Reclaimed refrigerant gases: what changes after the entry into force of the new EU rules?

As of January 1, 2025, the European regulatory framework for reclaimed refrigerant gases has entered a new phase. The provisions introduced significantly strengthen traceability, certification, and use requirements , with the aim of making the refrigeration supply chain more transparent, controlled, and consistent with the principles of the circular economy.

The new rules not only redefine documentation requirements, but also directly impact the operational decisions of technicians, companies, and operators in commercial and industrial refrigeration.

Traceability and certification: a more rigorous system

With the entry into force of the new provisions, the management of reclaimed gases is now subject to a more structured control system throughout the supply chain. Each batch of reclaimed refrigerant must be registered on the F-Gas portal, indicating the type of fluid, the quantity, and the certified reclamation facility within the European Union.

Container labeling is also mandatory, clearly indicating the word "reclaimed," the batch number, and the EU plant of origin. This step allows compliant reclaimed gas to be clearly distinguished from other gases on the market.

A particularly relevant point concerns the exclusion of non-EU regenerated gases : these are no longer recognized as regenerated for regulatory purposes and are treated the same as virgin gases, thus being subject to the same restrictions and limitations.

Bans already in force and progressive limitations for high GWPs

Restrictions on the use of high-GWP reclaimed gases also came into force in 2025. The use of refrigerants with a GWP of 2,500 or more is no longer permitted in stationary refrigeration systems, while from 2026 the ban will also be extended to split systems and air conditioning applications.

Temporary exemptions are available for existing plants, valid until 2032, provided that the gases used are correctly labeled, certified, and tracked according to the new requirements.

This transitional period allows operators to gradually plan the replacement of the most impactful refrigerants, carefully evaluating the technical and economic implications.

Concrete impacts for operators and cold chain companies

Operationally, the new rules require a change in approach to refrigerant management . Technicians and companies are now required to more carefully verify the origin of reclaimed gases, ensuring they have been processed in certified EU facilities and fully comply with labeling and registration requirements.

Proper management of the F-Gas portal becomes a key element, as is the ability to document every refrigerant movement and use. At the same time, the importance of ongoing training for technical staff is growing, as it is necessary to operate in compliance with more stringent procedures and ensure safety, traceability, and regulatory compliance.

Regeneration as a strategic lever for the transition

With the entry into force of the new provisions, refrigerant gas regeneration takes on an even more strategic role. It is no longer simply a cost-effective solution, but a key tool for reducing raw material consumption, limiting emissions, and strengthening a more sustainable and controlled European refrigeration supply chain .

The refrigeration sector is therefore called upon to integrate regeneration into a long-term vision, in which regulatory compliance, environmental responsibility, and operational continuity become closely interconnected elements.