F-Gas III: what Regulation (EU) 2024/573 changes for French refrigeration firms

The European framework that has structured the refrigeration trade for a decade has been replaced. Regulation (EU) 2024/573 of the European Parliament and of the Council of 7 February 2024, known as F-Gas III, entered into force on 11 March 2024 and repeals Regulation (EU) No 517/2014. In France, its operational rollout arrived at the end of 2025. Here is what actually changes for a refrigeration, air-conditioning or heat-pump business.

Why a third regulation

The underlying logic has not changed in twenty years: fluorinated refrigerants are excellent coolants and very powerful greenhouse gases, with a global warming potential that runs, for some, into thousands of times that of carbon dioxide at equal mass.

What the regulator changed is the pace. A study by Velders and co-authors published in 2022 in Atmospheric Chemistry and Physics estimates that, without controls, hydrofluorocarbon emissions would contribute of the order of 0.28 to 0.44 °C of warming by 2100, against about 0.04 °C under the controls provided for by the Kigali Amendment. The gap between those trajectories justifies tightening the timetable for phasing out high-GWP refrigerants.

For a business, that trajectory translates less into an abrupt ban than into a gradual shift of the market: different refrigerants, hence different skills.

Three changes that hit businesses directly

Extension to natural refrigerants and hydrocarbons. Carbon dioxide, ammonia and hydrocarbons enter the scope of certified competence. This is the most structural novelty: until now the certification system was built around fluorinated gases alone, while the market is shifting towards refrigerants that were not covered.

A new set of categories. The historical split into categories I to V, familiar to the whole trade, gives way to a revised nomenclature aligned with the European framework and accounting for the new refrigerants.

A periodic knowledge update. Holders of current certificates will have to refresh their skills on a timetable set by the European framework and its national implementation. This breaks with the previous logic, where the personal certificate, once obtained, carried no comparable refresh deadline.

The French rollout: the orders of 21 November 2025

Operational implementation runs through two orders of 21 November 2025, published in the Official Journal in December 2025:

• one on the issuance of capacity certificates to operators, provided for by article R. 543-99 of the Environment Code;
• the other on the issuance of personal certificates, provided for by article R. 543-106.

They replace the 2008 orders that governed both schemes — respectively the order of 30 June 2008 for capacity certificates and the order of 13 October 2008 for personal certificates.

The general architecture does not move: the capacity certificate is still issued to the company by an approved body for a maximum of five years, subject to certified staff and suitable tooling, with an annual refrigerant movement declaration and an inspection visit. That base is detailed on the scheme page.

The real trap: the dates

This is the point calling for most caution — and caution here means not deciding in the texts’ place.

The orders provide for a transition period during which certificates continue to be issued and recognised under the previous arrangements, before the new regime becomes the rule. The European framework separately sets a deadline beyond which holders of the historical categories must have updated their knowledge to keep relying on their certificate.

The dates circulating in the trade press, on training providers’ websites and in commercial brochures are not all consistent — and some conflate the European deadline, the end of the French transition period, and the orders’ entry into force, which are three different things.

The only reliable approach: ask your approved body in writing for the timetable applying to your company, and your assessment body for the one applying to each of your certified staff. They are the only parties that stake their liability on the answer, and they hold the up-to-date texts.

The commercial effect arrives before the regulatory one

A frequent analytical error is to treat F-Gas III as a compliance matter, to be settled once the dates are clear. In practice, the market moves faster than the deadlines.

The progressive reduction of hydrofluorocarbon quantities placed on the market acts on prices and availability well before any ban hits a given piece of equipment. A firm whose client base rests heavily on a refrigerant becoming scarce is exposed on three fronts at once: the cost of a recharge, the lead time, and the difficulty of defending to a client a repair whose horizon is uncertain.

Conversely, the firm that has technicians competent on CO₂ or hydrocarbons early positions itself on replacing installations rather than keeping them on life support. That is a difference in kind between two business models, not a catalogue adjustment.

It is also what makes the certificate question less administrative than it looks: certified competence conditions access to the market segment, quite apart from any penalty.

What the reform means for safety

Bringing hydrocarbons into the scope of certified competence is not an administrative extension. It changes the nature of the risk.

A study by Tang and co-authors, published in 2018 in the International Journal of Refrigeration, experimentally assessed propane (R290) leakage in a split-type household air conditioner, varying charge, leak-hole diameter and airflow, and examined risk-reduction devices (see the study). A flammable refrigerant is not handled like a fluorinated one: intervention protocols, tooling and site rules all differ.

In other words, the knowledge update is not an administrative renewal formality. It covers operations that most of the trade has not been taught.

What to do right now

Three actions do not wait for the dates to be clarified.

Take stock. Who holds which personal certificate, in which category, since when? When does the company’s capacity certificate expire? See our article on the personal certificate categories.

Ask. Put the timetable question in writing to the approved body and to the assessment body, and keep the answer.

Anticipate the refrigerants. If your business is moving towards propane heat pumps or CO₂ installations, the skills build-up is planned before the market demands it, not after.

Take action

F-Gas III does not overturn the French architecture of two certificates: it widens their scope and introduces skills maintenance. The short-term risk is not regulatory but commercial — being left without a technician qualified on the refrigerants the market wants. Take stock of your certificates, write to your approved body, and find the detailed requirements on the scheme page.