BRL 100: what happens when there's a non-conformity during the audit?

Your auditor has found something. Maybe a work instruction is missing, maybe a refrigerant logbook hasn't been kept up to date, maybe someone is working without a valid BRL 200 certificate. What happens now depends almost entirely on one question: is it a critical or a non-critical non-conformity? This article is about the process after the finding — for preparation for the audit itself, see The BRL 100 annual check: what the auditor expects.

Critical or non-critical: the distinction that determines everything

The BRL 100 assessment guideline has a fixed definition of a critical non-conformity: a non-conformity with the requirements of the BRL that has an immediate negative effect on the quality of the execution of the work or on the environment (which can therefore also include F-gas leakage). The BRL explicitly gives three examples:

• a non-conformity that means a mandatory element of the BRL is not documented or implemented — think of missing procedures, work instructions or records;
• not having the mandatory instruments and equipment available for the work, or not checking these in accordance with the BRL requirements;
• having non-certified personnel carry out work for which an F-gas certificate for persons is mandatory (with an exception for apprentice technicians who work under supervision and obtain their BRL 200 certificate within two years).

Everything that doesn't fall into this category is a non-critical non-conformity — the BRL simply defines it as "a non-conformity that cannot be regarded as a critical non-conformity". In practice this covers things like an administrative omission that doesn't directly affect the quality or safety of the work.

This distinction is not cosmetic: it determines your correction period and how quickly your certificate is put at risk.

Correction period: how much time do you have?

For critical non-conformities, your company must have corrected them within three months of the finding. After that, the CI carries out a reassessment to establish whether the corrective measure is adequate.

For non-critical non-conformities a longer period applies: corrective measures must be taken within six months of the finding. The assessment of this usually takes place at the next regular assessment, not via a separate reassessment.

The period for critical non-conformities was still four weeks under the older BRL 100 text (version 1.2, 2017). Since version 2.0 — mandatory from 2020, and therefore the currently applicable text — this is three months (chapter 6.4.3, "Opvolging van afwijkingen"); the six-month period for non-critical non-conformities is unchanged. Version 3.0 takes effect on 31 August 2026 — check with your certification body whether these periods remain unchanged in it.

From warning to suspension to withdrawal

If you don't meet the correction period — or the measure taken is not assessed by the CI as adequate — an escalating series of measures begins. Summarised, from light to severe:

• Written warning: if adequate corrective measures are not taken after a non-critical non-conformity. A written warning also follows for a second occurrence of the same non-critical non-conformity within a period of just over four years.
• Suspension of the use of the certificate: if no adequate measure has been taken within the period set in the written warning either.
• Withdrawal of the certificate: if no adequate measure has still been taken within the period set in the suspension.
• Direct withdrawal for a critical non-conformity that has not been adequately corrected within the applicable period — here the intermediate step of a warning is skipped.
• Direct withdrawal in the case of (a reasonable suspicion of) a violation of statutory regulations relating to the work.

Both the written warning and the suspension come with a period of at most four weeks each time to still correct the issue adequately and to notify the CI of this. After a suspension, the CI first carries out an additional assessment; only once that shows your company once again fully meets the requirements is the suspension lifted. If your company still doesn't meet the requirements at that additional assessment, withdrawal follows.

The CI reports issued, suspended and withdrawn certificates to Rijkswaterstaat, the administrator of the BRL. Certificates can also be checked via the Centraal Register Techniek — so it doesn't pay to let a suspension pass by hoping nobody notices.

What does a suspension mean for your business operations?

A suspension means you may not (temporarily) make use of the F-gas certificate for companies. The precise operational consequences — can you still carry out work as long as you deploy certified technicians, or does everything come to a halt — vary depending on the certification body and the situation. Always take this up directly with your CI in the event of a (threatened) suspension; there is no single answer that applies to every situation.

Does this differ per certification body?

BRL 100 certification is issued by several authorised certification bodies (see the overview in What is BRL 100, and why does it affect your work order?). The critical/non-critical classification and the associated periods are fixed in the assessment guideline itself, so they are in principle the same for every CI. Each CI does work out this process further in its own certification regulations (complaints and disputes procedure, communication around the reassessment). Ask your own CI for those regulations if you want to know exactly how it works at their organisation.

Don't agree with a finding?

The BRL requires every CI to adequately safeguard the requirements for confidentiality, complaints and disputes from NEN-EN-ISO/IEC 17065 — the accreditation standard for certification bodies. So if you disagree with an identified non-conformity or with the measure imposed, you can always start a complaints or disputes procedure with your CI. The exact steps and periods for this are set out in your CI's certification regulations, not in the BRL itself.

Prevention is cheaper than correction

Most critical non-conformities that lead to a suspension process fall into a small number of recurring themes: missing or non-calibrated measuring equipment, gaps in the logbook or the refrigerant balance, and technicians working outside their BRL 200 authorisation. A few places to structurally reduce that risk:

• Calibration of measuring equipment BRL 100: everything you need to know
• F-gas logbook: what needs to be in it?
• Refrigerant balance — a practical guide to a balance that adds up
• The BRL 100 annual check: what the auditor expects