F-Gas and ODS Regulations: Scope, Duties and Thresholds
The two regimes
Fluorinated greenhouse gases (HFCs, PFCs, SF6 and, historically, HFC blends) are controlled under the EU F-Gas Regulation as retained in UK law. Ozone-depleting substances - CFCs, HCFCs, halons, methyl bromide - sit under a separate ODS regime that is essentially prohibitive: virgin HCFC is banned, and reclaimed HCFC may only be used for maintaining existing equipment until the final cut-off date.
Who the duties fall on
Operators - the person or organisation with actual control over the equipment's day-to-day running - carry the leak-checking, record-keeping and recovery duties. Certified personnel carry the competence duties: they must hold the correct category certificate for the work and the equipment charge size. Category III covers recovery from stationary refrigeration, air-conditioning and heat-pump equipment, and certain service activities, but not installation, and not work requiring breaking into the circuit on larger systems reserved for higher categories.
Traps in questions
- Confusing operator with owner or contractor. The contractor does the work; the operator holds the legal duty.
- Quoting thresholds in kilograms when the regulation uses tonnes of CO2 equivalent (charge in kg × GWP ÷ 1000).
- Assuming a certificate never expires - periodic reassessment applies.
- Mixing the ODS phase-out calendar with the HFC phase-down calendar; they are different instruments with different dates.
Rule of thumb
If a question gives a charge weight and a GWP, convert to tCO2e first, then compare against the threshold. Example: 4 kg of R-410A (GWP 2088) = 4 × 2088 ÷ 1000 ≈ 8.4 tCO2e - above the 5 tCO2e band, so the tighter leak-check frequency applies.