The refrigerant charge is read in kilos on the nameplate, but your obligations are counted in tonnes of CO2 equivalent. The conversion is one multiplication: charge in kilos times the refrigerant GWP, divided by 1,000. The threshold that triggers periodic leak checking is 5 tonnes of CO2 equivalent under Article 5 of EU Regulation 2024/573, carried over by Article R543-79 of the French environment code, with intervals set by Article 4 of the order of 29 February 2016. On a residential heat pump holding 1 to 2 kg, none of those thresholds is reached, and the exemption is even explicit below 3 kg for labelled hermetically sealed equipment.
Turning a charge into an obligation
The conversion table by refrigerant
GWP values come from Annex I of EU Regulation 2024/573, on the fourth IPCC assessment report. Blends are not listed there: their GWP is worked out through the Annex VI method, a mass-fraction weighted average. The R410A and R407C figures below are therefore calculated values, and should be presented as such.
| Refrigerant | GWP used | 5 t CO2e | 50 t CO2e | 500 t CO2e |
|---|---|---|---|---|
| R32 | 675 (Annex I) | 7.41 kg | 74.1 kg | 741 kg |
| R410A | 2,088 (calculated, Annex VI) | 2.39 kg | 23.9 kg | 239 kg |
| R407C | 1,774 (calculated, Annex VI) | 2.82 kg | 28.2 kg | 282 kg |
| R134a | 1,430 (Annex I) | 3.50 kg | 35.0 kg | 350 kg |
| R290, R744, R717 | outside the annexes | not applicable | not applicable | not applicable |
The leak check interval table
These intervals are set identically by Article 5(6) of EU Regulation 2024/573 and by Article 4 of the French order of 29 February 2016. They double as soon as a leak detection system is fitted.
| Equipment charge | Without leak detection | With a detection system |
|---|---|---|
| Under 5 t CO2e | No periodic check required | Not applicable |
| 5 to under 50 t CO2e | 12 months | 24 months |
| 50 to under 500 t CO2e | 6 months | 12 months |
| 500 t CO2e and above | 3 months | 6 months |
The scope of the regime, narrower than commonly stated
Article R543-75 of the French environment code, as written by decree 2015-1790, lists four families and only four: CFCs, HCFCs, HFCs excluding HFOs, and PFCs. An R290, R744 or R717 circuit falls outside that scope: neither the company certificate of Article R543-99 nor the leak check of Article R543-79 is triggered by the refrigerant. That takes nothing away from the safety requirements specific to those fluids, nor from the manufacturer's warranty conditions. For an overview of refrigerants and their deadlines, see refrigerants for heat pumps in 2026.
What you meet on site, and what is wrong about it
R410A is not a banned refrigerant
This is the commonest confusion, and it turns against you in front of a client. Article 13(4) of EU Regulation 2024/573 bans, from 1 January 2026, the use of virgin fluorinated gases with a GWP of 2,500 or above for servicing air conditioning and heat pump equipment. R410A is calculated at 2,088: it stays under the threshold, it stays rechargeable, and an entire installed base will go on being maintained. What tightens is the placing on the market of new machines, with the ban on a GWP of 750 or above for split systems under 3 kg since 1 January 2025.
R32 and its A2L classification
R32 is classed A2L, mildly flammable, which calls for ventilation, no ignition sources and compatible tooling during charging and recovery. The maximum charge allowed in a room comes from the manufacturer's manual, which applies EN 378-1+A1 and IEC 60335-2-40, two paid standards from which no figure is publicly quotable. Do not write a maximum charge found online onto a quote: use the one in the manual for the model fitted.
The four prohibitions that depend on no threshold
- Intentional release of fluorinated gases to atmosphere, banned by Article 4 of the regulation where it is not technically necessary.
- Failing to recover before opening the circuit, recovery being required by Article 8.
- Mixing two refrigerants in one circuit, which makes any superheat reading uninterpretable.
- Topping up a circuit whose leak has not been searched for and repaired.
Calculating and setting the right charge
Start from the nameplate, then the manufacturer's table
The nameplate carries the refrigerant type and the nominal charge, usually the factory charge for a reference line length. Beyond that length the manufacturer publishes an additional charge in grams per metre by diameter. No generic value is published by any primary source: a figure borrowed from another model produces a wrong charge, and a wrong charge invalidates every later diagnosis.
The sequence for putting the circuit in clean condition
Pressure test and leak search with nitrogen, then a nitrogen purge during brazing to limit internal oxidation. Then a vacuum pull-down with a hold check, which is the only proof that air and moisture have gone. On the associated water circuits, the pressure test is run before filling and logged in the same way.
Charge by weight, then verify by measurement
The charge is set on a scale, to the manufacturer's value, and then verified through superheat and subcooling at steady state. For blends, charging is done in liquid phase to avoid fractionation. A top-up decided from pressures alone, without stabilisation or temperature readings, is the leading cause of overcharging seen on service calls. On handover checks, see heat pump commissioning.
What stays in the file after you leave
The intervention record, and who signs it
The intervention record of Article R543-82 states the nature of the work, the refrigerant type and the quantities recovered and added. Above 3 kg of HCFCs or 5 tonnes of CO2 equivalent of HFCs or PFCs, it is signed jointly by the operator and the equipment holder. Below the thresholds it is not mandatory, but it remains the only written proof of the circuit's condition when you left.
Retention periods and the check marking
Article R543-80 requires leak check records to be kept for five years. Article R543-79-1 provides for a check marking to be applied to the equipment, and a leak-fault marking where a leak found cannot be repaired immediately. Those markings are the first thing an inspector looks at, before your register.
The certificate of competence, per establishment
The certificate of competence of Article R543-99 is issued by an approved body, for a maximum of five years, and attaches to an establishment rather than to the company as a whole. It states the equipment types and activities covered. The French order of 21 November 2025 replaces the issuing scheme from the order of 30 June 2008 and becomes mandatory on 1 January 2027: check the renewal calendar for your establishments before that date.
