F-Gas regulations control the use of fluorinated greenhouse gases — the refrigerants inside most air conditioning and refrigeration equipment. The point that catches businesses out is where the duty sits: the operator of the equipment, which usually means the business that controls it, carries the legal obligations for leak checking, record keeping and using certified engineers. Your maintenance contractor performs the work, but the responsibility for it happening stays with you.
Key takeaways
- The equipment operator holds the compliance duty, not the contractor.
- Leak check frequency depends on the CO₂-equivalent charge, not the kilograms alone.
- Records must be kept for every system above the threshold and retained for five years.
- Only certified personnel and companies may install, service or decommission F-Gas equipment.
- High-GWP refrigerants are being phased down — plan replacements before availability bites.
Who counts as the operator
The operator is the person or organisation with actual power over the technical functioning of the equipment — in most cases the business occupying the premises and using the system. For leased premises the position depends on the lease: if the landlord retains control of the plant, the duty may sit with them, but if you control it and pay for its maintenance, expect the duty to be yours.
This is worth resolving in writing. When enforcement asks for leak records, 'we assumed the landlord had that' is not an answer that helps anyone.
CO₂ equivalent: the number that sets your obligations
Obligations are triggered by the CO₂-equivalent charge of a system, calculated as the refrigerant charge in tonnes multiplied by that refrigerant's global warming potential. That is why two systems with identical kilogram charges can have completely different duties — a modern low-GWP refrigerant may fall below a threshold where an older high-GWP gas sails past it.
| System CO₂ equivalent | Leak check interval | With leak detection system |
|---|---|---|
| Below 5 tonnes | No mandatory check | — |
| 5 to under 50 tonnes | Every 12 months | Every 24 months |
| 50 to under 500 tonnes | Every 6 months | Every 12 months |
| 500 tonnes and above | Every 3 months | Every 6 months |
Hermetically sealed systems benefit from a higher entry threshold. Confirm your specific system with your contractor.
Systems at or above 500 tonnes CO₂ equivalent must also have an automatic leak detection system fitted, and that detection system itself must be checked at least annually.
Records you must keep
For every system subject to leak checking, you must maintain records and keep them for at least five years, available for inspection.
- Quantity and type of refrigerant installed in the system
- Quantity of refrigerant added during servicing, maintenance or repair, and why
- Whether any installed refrigerant has been recycled or reclaimed, with the facility details
- Quantity of refrigerant recovered at any point
- Identity of the company and the certified individual who carried out the work
- Dates and results of every leak check
- Details of any repairs and the mandatory follow-up verification check
- Measures taken when equipment is decommissioned
A single logbook per system, held on site or in a shared drive your contractor also updates, is the simplest way to stay compliant. Scanned service sheets stuffed in an email folder is how gaps appear.
Certification: who is allowed to touch the equipment
Any work involving refrigerant containment — installation, servicing, maintenance, repair, leak checking, recovery and decommissioning — must be carried out by appropriately certified individuals, working for a certified company where the work involves stationary refrigeration and air conditioning equipment.
As operator, you must only employ certified personnel for that work. It is entirely reasonable to ask a contractor for their company certification number and to see the individual engineer's certificate. A firm that hesitates over that request has told you something useful.
The phase-down and what it means commercially
The regulatory direction is a steadily shrinking supply of high global warming potential refrigerants, alongside bans on certain new equipment types and on servicing some legacy systems with virgin high-GWP gas. The mechanism is a quota on the amount of gas placed on the market, which works through the supply chain as price rather than as a sudden unavailability.
What businesses see in practice
- Sharp price rises for high-GWP refrigerants such as R404A, sometimes several-fold
- Longer lead times on gas for older systems
- Repairs on legacy plant becoming disproportionate to its remaining value
- New installations specified on lower-GWP refrigerants such as R32 or R454B
- Insurers and buyers asking about refrigerant type during due diligence
If you operate equipment on an older high-GWP refrigerant, the sensible move is a planned replacement programme rather than waiting for a failure. A planned change lets you specify the right equipment, schedule downtime and budget across financial years. An unplanned one happens on the hottest Friday of the year at emergency rates.
Leaks: repair obligations
When a leak is detected, it must be repaired without undue delay, and the repaired system must be re-checked within one month by a certified engineer to verify the repair worked. Leaving a known leak while continuing to top up the system is not compliant, and it is expensive — refrigerant vented to atmosphere is money and carbon leaving the building.
Repeated top-ups on the same system are the clearest sign that leak detection and repair discipline is missing. Look at your last three years of service records: if the same asset appears with added gas each year, that is your priority.
A compliance routine that works
- 1Build an asset register: every system, its location, refrigerant type, charge in kg, GWP and resulting CO₂ equivalent.
- 2Assign each asset its leak check interval from that CO₂ equivalent figure.
- 3Diarise the checks a month ahead so a missed slot does not become a missed interval.
- 4Hold one logbook per system, updated at every visit, retained five years.
- 5Verify your contractor's company and engineer certification annually.
- 6Flag any system on a high-GWP refrigerant for a replacement plan with a target year.
- 7Review the register whenever you take on, give up or refit premises.
For a small business with two or three systems this is an hour of admin a year. For a multi-site operator it justifies a proper maintenance contract with reporting, because the register is the thing enforcement, insurers and buyers all ask to see.
This guide is general information. Thresholds and requirements are updated periodically, so confirm the current position for your specific equipment with your certified contractor or the Environment Agency.
Frequently asked questions
Does F-Gas apply to a small office split system?+
It applies to the equipment, but many small splits fall below the 5 tonne CO₂ equivalent threshold for mandatory leak checks. The certified-engineer requirement still applies to any refrigerant work.
What are the penalties for non-compliance?+
Enforcement can involve civil penalties and, in serious cases, prosecution. The more common commercial consequence is a failed audit or a stalled property transaction.
Who keeps the logbook — us or the contractor?+
The operator is responsible for records existing and being available. In practice the contractor completes entries at each visit and the operator retains the record.
Can I keep running R404A equipment?+
Existing equipment can generally continue in use, but servicing options and gas supply are increasingly constrained and costly, which is why planned replacement is usually the better commercial decision.