Dear Customers,
As you are certainly aware, the illegal market is also characterized by the offer of refrigerants claimed to be "reclaimed", often accompanied by documentation from Chinese producers or labeling that indicates reclamation sites outside the European Union (e.g., Albania or Turkey).
In this regard, please note the following:
- When technicians submit declarations to the F-Gas Online Database after using reclaimed refrigerants, they are required to indicate the EUROPEAN address of the reclamation facility (Article 7, paragraph 1, letter d), as well as the certificate number issued by the EU-based company that performed the reclamation.
For reference, please see the two screenshots below showing the maintenance intervention input forms on the F-Gas portal (fgas.it), which are mandatory for installers/technicians:
- With regard to labeling, containers of reclaimed refrigerant gases must display the EUROPEAN address of the reclamation facility (often incorrectly translated as “regeneration equipment,” but the correct English term is “reclamation facility” – Article 12, paragraph 7).
IMPORTAN: Analysis or reclamation certificates issued by companies based outside the European Union are not accepted.
For example, R-404A gas “reclaimed” outside the EU is considered equivalent to virgin R-404A and is therefore prohibited from January 1, 2025.
Regulatory References
For your convenience, below are excerpts from Regulation (EU) 2024/573 cited above.
Article 7 – Record Keeping
1. Operators of equipment requiring leak checks under Article 5(1) shall establish and maintain, for each such piece of equipment, records specifying the following information:
OMITTED
(d) if gases have been added, the quantities and types of those gases and whether they have been recycled or reclaimed, as well as the name and address in the Union of the recycling or reclamation facility, and, where applicable, the certificate number;
Article 12 – Labelling and Information on Products and Equipment
OMITTED
7. Containers of fluorinated greenhouse gases that are reclaimed or recycled and listed in Annexes I and II shall be labeled to indicate that the substance has been reclaimed or recycled. In the case of reclamation, information on the batch number and the name and address of the reclamation facility in the Union must be provided..
We kindly ask you to widely share this information.
