who does it affect?
Regulation (EU) 2024/573, replacing the previous 517/2014, governs the marketing, use and control of fluorinated greenhouse gases. It applies to:
- Equipment owners with refrigeration, air conditioning and heat pump systems containing fluorinated gases (HFCs, HFOs or blends).
- Installation and maintenance companies that handle these gases.
- Manufacturers and importers of equipment and gases.
If your business has an air conditioning system, a cold room, a commercial refrigeration unit or a heat pump using fluorinated gas, this regulation applies to you directly.
Current obligations for equipment owners
Mandatory leak checks
Equipment containing fluorinated gases in quantities equal to or greater than 5 tonnes of CO2 equivalent (tCO2e) is subject to mandatory periodic leak checks. The frequency depends on the charge:
- 5 to 50 tCO2e: leak check at least every 12 months.
- 50 to 500 tCO2e: at least every 6 months.
- Over 500 tCO2e: at least every 3 months.
If the equipment has an automatic leak detection system, the required frequency is halved.
To calculate the tCO2e of a piece of equipment, multiply the refrigerant charge (in kg) by the GWP of the gas. For example, a unit containing 8 kg of R-410A (GWP 2,088) has an equivalent charge of 16.7 tCO2e and is subject to six-monthly leak checks.
Intervention records
Every intervention on equipment containing fluorinated gas must be documented: installation, maintenance, leak checks, top-ups and gas recovery. Records must be kept for at least five years and be available for inspection by the competent authority.
The data that must be recorded include:
- Type and quantity of gas contained in the equipment.
- Quantity of gas added or recovered during each intervention.
- Identity and certification of the company or technician carrying out the work.
- Results of leak checks.
- Corrective measures taken when leaks are detected.
Mandatory gas recovery
When equipment is decommissioned or a repair requires opening the refrigerant circuit, the gas must be recovered by a certified technician. Venting fluorinated gases into the atmosphere is prohibited, and penalties for doing so are severe.
Phase-down calendar: key dates
The regulation sets staggered bans on the sale of new equipment using high-GWP gases:
Bans already in force
- Stand-alone commercial refrigeration equipment (such as supermarket display cabinets) with GWP above 150: banned since 2022.
- Centralised refrigeration systems with capacity above 40 kW and GWP above 150: banned since January 2025.
Upcoming bans
- Split air conditioning units below 12 kW: maximum GWP of 150 from 2027.
- Heat pumps below 12 kW: maximum GWP of 150 from 2027.
- Split systems above 12 kW: progressive restrictions with a GWP limit of 750 from 2029.
General phase-down
Regardless of product-specific bans, the total quantity of HFCs available on the European market is reduced each year. This means:
- Increasing difficulty in sourcing top-up gas for existing equipment.
- Progressive price increases for high-GWP HFC gases.
- The need to plan equipment replacement before recharging becomes economically or logistically unfeasible.
Penalties for non-compliance
In Spain, Law 16/2013 and Royal Decree 115/2017 set out the penalty framework for fluorinated gas infringements. Fines can be substantial:
- Minor infringements: EUR 600 to EUR 6,000 (for example, failing to carry out leak checks on schedule).
- Serious infringements: EUR 6,001 to EUR 100,000 (for example, not maintaining intervention records or carrying out top-ups without proper certification).
- Very serious infringements: EUR 100,001 to EUR 2,000,000 (for example, deliberate release of fluorinated gases into the atmosphere).
Other EU member states have equivalent penalty regimes. Beyond financial sanctions, non-compliance can affect the renewal of operating licences and insurance coverage.
What your business should do now
1. Inventory your equipment
The first step is to compile a complete list of all refrigeration and air conditioning equipment, identifying for each unit:
- Equipment type and model.
- Refrigerant gas it contains.
- Gas charge in kilograms.
- GWP of the gas and equivalent charge in tCO2e.
- Equipment age and general condition.
2. Verify documentation compliance
Check that leak checks are being carried out at the required frequency and that records are complete and up to date. If there are documentation gaps, address them as soon as possible.
3. Assess the situation of each unit
For every piece of equipment using a high-GWP HFC, evaluate:
- How many years of useful life remain.
- What the availability and price of top-up gas will be over that period.
- Whether a lower-GWP alternative can replace it.
- When the optimal replacement moment is, balancing remaining useful life against regulatory risk.
4. Plan the transition
The goal is not to replace everything at once but to have a plan. Equipment with the highest GWP, the largest charge and the shortest remaining life is the priority candidate for replacement. Units running on intermediate-GWP gases (such as R-32, with a GWP of 675) face a longer regulatory timeline but should also be included in the planning.
5. Work with a certified installation company
All interventions on equipment containing fluorinated gases must be performed by companies and technicians holding the certification required by the applicable national regulations (in Spain, Royal Decree 115/2017). Working with an uncertified company is not only an infringement — it invalidates records and can void equipment warranties.
Regulation as opportunity
Complying with the F-Gas Regulation is not just about avoiding fines. New equipment using low-GWP refrigerants is more efficient, incorporates more advanced control technology and has more predictable maintenance costs because it does not depend on a gas whose price rises every year.
At Acoval Technical Installations we manage F-Gas compliance for businesses with industrial refrigeration and HVAC systems in Valencia and the Valencian Community. From auditing equipment fleets to planning replacements and executing projects, we make sure your business stays on the right side of the regulation. Get in touch through our contact page for a no-obligation initial assessment.
