Heat Pump Refrigerant Records and Leak Checks: 2026 Guide

Heat pump refrigerant records and leak checks are triggered by CO2-equivalent charge, not by kilograms. Under the EU F-gas Regulation (EU) 2024/573, any stationary heat pump holding 5 tonnes CO2e or more of an F-gas needs a documented leak check at least every 12 months, every 6 months from 50 tonnes, and every 3 months from 500 tonnes. For R410A that 5-tonne line lands at about 2.4 kg of charge, so plenty of ordinary domestic ground-source units are in scope while a modern 2 kg R32 split is not. Every unit in scope needs a per-installation log kept for at least five years, and in Sweden, if the operator's total across all checkable equipment reaches 14 tonnes CO2e, they owe an annual report to the kommun's environmental office by 31 March. Propane (R290) and CO2 (R744) units carry none of this, because they are not F-gases.

Almost none of this is your legal duty. It is the operator's duty, which usually means the property owner or the housing association. But you hold the certificate, the gauges and the only record that the check happened. If your log is a photo in a technician's phone, the operator has nothing to report and you have nothing to invoice for next year.

Which heat pumps need refrigerant records and leak checks

Take the factory charge from the nameplate, multiply by the refrigerant's GWP, divide by 1000. That is your tonnes CO2e. Compare it to 5, 50 and 500.

Two adjustments matter in the field. If the unit is labelled hermetically sealed, the first threshold moves from 5 to 10 tonnes CO2e; it must carry the label, not just look sealed to you. If a fixed leak detection system is fitted, the intervals double: 12 months becomes 24, 6 becomes 12, 3 becomes 6. Above 500 tonnes CO2e that system is mandatory, and it has to be checked itself at least every 12 months.

What this means for a normal week

• A 2.0 kg R32 domestic split is 1.35 tonnes CO2e. Out of scope: no check, no log, no report.
• A 2.6 kg R410A ground-source unit from 2016 is 5.4 tonnes CO2e. Annual check, forever, until it is replaced.
• A 30 kg R410A VRF system in a small office is 62.6 tonnes CO2e. Six-month checks.
• Three R410A units at 2.6 kg each on one site total 16.3 tonnes CO2e. Each needs its own check, and the site is over the Swedish 14-tonne reporting line.

Charge matters even when the unit is small. Add 400 g of R410A to a 2.1 kg system to clear a nuisance fault and you push it from 4.4 to 5.2 tonnes CO2e, creating a permanent annual obligation for your customer. Say so in writing before you do it.

What the per-installation log must contain

Article 7 of Regulation (EU) 2024/573 requires a record for each piece of equipment in scope. It is a living document, not a certificate you issue once. It must hold:

• The quantity and type of F-gas installed at commissioning.
• Quantities added during installation, servicing, maintenance or repair, each with its date.
• Whether that gas was virgin, recycled or reclaimed, and for recycled or reclaimed gas the facility's name, address and certificate number.
• Quantities recovered, including at decommissioning, and where they went.
• The company and technician who did the work, plus the certificate number.
• The dates and results of every leak check, including the ones that found nothing.
• For a decommissioned unit, the measures taken to recover and dispose of the gas.

Retention is at least five years, and it cuts both ways: the operator keeps the record, and your firm keeps a copy for five years too. Both copies must be produced for the competent authority on request. A leak that is found and repaired has to be re-checked within one month to confirm the repair held, and that follow-up visit is a separate log entry.

The annual report to the kommun

This is the Swedish layer on top of the EU rules, in förordning (2016:1128) om fluorerade växthusgaser. Two duties get missed.

Reporting, by 31 March

If an operator's leak-checkable equipment adds up to 14 tonnes CO2e or more, they must report the previous calendar year to the supervisory authority, normally the kommun's miljöförvaltning. Deadline: 31 March. The report covers:

• Operator name, address, organisation number and a contact person.
• Each unit, its refrigerant, and charge in kilograms and tonnes CO2e.
• Amounts added and recovered during the year.
• Dates and results of the leak checks, and who performed them under which certification.

The aggregate counts equipment in scope for leak checks, not every cooling appliance on site. A house with one 5.4-tonne unit does not report. A landlord with four of them does.

Notification before installation

If an installation or conversion takes the operator's total to 14 tonnes CO2e or more, they must notify the supervisory authority in advance, not after commissioning. This one catches people, because the person who knows the threshold has been crossed is you, in the plant room, weeks before anyone at the kommun hears about it. Put it in your handover checklist and give the customer a filled-in draft.

Breaching either duty carries a miljösanktionsavgift, a fixed charge set in förordning (2012:259) on strict liability. Being busy is not a defence. The amounts sit in the ordinance, so check the current figure rather than a number from a forum post. Naturvårdsverket has the plain-language guidance at naturvardsverket.se; the regulation is on EUR-Lex.

Who is allowed to touch the circuit

Leak checks, recovery, installation, repair and decommissioning need a personal certificate in the right category, and the firm needs a company certificate too. In Sweden that runs through Incert. Categories are set at EU level and scoped by charge size and by whether the work breaks into the circuit, so a technician certified for small hermetically sealed units is not automatically cleared for a VRF system. Put the certificate number in every log entry and an expiry surfaces in your own records before an inspector finds it.

What changes between now and 2029

Regulation (EU) 2024/573 tightens the HFC quota year by year and Annex IV bans specific products from specific dates. Check the wording before you quote, but the direction is clear:

• From 2027, splits up to 12 kW using F-gases at GWP 750 or above come off the market, as do monoblocs up to 12 kW at GWP 150 or above.
• From 2029, monoblocs up to 12 kW containing any F-gas go, and splits up to 12 kW are held to GWP 150 or below.
• Leak-check duties extend to certain HFOs listed in Annex II from 2027, but on mass thresholds (roughly 1 kg, 10 kg, 100 kg) rather than CO2e, because their GWP is near zero. A low-GWP swap does not always mean no paperwork.

The quota squeeze reaches your invoices first. R410A does not become illegal to use, it becomes expensive and awkward to buy, which changes the repair-or-replace conversation on every unit you top up.

Keeping the record attached to the site, not the technician

Most firms do not fail this on knowledge. They fail on custody. The check happens, the gauges say fine, and the evidence lives in one person's head until that person is on holiday in March. Make the record a property of the installation instead:

1. Register the equipment, not the visit. One record per outdoor unit: serial number, refrigerant, factory charge, tonnes CO2e, commissioning date, resulting interval. Calculate the CO2e once and store it. Nobody should do that multiplication on a ladder.
2. Let the interval create the work. A service agreement that generates the next visit automatically, dated from the last check rather than a wall planner, is the only version that survives a busy autumn.
3. Use one form, every time. Fixed fields for gas added, gas recovered, virgin or reclaimed, method, result, technician, certificate number. Fixed fields make a five-year export possible. Free text makes it impossible.
4. Capture it in the plant room. Plant rooms are basements and there is no signal in basements. The form has to work offline and sync later, or it gets filled in from memory in the van.
5. Attest and freeze. Sign off, produce a PDF, attach it to the site. That PDF is the operator's copy and your copy at the same time.
6. Export in February. Filter to sites over 14 tonnes CO2e, pull the year's checks, hand each customer a report they can lodge. Billable, and an afternoon's work if the data is structured.

This is the shape of work OdinTask is built for: persistent equipment and site records, service agreements that generate the recurring visit, a form builder for the leak-check protocol, an offline-first field app for the basement, attest and PDF at the end. The rules are not the hard part. Getting the same eleven fields captured on every unit, by every technician, for five years running is the hard part.

If you are reading this outside Sweden

The 5, 50 and 500 tonne CO2e thresholds, the five-year records and the certification requirement are EU-wide and apply directly in every member state, plus Northern Ireland. Only the national layer varies.

• Great Britain runs its own retained F-gas regulation with the same CO2e thresholds, the same log duties and its own quota. Technicians certify through schemes such as REFCOM. There is no annual report to a council, so the log is the whole of the evidence. See gov.uk/guidance/f-gas.
• Australia requires an ARCtick licence to handle refrigerant and runs an HFC import phase-down rather than EU-style leak-check intervals.
• New Zealand prices HFCs through the Emissions Trading Scheme and uses an approved filler scheme rather than a mandated inspection calendar.

The workflow survives the border even where the thresholds do not. Record against the equipment, let the interval schedule itself, and keep five years you can actually retrieve.

Four mistakes that cost money

• Counting kilograms. 3 kg of R32 is nothing. 3 kg of R410A is a lifetime obligation.
• Skipping the one-month re-check after a repair. Separate legal step, separate log entry.
• Assuming the customer knows they are the operator. Most housing associations have no idea. Tell them in writing at handover and keep the copy.
• Only logging the leaks. A check that finds nothing still needs its date and result recorded. The clean ones are the evidence.

Heat pump refrigerant records and leak checks are not difficult work. They are recurring work, and recurring work stays done only when the system remembers instead of the person. If your logs live in a phone gallery and a spreadsheet, start with the equipment register and the recurring visit. Everything else follows. You can try OdinTask free for 14 days and see what it costs on the pricing page.