Air conditioning and F-gas compliance

Your air conditioning and F-gas duties

If your business premises have air conditioning or refrigeration systems, you are likely to have obligations under two separate sets of regulations. The Energy Performance of Buildings Regulations 2012 require periodic inspections of larger air conditioning systems. The Fluorinated Greenhouse Gases Regulations 2015 require regular leak checks and careful management of refrigerant gases.

These are distinct requirements enforced by different bodies. Air conditioning inspections assess energy efficiency and are enforced by local authority trading standards. F-gas leak checks address environmental protection and are enforced by the Environment Agency (or equivalent devolved body). You need to comply with both.

This guide explains what you need to do for each set of requirements.

Mandatory air conditioning inspections

If your air conditioning system has an effective rated output of 12kW or more, you must have it inspected by an accredited energy assessor at least once every 5 years. This applies to individual systems and to combined air conditioning and heating systems above the 12kW threshold.

What the inspection covers

The accredited assessor evaluates:

• The overall energy efficiency of the air conditioning system
• Whether the system is appropriately sized for the cooling load of your building
• The condition of ductwork, controls, and distribution systems
• Opportunities for cost-effective improvements or alternatives

You receive a report with recommendations for improving efficiency. While you are not legally required to implement the recommendations, they can reduce your energy costs. The report must be retained and made available to enforcement authorities on request. The penalty for failing to have the inspection carried out is a fine of up to 300 pounds per missed inspection period.

Finding an accredited assessor

The assessor must be accredited under an approved scheme. Check the Non-Domestic Energy Performance Certificate register to find accredited assessors in your area. Ensure the assessor holds Level 5 Air Conditioning Inspection accreditation.

F-gas leak checking

If your air conditioning or refrigeration equipment contains fluorinated greenhouse gases (F-gases), you must have it checked for leaks at intervals that depend on the quantity of gas in the system. The quantity is measured in tonnes of CO2 equivalent (tCO2e), calculated by multiplying the weight of refrigerant in kilograms by its global warming potential (GWP).

Who can carry out leak checks

F-gas leak checks must be carried out by a certified F-gas engineer holding both individual qualifications and working for a company with F-gas company certification.

When choosing a contractor for F-gas work, verify that both the individual engineer and their company hold current F-gas certification from an approved body such as Refcom, BESCA, or an equivalent. Ask for certification numbers and check them before work begins.

F-gas phase-down: planning for the transition

The UK is phasing down the use of high-GWP hydrofluorocarbon (HFC) refrigerants. This means the gases commonly used in existing air conditioning systems are becoming progressively harder to obtain and more expensive.

What this means for your business

If your air conditioning system uses R410A (GWP 2,088) or R404A (GWP 3,922), you should plan for the transition to lower-GWP alternatives. Key considerations:

• Existing systems - you can continue to maintain and service existing systems, but the cost of topping up high-GWP refrigerant will increase as supply reduces under the quota system.
• Replacement systems - when replacing equipment, choose systems using lower-GWP refrigerants such as R32 (GWP 675) or R290 propane (GWP 3). From January 2025, new single split AC systems cannot use refrigerants with GWP of 750 or more.
• Budget planning - factor in the increasing cost of high-GWP refrigerant when budgeting for maintenance. Early replacement with a low-GWP system may be more cost-effective than continuing to maintain an older unit.

Record keeping

You must maintain comprehensive records for both AC inspections and F-gas compliance:

• AC inspection reports - keep the current report and at least one previous report. Make available for enforcement on request.
• F-gas leak check records - date of each check, quantity and type of F-gas, results, any leaks found and repaired. Retain for at least 5 years.
• Refrigerant quantities - record the amount of F-gas in each piece of equipment and the total across your premises.
• F-gas purchase and disposal records - quantities purchased, recovered, recycled, reclaimed, or destroyed.
• Contractor certification - copies of F-gas certification for all engineers who work on your systems.