Air conditioning without F-gases: which refrigerants and which certificate (BRL 200)?

An air conditioner without F-gases uses a natural refrigerant, such as propane (R290), CO2 or ammonia. F-gases are synthetic fluorinated gases, such as R32 and R410A. The Informatiepunt Leefomgeving (IPLO, Dutch Living Environment Information Point) lists ammonia, CO2 and hydrocarbons alongside F-gases. Since 29 September 2025, work on such installations also requires certification. So “without F-gases” does not mean “without a certificate”.

More about the EU rules is in the F-gassenverordening 2024 (EU F-gas Regulation 2024). The personal certificate you need for these installations is on the page about the personal certificate.

In short: an air conditioner without F-gases is not automatically free of rules. Anyone who works on the refrigerant circuit needs a certificate, whatever refrigerant is in it.

Which refrigerants are there?

Refrigerants fall into roughly two groups: F-gases and natural refrigerants. Each group has different requirements for safety and for the work.

Group	Examples	What you need to know
F-gases: HFCs	R32, R410A, R404A	Synthetic, strong greenhouse gas. Covered by the F-gas rules and the leak checks.
F-gases: HFOs	R1234yf	Also synthetic and also an F-gas, but with a low global warming potential (GWP). Used in car air conditioning and in blends. Covered by the F-gas rules.
Natural refrigerants	Propane (R290), CO2 (R744), ammonia (R717)	Not F-gases. Certification is required, and they are often flammable or toxic.

The classification matters for the work. A low global warming potential does not mean that a refrigerant is not an F-gas. A blend of R32 and R1234yf, such as R454B, even contains two F-gases. If in doubt, check the safety data sheet of the refrigerant or the nameplate of the installation.

What does “without F-gases” mean for the installation?

A propane heat pump or a CO2 installation contains no F-gases. That does not mean you may install them without papers. IPLO states that, since the new regulation, certification no longer applies only to F-gases. It also applies to hydrocarbons, CO2 and ammonia.

For the customer, something changes when choosing an installer. You cannot ask only about the refrigerant. You also ask for the personal certificate of the fitter and the company certificate of the installation firm.

Example: two heat pumps, one rule

Suppose you receive two quotes for a new heat pump. One installation uses R32, the other propane (R290). Both are air-to-water heat pumps for a home.

The R32 installation falls under the F-gas rules, with leak checks and a logbook. The propane installation is not covered by the F-gas rules, but it is subject to the certification requirement. In both cases the fitter needs a personal certificate, and the company needs a BRL 100 certificate (Dutch company certification scheme). The difference therefore lies mainly in maintenance and leak checks, not in whether papers are needed.

Read certificate needed to install a heat pump to see how this works in practice.

Safety with natural refrigerants

Natural refrigerants are not necessarily more dangerous, but they need different safety measures. Propane is flammable. Ammonia is toxic and has a sharp smell. CO2 can build up in a small room in case of a leak and displace oxygen.

That is exactly why the training and the exam differ per category. Category B covers CO2 and category C covers ammonia. Propane and other hydrocarbons fall under A1 and A2. See the personal certificate for the classification, and course or training if you want to prepare.

Common misconceptions

“Natural means free of rules.” Natural refrigerants also require a certificate.
“R32 and propane are the same.” They differ chemically and in safety. R32 falls under the F-gas rules, propane does not.
“My fitter has an F-gas certificate, so he may also work with propane.” The category determines what you may do. Check that the category matches the refrigerant.
“I don’t need a BRL 100 if the installation has no F-gas.” The company certificate depends on work for third parties, not only on the refrigerant. See BRL 100.

How do you recognise the refrigerant in an installation?

The refrigerant is shown on the nameplate of the installation, usually on the outdoor unit or the indoor unit. There you find the refrigerant designation, such as R32 or R290, and often also the quantity in kilograms. Read this before you start work on the installation.

If there is no clear designation, ask the manufacturer or the supplier. Do not work on an installation whose refrigerant you do not know. This applies especially to flammable refrigerants, because the safety requirements are different for them.

Which role does the refrigerant play in maintenance?

The refrigerant determines which leak check, which logbook and which safety measures are needed. An installation with F-gases falls under the leak check and the logbook from the F-gas rules. An installation with propane or CO2 does not fall under these, but the fitter does still need the right certificate.

For the owner, this means maintenance is not the same for every refrigerant. Ask the installer which refrigerant is in the system and what maintenance goes with it. For the F-gas rules, read leak checks and logbook.

Frequently asked questions

Is a propane air conditioner safer than an R32 air conditioner? That depends on the situation. Propane is flammable and requires other measures, such as limiting the quantity in a room. R32 is less flammable, but it falls under the F-gas rules. The choice is up to the installer and the manufacturer.

May I top up an air conditioner with propane myself? No, not without the right knowledge and the right certificate. Work on the refrigerant circuit requires certification, also with natural refrigerants.

Why is this on an F-gas page? Because many people think that “without F-gases” means that no rules apply. That assumption is incorrect, which is why we put it here.

What do you do if you are unsure about the refrigerant?

If you are unsure about the refrigerant, stop before you touch anything. Ask the installer for the refrigerant designation in writing, and ask them to state the quantity. That way you can check whether the F-gas rules or the rules for natural refrigerants apply.

A good installer can explain this in one minute. An installer who talks around the question, or who does not want to name the refrigerant, is a reason to ask for a second quote. That is not rude, but it is sensible.

For the choice between refrigerants, ask about the advantages and disadvantages for your situation. Consider energy use, maintenance and safety in the room where the installation will go.