F gas wholesalers and resellers: record keeping requirements
What records you have to keep when selling F gas in bulk, or in equipment, and how to comply with the EU hydrofluorocarbon (HFC) phase down.
You’re an F gas wholesaler if you sell fluorinated greenhouse gases (F gases) in bulk.
Customer screening requirements
You must get a ‘letter of assurance’ from each customer that you sell bulk quantities of F gas to.
You can download a and send it to each of your customers to complete.
You must keep each letter of assurance for 5 years and make it available on request.
Different types of customer must include different information in their letter.
Company certificate
Contractors that service the following types of equipment require a company certificate:
- stationary refrigeration systems
- stationary air conditioning and heat pump systems
- stationary fire protection systems
Find out details of F gas company certification requirements.
Letters of assurance from these customers must include the:
- customer’s company certificate number
- name of the body that issued the certificate
- expiry date of the certificate
You must record the quantity and type of F gas for each sale to these customers.
Staff qualifications
Contractors that service the following types of equipment don’t require a company certificate, but their staff must be qualified to handle F gas:
- refrigerated trucks and trailer
- high voltage switchgear
- car and van mobile air-conditioners - only when recovering F gas, not when topping it up
Find out qualifications required by individuals who work with F gas.
Letters of assurance from these customers must:
- confirm that the company only works on refrigerated trucks and trailers, mobile air conditioners in cars and vans, or high voltage switchgear
- provide an F gas handling certificate number for any of the customer’s staff members that work directly with F gas
You must record the quantity and type of F gas for each sale to these customers.
Contractors that don’t require a certificate or qualifications
Contractors that service the following types of equipment don’t need company certificates, or staff qualified to handle F gas:
- transport refrigeration equipment apart from refrigerated trucks and trailers, eg small vans, ‘iso-containers’, trains, ships
- mobile air conditioners that aren’t in vans or cars, eg mobile air conditioners in buses, trains, ships
Letters of assurance from these customers must confirm the company only works on “other transport refrigeration or other mobile air-conditioning” equipment.
You don’t need to record the quantity or type of F gas you sell to these customers.
End users
End users are businesses that operate equipment containing F gas, like refrigeration or air conditioning systems.
They include businesses that own and operate equipment, and facility management companies that are contracted to service equipment.
Letters of assurance from end users must state how they intend to use F gas purchased from you.
Owners and operators must also provide a list of staff F gas handling certificate numbers, if their equipment includes:
- stationary refrigeration systems
- stationary air conditioning and heat pump systems
- stationary fire protection systems
- refrigerated trucks and trailer
- car and van mobile air conditioners
- high voltage switchgear
Contractors that service their equipment must also provide:
- a company certificate number if they service stationary refrigeration, air conditioning and heat pump, or fire protection equipment
- staff F gas handling certificate numbers if they service refrigerated trucks and trailers, car and van mobile air conditioners, or high voltage switchgear
You must record the quantity and type of F gas sold to end users if either of the following apply:
- the gas is going to be used in servicing or installation activities, eg to refill or install a refrigeration system
- the end user is an owner or operator of equipment, buying gas that’s going to be used by a contractor servicing the equipment
Equipment manufacturers and specialist users
Your other customers could be:
- manufacturers of equipment that contains F gas like aerosols, refrigeration and air conditioning equipment, insulating foam or fire protection systems
- magnesium smelters
- semiconductor manufacturers
- users of F gas in solvent applications and laboratory applications
Letters of assurance from these customers must state what they’ll use the F gas you sell them for.
You don’t have to record the quantity and type of F gas sold to these customers.
F gas resellers
F gas resellers are other wholesalers and companies that purchase F gas in bulk to sell on to other companies.
Letters of assurance from these customers must state they’re F gas resellers.
The letter must also state that the reseller will screen the customers they sell gas to.
You don’t have to record the quantity and type of F gas sold to resellers.
Selling equipment containing F gas
You can sell equipment ‘pre-charged with’ (containing) F gas, like split system air-conditioning units.
If you’re selling to an end user, you must get confirmation from them that the equipment will be installed by someone qualified to handle F gas.
End users must provide you with a letter stating that the equipment will be installed by either:
- someone with an F gas handling certificate
- someone from a contractor that has a company certificate
Contractors that have been through your screening process for bulk sales can buy equipment without providing a letter. They will have provided details of their company certificate in the screening process.
Resellers don’t need to provide you with a letter. They must get a letter from the end user when they resell the equipment.
Hermetically sealed equipment
You don’t need to get confirmation that installation will be carried out by someone qualified to handle F gas, if the equipment is hermetically sealed.
Equipment is hermetically sealed if both of the following apply:
- any part of the product that contains F gas is welded or brazed shut, or permanently sealed in another way
- the product has a tested leakage rate of less than 3 grams per year
A system that meets these 2 conditions is considered hermetically sealed, even if it has capped valves or capped service ports to allow access for repairs and maintenance.
Comply with the HFC phase down
The EU is phasing down the use of hydrofluorocarbons (HFCs). Read details of the HFC phase down.
Only organisations with a quota can produce or import HFCs for the EU market. Find out how to get an HFC quota.
You must buy HFCs from a quota holder, or a reseller that has bought the HFCs from a quota holder or a quota holder’s intermediary.
You need to get written confirmation that HFCs are from a supplier’s HFC quota, if you’re buying HFCs directly from a quota holder.
You need to get written confirmation that HFCs are accounted for in the EU quota system, if you’re buying HFCs from a reseller or other intermediary.