Heat pumps, air conditioning and refrigeration

• Regulation (EU) 2024/573 — fluorinated greenhouse gases
• Directive 2014/35/EU — Low Voltage
• Directive 2014/30/EU — EMC
• Regulation (EU) 2017/1369 — energy labelling
• Regulation (EU) 2016/2281 — ecodesign
• Directive 2014/68/EU — Pressure Equipment for some circuits

Who has to appoint one

Manufacturers and sellers outside the Union placing air conditioning, heat pumps or refrigeration equipment on the EU market. Equipment pre-charged with fluorinated greenhouse gases can only be placed on the market if the gases are accounted for within the EU quota system, and a non-EU seller must appoint an authorised representative for that purpose.

Thresholds and exemptions

The F-gas quota applies to hydrofluorocarbons placed on the market, with declaration and verification duties. Energy labelling and ecodesign apply per product group.

What must appear on the label

CE marking, manufacturer and EU representative details, model and serial number, refrigerant type and charge in kilograms and in tonnes of CO2 equivalent, the energy label with EPREL QR code where the group requires it, and the WEEE symbol.

Marketplace fields

Marketplaces require EPREL registration and the label for labelled groups. Pre-charged split systems sold online to consumers are a recurring enforcement target, because installation requires a certified technician and the quota accounting is frequently missing.

Documentation you must hold

EU declaration of conformity, technical file, electrical and pressure documentation, refrigerant charge records, the F-gas declaration of conformity with the quota system verified by an independent auditor, EPREL registration, and WEEE and packaging registrations.

Standards and testing

EN 60335-2-40 for heat pumps and air conditioners, pressure testing for the refrigerant circuit, EMC testing, and performance measurement for the seasonal efficiency values declared under ecodesign and labelling.

Language requirements

Installation and operating instructions in the language of each member state, including the refrigerant handling and leak checking information required by the F-gas rules.

When it applies

Documentation and quota accounting before placing on the market. The F-gas Regulation of 2024 tightens the phase-down sharply through the decade, with bans on certain equipment types by date and GWP threshold.

How long records are kept

Ten years for technical documentation, fifteen for EPREL data, and F-gas records per the Regulation.

What happens if you do not comply

Withdrawal, customs refusal and fines. Illegal HFC imports have been an enforcement priority for years, with criminal proceedings in several member states, and pre-charged equipment outside the quota system is seized at the border.

Who enforces it

Market surveillance and environmental authorities, customs, and energy agencies for labelling.

Where the boundary lies

Selling a pre-charged split unit to a consumer online is lawful only where the quota accounting is in place and, in most member states, where the unit is sold to or installed by a certified undertaking. This is the most frequently overlooked requirement in the category.

Questions we are asked

Do we need an F-gas representative as well as an Article 4 operator?

If you place pre-charged equipment on the market from outside the Union, yes: the F-gas Regulation requires its own authorised representative for quota purposes.

Can consumers install a split system themselves?

Handling the refrigerant circuit requires certification in every member state, so equipment sold for self-installation is a compliance and enforcement risk.