Refrigerants over 3 kg
Refrigerants over 3 kg: Your obligations
Reporting duty, logbook, leak checks and specialist permit: this is what ORRChem Annex 2.10 requires for air conditioning systems, heat pumps and refrigeration systems with more than 3 kg of refrigerant – plus the new refrigerant rules from 2027.
Illustration
Reporting duty: report systems over 3 kg to the FOEN
Anyone who commissions or decommissions a stationary system with more than 3 kg of refrigerant must report this to the Federal Office for the Environment (FOEN) within three months. This applies to refrigeration and air conditioning systems as well as heat pumps, to permanent and temporary systems – and since 1 June 2019 regardless of which refrigerant is used, i.e. also for natural refrigerants such as propane or CO₂.
The decisive figure is the charge on the type plate or in the logbook. According to the ORRChem, a system comprises all refrigerant circuits that serve the same use.
As of October 2026. Basis: ORRChem Annex 2.10 section 5.1 and the FOEN enforcement guide «Operation and maintenance».
| Question | What applies |
|---|---|
| Which systems? | Stationary systems with more than 3 kg of refrigerant: refrigeration systems, air conditioning systems and heat pumps, regardless of the refrigerant. Systems used for national defence are exempt. |
| To whom? | To the FOEN. The reporting office is run by Lombardi SA on behalf of the FOEN. Electronic reporting via the cooling-reg.ch platform is recommended; paper reports are still possible. |
| By when? | Within three months of commissioning or decommissioning. Systems already in operation that have not yet been reported must be reported immediately. |
| What is reported? | Date of commissioning or decommissioning, names of the owner, the specialist company and the specialist carrying out the work, type, location and cooling capacity of the system, type and quantity of refrigerant. On decommissioning also the recipient of the refrigerant; for heating systems commissioned after 30 September 2022, also the energy source and heating capacity. |
| Changes | The owner reports changes to the location, cooling capacity, type or quantity of refrigerant immediately. If the owner changes, the new owner reports their name immediately. If a system is replaced, the decommissioning of the old system and the commissioning of the new one must be reported. |
| Number | The FOEN assigns an identification number. It must be affixed to the system immediately, visibly, legibly and permanently – optionally with the reporting office's sticker. |
| Who reports? | The person who commissions or decommissions the system is obliged to report. The specialist company must draw the owner's attention to the reporting duty; in practice the specialist company often reports on the owner's behalf. |
Reporting office: cooling-reg.ch · FOEN – reporting systems with refrigerants
Logbook: the history of the system
For equipment and systems with more than 3 kg of refrigerant – regardless of the type of refrigerant – the owner must ensure that a logbook is kept. It bears the owner's name. It is normally created at commissioning; for existing systems at the first maintenance or leak check.
After every intervention and every maintenance, the specialist enters:
- Date of the intervention or maintenance
- Short description of the work
- Result of the leak check
- Quantity and type of refrigerant removed
- Quantity and type of refrigerant filled in – from 1.1.2027 also whether it is new or reclaimed
- Company, name and signature of the specialist
Leak check
Who has to have leaks checked – and how often?
The owner must have the system checked for leaks regularly, but at least at every intervention and every maintenance, if it:
- contains more than 3 kg of ozone-depleting or air-stable refrigerants (e.g. HFCs such as R32, R410A, R404A),
- from 1 January 2027 contains more than 3 kg of HFO refrigerants (e.g. R1234yf, R1234ze),
- contains air-stable refrigerants with a charge of more than 5 tonnes CO₂ equivalent – even below 3 kg.
| Check | Systems assembled on site | Factory-made, hermetically sealed compact systems and equipment |
|---|---|---|
| First check after commissioning | after 2 years | after 6 years |
| Second check | 1 year after the first check | 4 years after the first check |
| Further checks | annually | every 2 years |
Factory-made split systems are treated like factory-made compact systems only under strict conditions, including a maximum of 6 kg of refrigerant, connecting pipes of no more than 20 m and confirmation in the commissioning report. The ORRChem sets no leak-check requirements for natural refrigerants such as propane, CO₂ or ammonia; regular checks nevertheless help to avoid efficiency losses caused by refrigerant loss.
Leaking? If a leak is found, the owner must arrange for repair immediately; the system must then be checked for leaks again. Large systems: since 1.1.2025, systems with air-stable refrigerants of 500 tonnes CO₂ equivalent or more need a leak detection system with an alarm that is checked at least once a year (existing systems until 31.12.2026). From 1.1.2027 this also applies to systems with more than 250 kg of HFO refrigerant (systems commissioned before 2027 until 31.12.2028).
Specialist permit: who may work with refrigerants
Manufacturing, installing, maintaining or disposing of equipment and systems for cooling, air conditioning or heat generation, as well as disposing of refrigerants, may only be carried out professionally by persons with a specialist permit, a qualification recognised as equivalent or under their supervision. This also applies to leak checks – and regardless of the charge.
Since 1 March 2020 there have been two areas of application: vehicle air conditioning and all other equipment and systems, such as stationary air conditioning systems and heat pumps.
Responsibility
What is the owner's job, and what is the specialist company's?
The ORRChem refers to the «owner» of the system – usually the proprietor or the operator. In practice, the owner delegates many tasks to a specialist company but remains responsible.
| Obligation | Responsible | Basis |
|---|---|---|
| Report commissioning and decommissioning (over 3 kg) | Whoever commissions or decommissions the system; the specialist company points out the reporting duty | Annex 2.10 section 5.1 |
| Report changes and change of owner | Owner or new owner | Annex 2.10 section 5.1 |
| Have a logbook kept (over 3 kg) | Owner; entries by the specialist | Annex 2.10 section 3.5 |
| Arrange leak checks | Owner | Annex 2.10 section 3.4 |
| Have leaks repaired immediately | Owner | Annex 2.10 section 3.4 |
| Work on the refrigerant circuit | Specialist with a specialist permit | Article 7 ORRChem |
Examples
What does this mean for typical systems?
The decisive figure is always the charge on the type plate. CO₂ equivalents are calculated as charge in kg × GWP of the refrigerant.
Split air conditioner under 3 kg
No reporting duty and no logbook under the ORRChem. A leak check is only required if the charge exceeds 5 tonnes CO₂ equivalent – with R410A (GWP 2088) from around 2.4 kg, with R32 (GWP 675) only above 7 kg. Installation and maintenance nevertheless only by specialists with a specialist permit.
Multi-split, VRF or heat pump over 3 kg
With HFCs such as R32 or R410A: report, affix the number, keep a logbook and have leaks checked according to the check intervals. From 2027, leak checks also apply to systems with over 3 kg of HFO.
Propane heat pump over 3 kg
Reporting and a logbook are mandatory here too. The ORRChem does not require leak checks for natural refrigerants – regular maintenance still makes sense.
Older system with R404A or R507A
Refrigerants with a GWP of 2500 or more may only be refilled with reclaimed refrigerant, and only until 31.12.2029. From 2030, refilling is prohibited – plan the replacement in good time.
New rules from 2027
Which refrigerants are still permitted for new systems?
On 29 October 2025 the Federal Council tightened Annex 2.10 ORRChem (AS 2025 747). The new bans for stationary systems apply from 1 January 2027; for supply to third parties the previous rules still apply until 30 June 2027. They concern the placing on the market of new systems – existing systems may continue to be operated.
| New stationary system | GWP below 150 | GWP 150 to below 750 | GWP 750 and above |
|---|---|---|---|
| Air conditioning up to 12 kW cooling capacity | permitted | not permitted; split systems with direct evaporation and direct condensation still until 31.12.2028 | not permitted |
| Air conditioning over 12 to 200 kW | permitted | permitted, except self-contained systems and systems with direct evaporation (transition periods: split until 2028, self-contained with direct evaporation over 50 kW until 2029, VRF until 2032) | not permitted |
| Heat pump up to 12 kW heating capacity | permitted | not permitted; split systems with direct evaporation and direct condensation still until 31.12.2028 | not permitted |
| Heat pump over 12 to 250 kW | permitted | permitted, except self-contained systems (over 50 kW transition until 31.12.2029) | not permitted; up to GWP 2100 transition for split systems until 31.12.2028 and for self-contained systems over 50 kW until 31.12.2029 |
Natural refrigerants such as propane (R290), CO₂ (R744) and ammonia (R717) are not restricted by Annex 2.10 when placed on the market. HFO refrigerants such as R1234yf and R1234ze are not stable in air but, as in the EU, are being restricted step by step: from 1.1.2032 they are banned in appliances for cooling and heating rooms and in self-contained air conditioning systems and heat pumps up to 12 kW, and from 1.1.2035 also in split air conditioners and split heat pumps up to 12 kW – in each case with an exception if the safety standards cannot be met otherwise.
Plug-in appliances (up to 4 kW, not permanently connected) with air-stable refrigerants are prohibited in principle unless there is no substitute according to the state of the art. According to the FOEN, new portable compact air conditioners with such refrigerants may no longer be supplied since 1.7.2020.
| Refilling existing systems | Rule |
|---|---|
| Natural refrigerants and HFOs | permitted |
| Air-stable, GWP below 750 | permitted |
| Air-stable, GWP 750 to below 2500 (e.g. R410A) | Permitted in air conditioning systems and heat pumps. In refrigeration systems for food, industrial and process cooling and ice rinks, only with reclaimed refrigerant from 1.1.2032. |
| Air-stable, GWP 2500 and above (e.g. R404A, R507A) | Only with reclaimed refrigerant, until 31.12.2029. Prohibited from 1.1.2030 (exceptions include systems below –50 °C). |
| Ozone-depleting refrigerants (e.g. R22) | prohibited |
Comparison
Refrigerants compared: pros and cons
GWP = global warming potential over 100 years. Safety group according to SN EN 378-1: A = lower, B = higher toxicity; 1 = no flame propagation, 2L = lower flammability, 3 = higher flammability.
| Refrigerant | GWP | Safety group | Properties according to the sources | Typical use | New systems (CH) |
|---|---|---|---|---|---|
| R32 (HFKW) | 675 | A2L | Substitute for R410A; stable in air | Split air conditioners, multi-split/VRF, heat pumps | up to 12 kW no longer from 2027 (split with direct evaporation until 2028) |
| R454B (HFC/HFO blend) | 465* | A2L | Substitute for R410A; stable in air | Chillers, industrial heat pumps | like R32 (GWP 150 to below 750) |
| R410A (HFC blend) | 2088 | A1 | non-flammable; GWP above 750 | previously split air conditioners and heat pumps | Air conditioning: no longer; heat pumps only transition periods |
| R404A (HFC blend) | 3922 | A1 | very high GWP; refilling only with reclaimed refrigerant | existing refrigeration systems | no longer |
| R507A (HFC blend) | 3985 | A1 | very high GWP; refilling only with reclaimed refrigerant | existing refrigeration systems | no longer |
| R290 (propane) | 3 | A3 | very good thermodynamic properties, but flammable; installation outdoors or with suitable ventilation | Heat pumps, chillers up to several 100 kW, refrigerators | permitted |
| R744 (CO₂) | 1 | A1 | non-flammable; transcritical or subcritical operation; efficiency depends on the application, good for waste heat at high water temperatures | Commercial and industrial refrigeration (standard at large retailers), increasingly heat pumps | permitted |
| R717 (ammonia) | 0 | B2L | very good thermodynamic properties and coefficients of performance; toxic, so special safety measures are needed; more complex system design | Industrial refrigeration, industrial heat pumps, large air conditioning systems, ice rinks | permitted |
| R1234yf (HFO) | below 1 | A2L | not stable in air; degradation product trifluoroacetic acid (TFA) | Car air conditioning | permitted; bans from 2032/2035 for systems up to 12 kW |
| R1234ze (HFO) | below 1 | A2L | good thermodynamic properties; not stable in air | Industrial and air conditioning refrigeration, heat pumps, chillers | permitted; bans from 2032/2035 for systems up to 12 kW |
The official sources do not quantify pressure levels or prices, so we do not state them. According to the FOEN's explanatory report, buyers will initially pay a premium for environmentally friendly technologies, which is expected to level out as volumes grow.
And the EU? F-gas Regulation 2024/573
Switzerland has aligned its new rules with the EU Regulation on fluorinated greenhouse gases so that series products made in the EU can also be offered here. For split systems up to 12 kW, the European Commission lists the following bans:
- from 1.1.2025: single-split air conditioners with less than 3 kg of F-gas and a GWP of 750 or more
- from 1.1.2027: split air-to-water systems with a GWP of 150 or more
- from 1.1.2029: split air-to-air systems with a GWP of 150 or more
- from 1.1.2035: split systems with fluorinated greenhouse gases in general
In each case, exceptions apply where safety requirements at the site make this necessary. In Switzerland, the rules of the ORRChem apply.
Maintenance, leak checks and logbook from a single source
We maintain air conditioning systems and heat pumps of all brands – with a checklist, leak check according to the ORRChem, logbook entry and service report.
Sources
ORRChem (SR 814.81), Annex 2.10 Refrigerants · Amendment of the ORRChem of 29 October 2025 (AS 2025 747), Annex 2.10 in force from 1 January 2027 · FOEN – Refrigerants · FOEN – reporting systems with refrigerants · FOEN enforcement guide «Equipment and systems with refrigerants: operation and maintenance» (September 2025, PDF) · FOEN enforcement guide «Systems with refrigerants: from concept to placing on the market» (September 2025, PDF) · FOEN – Overview of the most important refrigerants (February 2025, PDF) · FOEN – Graphic summary of the rules from 1 January 2027 (as of May 2026, PDF) · FOEN – Specialist permit for handling refrigerants · European Commission – Air conditioning, Regulation (EU) 2024/573. As of October 2026, no guarantee. The legal text is authoritative.
Read more
Services
Planning, building permits, installation, maintenance and repairs – for all brands
FAQ
Questions about refrigerants and maintenance obligations
Do I have to report my air conditioning system or heat pump?
Yes, if it is a stationary system with more than 3 kg of refrigerant – regardless of the refrigerant. Commissioning and decommissioning must be reported to the FOEN within three months, for example via cooling-reg.ch.
Who has to keep the logbook?
The owner of the system is responsible. After every intervention and every maintenance, the specialist enters the date, the work done, the result of the leak check, the refrigerant quantities and the company, name and signature.
How often must the system be checked for leaks?
At every intervention and every maintenance and on a regular basis. For systems assembled on site, the FOEN recommends the first check after 2 years, the second 1 year later and annually thereafter; for factory-made hermetic systems after 6 years, 4 years later and every 2 years thereafter.
May I continue to operate and refill my R410A system?
Yes. Existing systems may continue to be operated. Air conditioning systems and heat pumps with R410A (GWP 2088) may still be refilled – by specialists with a specialist permit. New air conditioning systems with R410A are no longer permitted from 2027.
Is R32 banned from 2027?
Not in general. From 1.1.2027, new air conditioning systems and heat pumps up to 12 kW must use a refrigerant with a GWP below 150; split systems with direct evaporation and direct condensation using R32 remain permitted until 31.12.2028. Existing R32 systems may continue to be operated and refilled.
Does the reporting duty also apply to propane heat pumps?
Yes. The reporting duty and the logbook apply from 3 kg for all refrigerants. The ORRChem does not require leak checks for natural refrigerants such as propane.
What applies to old systems with R404A?
R404A has a GWP of 3922. Such systems may only be refilled with reclaimed refrigerant, until 31.12.2029. From 2030, refilling is prohibited.
Let’s discuss your project
Questions about maintenance, leak checks or refrigerants? Call us or write to us.