F-Gas Regulations and Heat Pumps: Refrigerant Handling, REFCOM Registration and Record-Keeping

Summary

The UK F-Gas Regulations (retained from EU Regulation 517/2014 and implementing regulations) control the use of fluorinated greenhouse gases (HFCs and HFOs) used as refrigerants in heat pumps, air conditioners, and refrigeration systems. For heat pump installers, the key obligations are: certification to handle refrigerants, REFCOM registration for companies, and record-keeping for each piece of equipment containing F-Gas.

The regulations apply primarily to split systems. The majority of domestic ASHP installations use monobloc units (all refrigerant components sealed in the outdoor unit) — these do not require installer F-Gas certification, as the installer only handles water pipework.

Key Facts

• F-Gas — fluorinated greenhouse gases including HFCs (hydrofluorocarbons) and HFOs (hydrofluoroolefins) used as refrigerants; categorised by their Global Warming Potential (GWP)
• R32 — the most common refrigerant in current ASHP models; GWP of 675 (moderate); flammable (A2L classification); requires trained handling
• R410A — previous generation ASHP refrigerant; GWP of 2,088 (high); being phased out under F-Gas phase-down
• R290 (propane) — low-GWP natural refrigerant gaining adoption in heat pumps; GWP of 3; highly flammable (A3); requires specific handling protocols; not covered by F-Gas regulations but requires alternative competency
• R454B, R466A — next-generation lower-GWP HFO/HFC blends replacing R410A; GWP ~466 for R454B; some mildly flammable
• Monobloc ASHP — all refrigerant components sealed within the outdoor unit; installer handles only water pipework; no F-Gas certification required for the installer
• Split ASHP — outdoor evaporator + indoor unit connected by refrigerant pipes; the installer makes refrigerant connections, pressure tests, and charges (or checks the charge) the system; F-Gas certification required
• City & Guilds 2079 — the standard UK qualification for F-Gas handling; covers safe handling, leak testing, charging, recovery, and record-keeping; split into categories (1, 2, 3, 4) by refrigerant type and system size; Category 1 covers all refrigerant types and system sizes
• REFCOM — the F-Gas registration scheme operated by the ACRIB (Air Conditioning and Refrigeration Industry Board); companies that maintain, service, or install refrigeration or AC equipment must be registered with REFCOM or an equivalent approved body
• Equipment log (F-Gas register) — a written or electronic log required for all equipment containing ≥3kg CO2 equivalent of F-Gas (or ≥5 tonne CO2e for lower GWP refrigerants); records installation, commissioning, refrigerant type and charge, leak checks, and service history
• CO2 equivalent charge — the refrigerant charge (kg) × GWP; R32 at 1.5kg = 1.5 × 675 = 1,012 kg CO2e (above the 3kg CO2e threshold); requires an equipment log
• Leak checking — equipment above 3kg CO2e must be leak checked at least annually; above 30kg CO2e, every 6 months; above 300kg CO2e, every 3 months; certified engineer only
• Refrigerant recovery — F-Gas must be recovered (not vented to atmosphere) when decommissioning equipment; recovery can only be performed by a certified F-Gas engineer using a recovery machine

Quick Reference Table: F-Gas Obligations by Installation Type

Detailed Guidance

R32 Handling Requirements

R32 is classified as A2L (mildly flammable). Safe handling requires:

• Certified F-Gas engineer (City & Guilds 2079 Category 1 or 2)
• Equipment rated for A2L refrigerants (manifold gauges, hoses, recovery machine, recovery cylinder)
• Ignition source control during charging and recovery (no open flame, no sparks within 3m)
• Adequate ventilation in the work area
• Leak detector calibrated for R32

When connecting the refrigerant lineset on a split ASHP, the procedure is:

1. Braze or flare-fit the refrigerant lines (copper, purpose-sized for the system)
2. Pressure test the refrigerant circuit with dry nitrogen (typically to 40 bar for R32 systems) — do not use oxygen or compressed air
3. Evacuate the circuit using a vacuum pump (minimum 500 micron vacuum, hold for 30 minutes)
4. Break the seal on the outdoor unit's factory charge and allow refrigerant to fill the lineset
5. If additional charge is required (long lineset), add by weight using the manufacturer's additional charge calculation
6. Record the total charge weight in the equipment log

REFCOM Registration

Any company that installs, services, or maintains equipment containing F-Gas must be registered with an approved registration body. In the UK, REFCOM (operated by ACRIB) is the principal registration body.

Registration requirements:

• The company must have at least one qualified F-Gas engineer (City & Guilds 2079 or equivalent)
• Annual registration fee (typically £200–£400/year)
• Maintain records of all F-Gas work and make available to the Environment Agency on request
• Ensure all operatives working on F-Gas systems are individually qualified

REFCOM registration is visible to customers and other contractors — it is proof that the company meets the legal minimum for F-Gas work.

Equipment Log Requirements

For equipment containing F-Gas above the CO2e threshold (3kg CO2e or 5 tonne CO2e for lower-GWP refrigerants), the equipment log must record:

• Equipment owner and location
• Refrigerant type, charge weight, and CO2e equivalent
• Date of installation and commissioning
• Annual leak check dates and results
• Any refrigerant added or recovered
• Servicing history

The log must be kept for at least 5 years after the equipment is decommissioned. It must be made available to the Environment Agency or the registration body on request.

Practical approach for split ASHP: Create an equipment log at commissioning. Provide the customer with a copy (or digital record). Schedule annual leak checks into the maintenance contract. Update the log after each visit.

The Refrigerant Phase-Down

F-Gas regulations include a phase-down of high-GWP refrigerants (primarily HFCs). The quota system progressively reduces the total amount of high-GWP refrigerant placed on the UK market, driving manufacturers to transition to lower-GWP alternatives.

Impact on heat pump installers:

• R410A is being phased out — being replaced by R32 (GWP 675) and lower-GWP alternatives (R454B, R466A, R290)
• New ASHP models are increasingly using R32 or natural refrigerants
• Maintain training across the current and next-generation refrigerants
• R290 (propane) systems require separate A3 refrigerant competency — not covered by the standard F-Gas qualification; typically covered by City & Guilds 6187 or equivalent flammable refrigerant handling qualification

Frequently Asked Questions

My customer's ASHP is a monobloc. Do I still need F-Gas certification?

No — a monobloc ASHP has all refrigerant components pre-sealed within the outdoor unit. You only connect water pipes. There is no refrigerant handling involved, so F-Gas certification is not required for the installer. Note: if the monobloc unit ever develops a refrigerant leak and requires servicing of the refrigerant circuit, the manufacturer or a certified engineer must be used.

Can I service an R32 split ASHP if I only hold R410A certification?

No — City & Guilds 2079 Category 1 covers all refrigerant types (including R32). Category 2 covers specific refrigerant types as specified on the certificate. Check the specific certificate scope. If it covers A2L refrigerants, yes; if it only covers A1 refrigerants (non-flammable), no.

Do F-Gas records need to be kept in a specific format?

No specific format is mandated. A paper log, spreadsheet, or dedicated F-Gas management software are all acceptable. The key requirement is that the required information is recorded and can be provided to the Environment Agency on request. Several software tools are available (e.g., F-Gas Manager, REFCOM's own record-keeping template).

Regulations & Standards

• UK F-Gas Regulations (SI 2015/310 and amendments) — retained from EU Regulation 517/2014; the primary regulatory framework for F-Gas in the UK post-Brexit

• City & Guilds 2079 — qualification standard for F-Gas handling competency; the standard UK certification route

• REFCOM registration scheme — approved body registration for companies handling F-Gas; operated by ACRIB

• HSE COSHH Regulations — relevant to refrigerant handling as chemical substances in the workplace

• British Refrigeration Association (BRA) guidance — practical guidance on R32 and A2L handling

• REFCOM — refcom.org.uk — company registration and engineer certification

• City & Guilds 2079 — cityandguilds.com — F-Gas qualification details

• Environment Agency F-Gas guidance — gov.uk — compliance requirements and record-keeping

• ACRIB — acrib.org.uk — industry guidance on refrigerant handling

• air source heat pump installation — monobloc vs split installation; refrigerant pipe run guidance

• mcs 007 heat pump standard — MCS certification requirements for ASHP installation

• heat pump commissioning checklist — commissioning steps including split system refrigerant handling