1. Introduction

With a view to reducing greenhouse gas emissions to prevent undesirable effects on the global climate, the European Union has introduced the F-Gas Database, or an electronic register where it will be mandatory to communicate all data relating to sales activities and installation of air conditioning systems.

Since these are equipment that contains fluorinated greenhouse gases, the items on our e-store can be sold only by virtue of a self-declaration in which the purchaser guarantees that the installation of the products will be managed exclusively by F-Gas certified companies and / or professionals.

2. European Union (EU) policy

The European Union has established that developed countries must reduce emissions of greenhouse gases by 80-95% by 2050 to limit climate change which foresees a temperature increase of 2°C in order to prevent unwanted effects on the climate.

The European Commission has adopted a roadmap towards a competitive low-carbon economy in 2050. Compared to 2005, a 60-61% reduction in emissions other than CO₂ - including fluorinated gases and excluding emissions from agriculture - is required by 2030.

Fluorinated gases or F-Gas (HFC, PFC, SF6) are artificial chemical substances used in various sectors and applications. These gases do not contribute to the reduction of the ozone layer and their use is safe due to the low level of toxicity and flammability. However, most of them have a high global warming potential (GWP) up to 23,000 times higher than that of CO₂. The F-Gases represent 2% of the total greenhouse gas emissions of the entire European Union, but since 1990 they have grown by 60%.

Regulation 517/2014 aims to reduce F-GAS emissions in order to achieve EU climate goals, including:

• Periodic obligation to check for leaks and install leak detection systems;
• Obligation to recover residual gases in order to guarantee their recycling, regeneration or destruction;
• Restrictions on the marketing of gas and equipment containing them;
• Control on the use of certain gases;
• Labeling of products and equipment before being put on the market;
• Reduction of the quantity of hydrofluorocarbons marketed through a quota system;
• Training and qualification programs for personnel working on equipment containing gas;
• Monitoring and tracking of the production, import and distribution phases, including the use of gas.

The expected result is that, thanks to the new regulation, European Union F-Gas emissions will be reduced by 60% by 2030. In this perspective, the European Union, with the aim of verifying the progress made in achieving the objectives to reduce emissions, considers the monitoring of emissions of fluorinated greenhouse gases to be of fundamental importance. For this reason the use of consistent and high quality data for the communication of emissions of fluorinated greenhouse gases is fundamental: therefore the Regulation asks all Member States to establish information communication systems in order to acquire data on the emissions.

3. D.P.R 146/2018: subjects involved

Regulation (EU) 2067 provides for the certification of natural persons for stationary refrigeration and air-conditioning equipment, fixed heat pumps and refrigerated cells of refrigerated trucks and trailers as well as companies for stationary refrigeration and air conditioning equipment and heat pumps containing F-Gas.

Individuals and companies, as established by the Regulation, which carry out activities such as the control of leaks from equipment containing fluorinated greenhouse gases, recovery of fluorinated greenhouse gases, installation, repair, maintenance, assistance and dismantling are required to observe the following obligations:

• Enrollment in the Registry;
• Obtaining a Certificate;
• Communication of installation, maintenance, dismantling and leak check data.

Retailers, on the other hand, which supply to third parties products containing fluorinated gases and / or equipment containing fluorinated gases that are not hermetically sealed have the obligation to be registered in the Registry and to communicate their sales data.

4. The national electronic register of certified persons and companies

Individuals and companies are registered with the National Telematic Registry in such a way that information on the activities governed by this decree is made accessible to all interested parties, and that their transparency, certification and evaluation bodies are guaranteed.

Registered users include companies and individuals who carry out activities on fixed refrigeration equipment, fixed air-conditioning equipment and on fixed heat pumps.

The online registry can be consulted by section:

• Section A
  Certification Bodies, Conformity Evaluation Bodies and Assessment
• Section B
  Individuals and companies not subject to the obligation of certification but only of registration in the FGAS Register
• Section C
  Certified people and companies
• Section D
  People who have obtained the Certificate
• Section E
  Exempt persons or persons with a temporary exemption from the certification obligation
• Section F
  People and companies that have obtained certification in another Member State

5. Certification

Certificates are issued by accredited certification bodies whose list is available on the Registry website. These bodies operate according to accreditation schemes prepared by Acredia (the only certification body) and approved by the Ministry of the Environment. This ministry, on January 29, 2019, approved the following accreditation schemes:

• Personnel accreditation scheme for the issuing of certifications to natural persons involved in the activities referred to in Regulations (EC) n.304/2008 and n.306/2008, as well as to Execution Regulations (EU) 2015/2067 and 2015/2066
• Company accreditation scheme for the issuing of certifications to the companies that carry out the activities referred to in Regulation (EC) n.304/2008 and to the execution regulation (EU) 2015/2067.

6. Fluorinated greenhouse gas data bank and equipment containing fluorinated gases

Article 6 of Regulation 517/2014 provides that operators establish and maintain, for the indicated equipment, registers which specify a series of information. The D.P.R. 146/2018, which established the database of fluorinated gases and equipment containing flowing gases, provides for the obligation to communicate all the activities affected by the Regulation starting from 25 September 2019.

The obligation to communicate is no longer for the operators but for the certified subjects (persons and companies) who carry out the activity of installation, maintenance, repair, leak check and dismantling, each for the part of their competence.

The equipment defined by Article 4 c.2 of Regulation 517/2014 are the following:

• fixed refrigeration equipment (chillers and mini-chillers);
• stationary air-conditioning equipment (monosplit systems, multi-split systems and fixed air conditioners without an external unit);
• fixed heat pumps (air / water heat pumps, hybrid systems, floor heating);
• fixed fire protection equipment;
• refrigerated truck cells and refrigerator trailers;
• electrical switches.

The communication must be made electronically to the national database managed by the Chambers of Commerce no later than 30 days:

• from the installation of the equipment;
• from the first intervention to check for leaks, maintenance or repair of equipment already installed;
• from the dismantling of the equipment.

The data to be communicated to the Database are the following:

• date of installation or date of intervention;
• invoice and / or sales receipt (if available);
• place of installation or disposal;
• operator data;
• type of equipment;
• quantity and type of fluorinated greenhouse gases present and / or possibly added;
• name and address of the recycling or regeneration plant;
• identification data of the certified natural person or of the certified company that carried out the intervention;
• quantity and type of greenhouse gases recovered during the intervention on the equipment;
• observations (unencoded free field).

A natural or legal person exercises effective control if all the following conditions are met:

• free access to the equipment which involves the possibility of monitoring the components and their functioning and the possibility of granting access to third parties;
• operation control and ordinary management;
• the power, including financial, to decide on technical changes, the modification of the quantities of fluorinated gases in the appliance, and the performance of checks or repairs.

According to the D.P.R. n. 146/2018 the company or body that is configured as an "operator" of the equipment containing F-Gas is not obliged to register with the Registry or be certified. However, the same company or organization has the obligation to contact certified persons or companies for the installation, maintenance, repair, assistance and disposal of the aforementioned equipment as well as for the loss and recovery control of the F- Gases contained in them.

Starting from 25 September 2019, therefore, the obligation to keep records will be respected by the communication that installers and maintenance technicians will send to the database from which the operator can download a certificate containing all the information related to their equipment.

7. Sales data communication

Equipment not hermetically sealed or containing fluorinated greenhouse gases are sold to end users if it is demonstrated that the installation is carried out by a certified company (Regulation 517 art. 11). This obligation refers to all equipment regardless of the content of fluorinated gases (F-Gas).

The D.P.R. 146/2018 establishes that the obligation to communicate sales data starts from 24 July (6 months after entry into force of the Decree). Until July 24, the paper records will have legal validity (this is a requirement set by the European Regulation). Starting from July, 25th 2019, instead, only the new Database will have legal value.

8. Sanctions

With regards to the sanctions, Legislative Decree 5 March 2013 No. 26 "Disciplinary sanctions for the violation of the provisions of Regulation (EC) n. 842/2006 on certain fluorinated greenhouse gases" remains in force. The activity of supervision and assessment, for the purpose of imposing the sanctions referred to in paragraph 1, is carried out by the Ministry of the Environment and Protection of the Territory and the Sea.

These sanctions can affect operators (or owners) of refrigeration systems, air conditioning systems and heat pumps that do not use certified personnel for installation and control activities.