Refrigerants
In Switzerland, refrigerants are regulated by Annex 2.10 of the Chemical Risk Reduction Ordinance (ORRChem). A key objective of the Ordinance is to reduce emissions of ozone depleting and potent climate-warming refrigerants. The Ordinance is regularly updated to keep it in line with the advancing state of the art.
Relevant legal provisions
NEWS:
Regulations from 1 January 2027
Changes to Annex 2.10 of the Chemical Risk Reduction Ordinance (ORRChem) in accordance with the Federal Council decision of 29 October 2025 (press release). The graphical summary is available in German and French:
1. Refrigerants stable in the atmosphere in stationary systems
Refrigerants stable in the atmosphere are refrigerants, which contain any of the substances stable in the atmosphere according to Annex 1.5 ORRChem (Annex 2.10 number 1 paragraph 3 ORRChem). A system is considered stationary if it is used unmoved.
Prohibitions
Annex 2.10 number 2.1 paragraphs 3 to 7 ORRChem prohibit the placing on the market (including import) of certain stationary systems (e.g. air conditioning systems, industrial cooling systems, heat pumps) that use refrigerants stable in the atmosphere. The ban applies in particular to systems with high cooling capacities, systems containing refrigerants stable in the atmosphere with high global warming potentials, and systems with high filling capacities.
The guide to “systems containing refrigerants: from concept to placing on the market” (available in German, French and Italian) explains these regulations in more detail. It defines the state of the art in the various fields of application.
5th updated edition 2022 (available in German, French and Italian). The updated 6th edition will be available here soon.
The guide also contains the following practical summaries:
2. Refrigerants stable in the atmosphere in appliances and mobile systems
An appliance is a plug-in system for refrigeration which is not permanently connected to cool or heat distribution piping; also fixed appliances are classified as appliances rather than as systems (Annex 2.10 number 1 paragraph 6 ORRChem). To promote uniform enforcement practice, the following terms are further specified from a technical point of view:
- A "plug-in system" is a compact system which can be connected and operated unchanged, directly and without the need for tools after delivery to its installation site and whose maximum electrical power consumption does not exceed 4 kW.
- "Permanently connected" is defined as a permanent (non-detachable) welded or brazed joint in accordance with the specifications of SN EN 378-2:2017 section 6.2.3.2.2.
Mobile systems are considered to be systems if they are used in a mobile way (in contrast to stationary systems), e.g. air conditioning systems in cars or public transport vehicles, transport refrigeration for containers on trucks, etc.
Prohibitions
Annex 2.10 number 2.1 paragraph 2 ORRChem prohibits the manufacture and placing on the market (including import) of certain appliances and mobile systems that use refrigerants stable in the atmosphere (see list below).
Exemptions
Appliances and mobile systems listed in Annex 2.10 number 2.1 paragraph 2 letters a-e ORRChem are permitted subject to certain requirements. The current technology must be such that no substitute is available, the refrigerant stable in the atmosphere with the smallest impact on the climate must be used, and state-of-the-art measures must be taken to prevent refrigerant emissions (Annex 2.10 number 2.2 paragraph 2 ORRChem). Annex 2.10 number 7 paragraph 4 ORRChem regulates the transitional period after a change in the state of the art; the FOEN gives notice of these changes on this page after consultation with the industry concerned.
For the appliances and mobile systems listed below, the current state of the art is as follows:
a) Refrigerators and freezers for cooling food or perishable goods
b) Appliances for cooling or heating rooms
c) Devices for cooling or heating processes, including dehumidification and drying
d) Mobile air conditioning systems used in motor vehicles, rail vehicles or ships
e) Mobile refrigeration systems for the transport of food or perishable goods
An alternative currently does not exist, so the direct exemption applies for all uses.
3. Ozone-depleting refrigerants
Ozone-depleting refrigerants are refrigerants that contain any of the substances that deplete the ozone layer according to Annex 1.4 ORRChem (Annex 2.10 number 1 paragraph 2 ORRChem).
Prohibitions
- Placing refrigerants containing CFCs or halons on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2004.
- Placing refrigerants containing virgin HCFCs on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2010.
- Placing refrigerants containing HCFCs on the market and their use for refilling appliances and systems, has been prohibited since 1 January 2015.
Exemptions
Since 1 June 2019, the manufacturing, placing on the market, import for private purposes and export of appliances and systems that use ozone-depleting refrigerants has been permitted, subject to certain requirements. The current technology must be such that no alternative is available, the refrigerant used must have an ozone depleting potential of not more than 0.0005 and state-of-the-art measures must be taken to prevent refrigerant emissions (Annex 2.10 number 2.2 paragraph 6 ORRChem). Annex 2.10 number 7 paragraph 4 ORRChem regulates the transitional period after a change in the state of the art; the FOEN gives notice of these changes on this page after consultation with the industry concerned.
4. Leakage checks, maintenance log and reporting procedures
Annex 2.10 numbers 3.4, 3.5 and 5 ORRChem lay down certain obligations with regard to checking for leaks, keeping a maintenance log and giving notice of certain systems and appliances that use refrigerants. The guide to "systems and appliances containing refrigerants: operation and maintenance" (available in German, French and Italian) explains these obligations.
As of October 1, 2021, the reporting of stationary systems with more than 3 kg of refrigerants will be carried out by the company Lombardi SA. Further information on how to make the notification can be found at www.bafu.admin.ch/meldung-kw (information available in German, French and Italian).