New Chemicals and Climate Protection Ordinance 2026 – key facts from the Federal Law Gazette
The new Chemicals and Climate Protection Ordinance came into force on 17 April 2026. It is based on the “Regulation implementing Regulation (EU) 2024/573 on fluorinated greenhouse gases” of 14 April 2026, published in the Federal Law Gazette 2026 I No. 100. At the same time, the previous Chemicals and Climate Protection Ordinance of 2 July 2008 ceased to apply. The regulation was promulgated on 16 April 2026 and came into force the following day.
The aim of the revised version is to align German regulations with the new European F-Gas Regulation (EU) 2024/573. This replaces the previous EU Regulation No. 517/2014. For operators, specialist companies, qualified personnel and distributors of fluorinated greenhouse gases, this means: many basic obligations remain in place, but the requirements regarding documentation, certificates, refresher courses and operator inspections are becoming significantly more specific.
1. New structure and new EU references
The new regulation is still referred to as the ChemKlimaschutzV for short, but its content is aligned with the new EU F-Gas Regulation. The Federal Law Gazette makes explicit reference to Regulation (EU) 2024/573 of 7 February 2024. In addition, several new EU implementing regulations are cited, including Implementing Regulations EU 2024/2174, EU 2024/2215, EU 2025/623, EU 2025/625, EU 2025/627 and EU 2025/1893.
This makes it clear: the new German regulation is not an isolated national measure, but complements European F-gas legislation. It primarily regulates how competence, company certificates, responsibilities, operator obligations, take-back and administrative offences are implemented in Germany.
2. Specific limit values for refrigerant losses remain in place
A particularly practical section is found in § 2 ChemKlimaschutzV. This sets out specific limits for specific refrigerant leakage. Operators of stationary installations must ensure that these limits are not exceeded during normal operation.
For self-contained refrigeration systems with a refrigerant charge of at least 3 kg, a limit of 1% per year applies.
For installations erected at the site after 30 June 2008, the following limit values apply:
| Refrigerant charge |
Maximum specific refrigerant loss |
| under 10 kg | 3 % |
| 10 to 100 kg | 2 % |
| over 100 kg | 1 % |
Higher limits apply to older installations. If they were installed after 30 June 2005 and up to 30 June 2008, the limits are 6%, 4% or 2%, depending on the charge. For installations installed up to 30 June 2005, the limits are 8%, 6% or 4%.
It is also important to note that operators must ensure access to all detachable connections, insofar as this is technically possible and reasonable. These regulations do not apply to hermetically sealed installations that are marked accordingly.
3. Take-back and documentation: five-year retention obligation
The take-back of used fluorinated greenhouse gases is also expressly regulated. Under Section 4 of the ChemKlimaschutzV, manufacturers and distributors are obliged to take back fluorinated greenhouse gases after use or to ensure that they are taken back by a third party designated by them.
Of particular practical importance is the documentation requirement: manufacturers, distributors, commissioned third parties and operators of disposal facilities must keep records of the type and quantity of the substances taken back or disposed of, as well as their disposition. These records must be retained for at least five years and submitted to the competent authority upon request.
4. Competence: Refresher training at least every seven years
One of the most significant changes concerns competence. Under § 5 ChemKlimaschutzV, certain activities under Article 10(1) of EU Regulation 2024/573 may only be carried out by natural persons who hold an appropriate certificate of competence, possess the necessary technical equipment and are trustworthy.
A new or significantly stricter requirement concerns the deadline for refresher courses: if more than seven years have elapsed since the certificate of competence was issued, the person must have attended a refresher course that was also completed no more than seven years ago.
In practical terms, this means: competence is no longer a one-off qualification. Specialists must regularly update their knowledge.
5. Refresher courses: not always with a practical component
Section 8 of the ChemKlimaschutzV describes in more detail what refresher courses are intended to achieve. They serve to refresh theoretical knowledge and practical skills relevant to the respective activity. One interesting exemption is that a practical component does not need to be completed if the qualified person declares that they have carried out the activities covered by the certificate of competence in the two years prior to the refresher course. A list of these activities must be attached to the self-declaration.
The certificate must also state the date by which the next refresher course must be taken. In addition, the certificate must contain the name of the certifying body, the date of issue and the signature of the authorised issuer.
6. Company certificates: new obligation to monitor employees
Companies are also being held more accountable. Anyone holding a company certificate must, in accordance with Section 10(5) of the ChemKlimaschutzV, ensure that the competent persons employed attend a refresher course at least every seven years.
A transitional relief measure is also provided for companies: if the application for a company certificate is submitted before 12 March 2029, the company may, for nine months from the date of application, demonstrate compliance with certain requirements using an old company certificate and a confirmation of receipt. However, the competent authority may object to this within four weeks.
7. Transition periods: 2027 and 2029 are key
The transitional provisions are set out in § 17 ChemKlimaschutzV. Several important deadlines are specified there:
Old regulations regarding certain obligations remain in force until the end of 12 March 2027.
Old certificates of competence and certificates generally remain valid until the end of 12 March 2029. From 13 March 2029, the new refresher training requirement under Section 5(1), first sentence, point 2, becomes fully applicable.
Old company certificates and attestations also remain valid in principle until the end of 12 March 2029. For certain establishments under Article 5(3), first subparagraph, points (b) and (c) of EU Regulation 2024/573, Sections 5, 10 and 14 shall apply only from 13 March 2027.
8. Operators’ obligations: Evidence must be verified
The new Regulation makes it clear: operators must not rely solely on the assumption that a service provider is ‘already doing everything correctly’. They must ensure that contracted companies or individuals can provide the necessary certificates of competence and company certificates. Breaches of these operators’ obligations may be treated as administrative offences.
In practice, this means: Operators should actively request, document and regularly update evidence. Particularly when it comes to the maintenance, servicing, repair, installation or decommissioning of systems containing F-gases, the certification status of the contracted individuals and companies should be checked.
Conclusion: More documentation requirements, clear deadlines, greater responsibility
The new Chemicals and Climate Protection Ordinance 2026 does not mark a complete departure from the previous system, but it makes many obligations more specific. The fixed deadlines are particularly important:
17 April 2026: Entry into force of the new ordinance
12 March 2027: End of certain transitional arrangements
13 March 2027: Application of certain obligations for additional facilities
12 March 2029: End of key transitional periods for existing certificates of competence and company documentation
13 March 2029: Application of the new seven-year refresher training requirement
every seven years: Refresher course for competent persons
five years: Retention requirement for certain take-back and disposal records
For operators, specialist companies and qualified persons, this means: Now is the right time to review existing certificates, training intervals and documentation processes. Those who act early will avoid future gaps in expertise, company certification and operator obligations.
