Refrigeration Plant
Where Regulation (EU) 2024/573 applies, shipboard plants follow general release-prevention and prompt-repair duties; leak checks, records and certification do not automatically extend to every plant, while reefers are a separate mobile category.
Operational Explanation
Where Regulation (EU) 2024/573 applies, shipboard plants follow general release-prevention and prompt-repair duties; leak checks, records and certification do not automatically extend to every plant, while reefers are a separate mobile category.
Regulatory Reference
MARPOL Annex VI/12 (ODS); Regulation (EU) 2024/573, recital 14, Articles 4–7 and 13(3); jurisdiction/operator/equipment-specific implementing law.
Refrigeration units of intermodal containers, including reefers, are a specific mobile category under Article 5(3)(b). Paragraph 5 defers application of paragraphs 1 and 6 to their operators until 12 March 2027: check thresholds and exemptions, without bringing that deadline forward or confusing it with general Article 4 duties. Regulation (EU) 2024/573, Article 5.
Article 13(3) prohibits using the gas for maintenance or servicing: it does not by itself order shutdown of equipment retaining its existing charge. For derogations until 1 January 2030, document reclaimed gas and its label, or recycled gas with permitted origin and user. Regulation (EU) 2024/573, Article 13(3).
MARPOL VI/12 separately governs ozone-depleting substances (ODS). The HCFC installation ban covers ships constructed from 1 January 2020 and, on earlier ships, equipment contractually delivered from that date (or actually delivered where no contractual date exists). Ships subject to VI/6.1 need an ODS equipment list and, where they have rechargeable ODS systems, an ODS record book: check the voyage criterion in regulation 6.1 as well as tonnage. Regulation 12 excludes permanently sealed equipment without charging connections or potentially removable ODS-containing components. IMO — MARPOL VI/12 and VI/6.1.
Scope of Application
Do not use EU flag as the sole test. Article 5 categories, operator, equipment and operation determine leak-check/record/certification applicability.
Procedure / How to Complete It
- Determine whether the Regulation governs operator, equipment and operation.
- Prevent unintended release and repair leaks without undue delay where applicable.
- Apply periodic leak checks/records/certification only to listed categories; treat reefers separately.
- From 1 January 2025 check Article 13(3) for GWP ≥2500.
- Until 1 January 2030 assess reclaimed/recycled conditions, labelling, source and exemptions.
Practical Example
A fixed shipboard plant does not automatically receive the full Article 5/7/10 regime; a reefer may fall under its specific mobile category.
What Typically Goes Wrong
Extending the full F-gas regime to every ship or saying high-GWP was simply banned in 2020 without thresholds, transition and reclaimed/recycled exceptions through 2030.
Common Mistakes Mistake Library
| Mistake | Consequence | How to Avoid It |
|---|---|---|
| Extending the full F-gas regime to every ship or saying high-GWP was simply banned in 2020 without thresholds, transition and reclaimed/recycled exceptions through 2030. | Non-compliant decision or treatment | Follow the approved arrangement and applicable sources |
What the PSCO Checks
Operational Tips
- Separate current requirement, class/maker, SMS and voluntary guidance.
- Do not improvise tests, thresholds or intervals.
- Record deviations and corrective action.
Preparation checklist
- Applicability documented
- Ship plant/reefer distinct
- Leak-repair duty
- Article 13(3) and exceptions
- Gas source/label checked
FAQ
Related Topics
Last substantive revision of this page: 16 September 2026 · page fingerprint a547125dc0f7