Refrigerants: leak checks and the 31 March annual report

If you hold fluorinated refrigerants in heat pumps, refrigeration or air conditioning plant, two duties apply: recurring leak checks whose interval is set by the quantity of fluorinated greenhouse gases in the equipment, and an annual report to the municipal environmental committee by 31 March of the following year, if the installation contains at least 14 tonnes of carbon dioxide equivalent in total. The rules follow from the EU F-gas Regulation (EU) 2024/573, which has replaced the previous regulation since 11 March 2024, and from the Swedish Ordinance (2016:1128).

Leak checks — the intervals

Quantity in the equipment	Without leak detection system	With leak detection system
From 5 tonnes CO2e	At least every 12 months	At least every 24 months
From 50 tonnes CO2e	At least every 6 months	At least every 12 months
From 500 tonnes CO2e	At least every 3 months	At least every 6 months

The thresholds are counted in carbon dioxide equivalent, not in kilograms of refrigerant. The same weight of two different refrigerants gives entirely different CO2e depending on the gas's global warming potential, which is why a small installation with an older refrigerant can land above a threshold that a larger installation with a modern one clears.

One change in the 2024 regulation worth knowing: HFO refrigerants are now also covered by the leak check and reporting requirements.

Are all our heat pumps counted together, or does the threshold apply per unit?

The two thresholds work differently, and this is the most common confusion. The leak check interval is set by the quantity in the individual piece of equipment — a unit at 6 tonnes CO2e is checked annually regardless of how many other units you have. The 14-tonne reporting threshold, by contrast, refers to the installation's total quantity, that is the sum of the equipment at the site. A portfolio can therefore be subject to reporting without any single machine being particularly large.

The annual report

The report covers the previous calendar year and must reach the supervisory authority — the municipal environmental committee — by 31 March. Among other things it must state what equipment exists, what quantities and refrigerants it contains, which checks were carried out and when, and what leaks were detected and remedied.

Two practical consequences:

• The checks must be done before the report is written. A check that should have been carried out in November and was forgotten cannot be repaired in March.
• The report is in practice written by the refrigeration contractor in most cases, but responsibility for filing it lies with the operator — normally the property owner. That the contractor "usually handles it" is no defence against the supervisory authority.

The Swedish Environmental Protection Agency (Naturvårdsverket) provides guidance on the regime; checks must be carried out by certified personnel.

31 March is one of only two fixed dates in the year

Almost everything else a property owner must do rolls per building: ventilation control every three or six years from the last inspection date, the energy certificate ten years from issue. The refrigerant report and the radon measuring season are the only items with a date in the calendar — see the annual calendar.

That paradoxically makes them easier to miss in a large portfolio: the rolling inspections are tracked in a system, while the fixed dates are assumed to be remembered by somebody.

What Emphyx does — and does not do

We read cooling system data from the energy certificate where it is present, so you can see which buildings in the portfolio have cooling or heat pump plant at all. That is a field in the building's data, nothing more.

There is no tracking of leak check intervals or of the reporting date in Emphyx. We do not produce the refrigerant report, carry out no leak checks and do not calculate the installation's carbon dioxide equivalent. Your refrigeration contractor does that, and you or the contractor file the report with the municipal environmental committee. If you are looking for a system that produces the annual report itself, you want a refrigerant register, not a property management platform.

If you have only a couple of smaller heat pumps below 5 tonnes CO2e, none of the requirements above apply — but the quantity is worth checking in the equipment documentation rather than assumed.