Refrigerant certification 2026: the A1 A2 B C D E reform explained to HVAC technicians and their customers
The Proclimo team
23 Jul 2026 - 07 min read
Two orders of 21 November 2025 — one on "Capacity" (legal entities), the other on "Aptitude" (natural persons) — published in the Official Journal on 6 and 10 December 2025, thoroughly overhaul the French framework for the handling of refrigerant fluids. Implementing Implementing Regulation (EU) 2024/2215, they replace the former categories I, II, III, IV with a new six-category framework (A1, A2, B, C, D, E) — plus a V category for vehicle air conditioning — extend the regulation to hydrocarbons (R-290 propane), to CO₂ (R-744) and to ammonia (R-717), and extend the validity of aptitude certifications from 5 to 7 years. The application is mandatory from 1 January 2027, with a transitional period until 12 March 2029 for current holders. For Proclimo, an air-conditioning and heat-pump installation, maintenance and repair company in Île-de-France, this is a structural reform: it conditions the legality of every intervention on a refrigerant circuit, the validity of our certifications with insurers, and the trust of our individual, property-management and tertiary-sector customers. Here is the complete guide to understand, anticipate and succeed in the transition.
Why this reform now?
A European harmonisation long awaited since 2024
Implementing Regulation (EU) 2024/2215 of 11 September 2024 modernised the European fluorinated certification framework, aligning it with the objectives of F-Gas Regulation 2024/573 (phase-out of high-GWP HFCs, transition to low climate-impact fluids: HFOs, R-290, R-744, R-717). Each Member State had to transpose these new categories by 12 March 2026. France does so with the two orders of 21 November 2025, NOR TECP2532494A (capacity) and TECP2532495A (aptitude).
What concretely changes for HVAC companies
- Six categories instead of four (I → A1, II → A2, III → D, IV → E) plus two new ones (B for CO₂, C for ammonia).
- Extension to hydrocarbons: category A1/A2 now also covers R-290 propane, which used to be treated separately.
- 7-year validity (instead of 5) for the aptitude certification, with mandatory periodic refresher training delivered by a Qualiopi-certified organisation.
- Commissioning skills explicitly listed (Annex II-B): pressure test, vacuum pull, leak check before start-up.
- Stronger penalties in case of non-recycling: suspension of the certification, 3-year period to comply, beyond that: obligation to retake the full exam.
info
A smooth transition until 12 March 2029: during the transitional period, certifications issued under the former order of 13 October 2008 remain valid. But beware: after 12 March 2029, without refresher training, the certification becomes invalid and the technician must retake the full exam (theoretical + practical).
Correspondence table: old → new categories
The table below summarises the equivalence between the former categories (order of 13 October 2008, repealed on 31 December 2026) and the new categories from the order of 21 November 2025. It comes from Annex VIII (refresher training) and Annex I (scope of activity) of the two texts.
| Former category (2008) | New category (2025) | Scope of activity | Refrigerants concerned | Refresher training |
|---|---|---|---|---|
| I (all operations, no charge limit) | A1 | Installation, maintenance, repair, commissioning, leak check, recovery, decommissioning | HFCs, HFOs, hydrocarbons (R-290), no charge limit | 3h30 |
| II (all operations, charge < 3 kg) | A2 | Same operations as A1, charge < 3 kg (or < 6 kg hermetic) | HFCs, HFOs, hydrocarbons, limited charge | 3h30 |
| III (recovery) | D | Recovery only | HFCs, equipment < 3 kg | 1h30 |
| IV (leak check without access to the circuit) | E | Leak check only, without intervention on the circuit | HFCs | 1h30 |
| (none) | B | Installation, repair, maintenance, commissioning | CO₂ (R-744) | Full initial training |
| (none) | C | Installation, repair, maintenance, commissioning | Ammonia (R-717 / NH₃) | Full initial training |
| V (vehicle air conditioning) | V | Check, maintenance, assembly, commissioning, recovery | Vehicle air conditioning (art. R.311-1 Highway Code) | Practical test only |
The 6 categories A1 A2 B C D E in detail
Category A1 — the flagship category for residential and tertiary HVAC
This is the category that Proclimo and most air-conditioning and heat-pump companies hold. It covers all operations on a refrigerant circuit — installation, commissioning, maintenance, servicing, repair, decommissioning, leak check, recovery — without charge limit, on HFCs (R-32, R-410A), HFOs (R-1234yf, R-1234ze) and hydrocarbons (R-290 propane). The exam covers the practical skills of Annex II-B: pressure test, vacuum pull, leak check before commissioning, clean refrigerant recovery.
Category A2 — the lighter one for splits under 3 kg
For residential monosplits and multisplits with a charge below 3 kg (or 6 kg for factory-hermetically sealed systems), the A2 category is sufficient. It is the direct equivalent of the former category II, extended to hydrocarbons. Warning: a 5 kg R-32 split falls under A1, not A2.
Category B — CO₂ (R-744) for commercial and industrial cooling
New category created for carbon dioxide (R-744), used in commercial and industrial cooling (supermarkets, cold-storage warehouses, ice rinks, high-temperature heat pumps). No equivalence with the former framework: a full initial training, theoretical and practical, is required.
Category C — ammonia (R-717) in industry
Ammonia (R-717 / NH₃) is a toxic but GWP=0 fluid, widely used in the agro-food industry, chemical industry and industrial cooling. Category C requires dedicated training (Annex II-C) and specific protective equipment. Outside the scope of typical residential/tertiary HVAC.
Category D — recovery only
For operators who only carry out refrigerant recovery for destruction or regeneration, on equipment with less than 3 kg of charge (or 6 kg hermetic). It is the equivalent of the former category III, refocused on recovery.
Category E — leak check without access to the circuit
For building maintenance technicians, energy managers, facility management agents who perform the periodic leak check of a refrigerant circuit without accessing it (neither manipulating the refrigerant). Visual inspection, electronic leak detector, traceability register. It is the equivalent of the former category IV, but now valid for 5 years (rather than 7) because it follows a different logic.
tip
For a ProClimo installer, the A1 category is the target. It covers 100% of our routine interventions (air-to-air heat pumps, air-to-water heat pumps, split air conditioners, multi-splits, ducted units, cassettes). If you also work on transcritical CO₂ (supermarkets) or ammonia, add B or C with complementary training.
2025-2029 schedule: 4 key dates to remember
| Date | Event |
|---|---|
| 21 November 2025 | Signature of the two orders (NOR TECP2532494A and TECP2532495A) |
| 6 December 2025 | Publication in the Official Journal of the "Capacity" order (companies) |
| 10 December 2025 | Publication in the Official Journal of the "Aptitude" order (technicians) |
| 1 January 2027 | Mandatory application of the new framework — new certifications must be issued under the A1 A2 B C D E V categories |
| 31 December 2026 | Repeal of the former order of 13 October 2008 (but already issued certifications remain valid until their expiry) |
| 12 March 2029 | Deadline for the refresher training of current holders (cat. I, II, III, IV) |
| Beyond 12 March 2029 | Former certifications invalid: obligation to retake the full exam |
What ProClimo has already put in place
At Proclimo, F-Gaz compliance is not optional: it is the foundation of our decennial insurance and our perfect-achievement guarantee. Concretely, here is what we have initiated since the texts came into force:
- Audit of the certifications register of our technicians (category I currently being converted to A1).
- Group enrolment in a Qualiopi refresher course (3h30) scheduled for the first quarter of 2027, well ahead of the 12 March 2029 deadline.
- Update of our capacity certification with our COFRAC-accredited certification body: the new certification will explicitly mention category A1.
- Display of the capacity certification number on all our quotes, invoices and intervention reports: it is mandatory, and it is also a mark of professionalism for our customers (homeowners, condominium property managers, tertiary asset managers).
- Overhaul of the intervention traceability register (charge reading, type of refrigerant, operations performed, leak check) to include the new items required by Annex II-B.
Why it matters for our customers
You are a homeowner, condominium property manager, tertiary asset manager or industrial site maintenance manager: the reform also concerns you, indirectly but directly. Three reasons:
- Validity of the decennial guarantee: an installer whose certification is not compliant is exposed to a forfeiture of the decennial guarantee (see our article on the decennial guarantee for air conditioning and heat pumps in 2026). In the event of a claim, the insurer may refuse cover.
- Regulatory compliance of the site: for a tertiary building subject to the BACS decree (see our complete guide on the class A GTB mandatory since 1 January 2026) or to the tertiaire decree (see our article on the EET digital certification of 1 July 2026), the HVAC maintenance company's capacity certification is a piece of evidence in a DREAL inspection.
- Leak control and carbon footprint: a technician trained in the new practices (clean recovery, reinforced leak check, R-290 handling) limits refrigerant leaks, which are taxed under the fluorinated component of the regulated tariff (since the 2021 Climate & Resilience Act).
The special case of R-290 propane: what changes
R-290 (propane) is a natural fluid with a GWP of 0.003 (almost zero), increasingly used in residential air-to-air heat pumps (Daikin Altherma, Atlantic Calypso, Bosch Compress 7000i) as a replacement for R-32. It is however flammable (A3) and requires specific constraints:
- Maximum charge of 150 g per circuit in occupied premises (IEC 60335-2-40 standard).
- Maximum charge raised to 5 kg in certain unoccupied configurations.
- Room ventilation mandatory, leak detection recommended, electrical isolation nearby.
With the 2025 reform, the handling of R-290 falls within the scope of category A1 (and A2 for charges < 3 kg), with a specific competence training module (Annex II-B, point 4). If you plan to install an R-290 heat pump, require that your installer holds this R-290 competence added to their A1 category — that is what we guarantee at Proclimo.
warning
Handling a refrigerant circuit yourself with R-290 — or any other refrigerant — is strictly prohibited without certification. This prohibition is set out in Article R.543-106 of the French Environmental Code (penalty: one year's imprisonment and a €75,000 fine, art. L.173-1 of the same code). For a diagnosis or a quote, call on a certified professional: contact Proclimo.
How to verify the compliance of an installer?
Before signing a quote, ask for:
- The company's capacity certification number (which must be mentioned on the quote).
- A copy of the technician's aptitude certification (category and expiry date).
- Proof of decennial insurance specific to HVAC installations (heat pump, air conditioning, refrigerant cover).
- The previous interventions register (charge reading, leak check).
Proclimo systematically provides these four documents with every quote and keeps a traceability register per installation. To learn more about selecting a certified installer, see our 2026 HVAC technician shortage guide: how to choose your installer.
Useful links and resources
- Official texts: Order of 21 November 2025 — Capacity (TECP2532494A) · Order of 21 November 2025 — Aptitude (TECP2532495A)
- European regulations: Implementing Regulation (EU) 2024/2215 of 11 September 2024 (fluorinated certification overhaul) · Regulation (EU) 2024/573 of 7 February 2024 (F-Gas) (HFC phase-out)
- French Environmental Code: Art. R.543-99 (capacity certification) · Art. R.543-106 (aptitude certification) · Art. L.173-1 (criminal penalties)
- France Compétences: Directory of COFRAC-accredited certification bodies · List of Qualiopi courses for refrigerant refresher training
To go further, see our other Proclimo guides:
- 2026 HVAC technician shortage: how to choose your installer — the #1 criterion is the validity of the capacity certification.
- RGE reform 2026: air-conditioning and heat pump installer — the capacity certification complements the RGE qualification.
- Decennial guarantee air conditioning and heat pump 2026 — what your insurance covers (and does not cover).
- R-290 propane refrigerant: safety and environment — why propane is becoming the reference.
- F-Gas R-32 regulation 2026 — where do we stand on the HFC phase-out?
ProClimo installs, maintains and repairs your air conditioners and heat pumps in Île-de-France, with A1-certified technicians and a decennial insurance explicitly covering refrigerants. Request your free quote or call us on 09 83 30 98 07: we provide, with the quote, a copy of our capacity certification, our aptitude certifications, and our decennial insurance certificate.
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