What does and doesn't fall under the BRL 100 certification scope?

BRL 100 sounds like one clearly defined quality mark, but in practice installation companies often run into borderline cases: does that one heat pump fall under it, and does the obligation also apply if you only work on your own business premises? This article sets out which activities, installations and situations fall within the BRL 100 scope — and which (probably) fall outside it. For the basics of what BRL 100 is, see what is BRL 100?

The core rule: refrigerant circuit + for third parties

BRL 100 is the assessment guideline behind the legally required F-gas company certificate. According to the Informatiepunt Leefomgeving (IPLO) (opent in nieuw tabblad) and the Ondernemersplein (opent in nieuw tabblad), the core is simply formulated: as soon as a company or sole trader carries out operations on the refrigerant circuit for a client (a third party), the company certificate is mandatory. Two elements are therefore decisive — *what* you do (does it affect the refrigerant charge or the circuit) and for *whom* you do it (a customer, or yourself).

Which installation types fall under it?

Based on the official explanations from Kiwa (opent in nieuw tabblad), Techniek Nederland (opent in nieuw tabblad) and DEKRA (opent in nieuw tabblad), the following installations fall within the scope at any rate:

• Stationary refrigeration installations and freezer installations
• Climate control installations and air conditioning
• Stationary heat pumps (air-to-water, ground-water) — see also heat pump: is maintenance and a logbook mandatory?
• Fire protection equipment that operates with F-gases or alternative extinguishing agents

With BRL 100 version 3.0, the scope is further broadened from 31 August 2026 to mobile refrigeration applications: light refrigerated vehicles, reefers (refrigerated containers) and refrigerated rail wagons. Until that date, the current scope (version 2.0, without mobile applications) remains in force; from 31 August 2026, certifying bodies no longer issue new version 2.0 certificates, and existing version 2.0 certificates remain valid until 31 August 2028 at the latest. Check with your certifying body or in BRL 100 in 2026: what changes? what this means concretely for your company and any transition period.

Which refrigerants fall under it?

The scope is broader than F-gases alone. Besides fluorinated greenhouse gases, natural refrigerants also fall under the guideline: hydrocarbons (such as propane/R-290), carbon dioxide (CO2/R-744) and ammonia (NH3). A comparison of these refrigerants can be found in natural refrigerants: R-290, R-744 and ammonia compared. If you work exclusively with natural refrigerants, you therefore don't automatically escape BRL 100 — the guideline is refrigerant-independent as soon as it concerns refrigeration-engineering installations.

Which activities fall under it?

The scope doesn't just touch "installing", but the entire spectrum of activities on the refrigerant circuit:

• Installation of new equipment
• Maintenance and service
• Repair
• Leak checking and inspection
• Decommissioning
• Recovery of refrigerant (see also recovering refrigerant: the rules)

Activities that don't affect the refrigerant circuit — think of purely electrical work, mechanical mounting or structural work around an installation — are not explicitly named in the sources consulted as either within or outside the scope. We don't dare make a firm statement about that; if in doubt, check this with your certifying body.

What (probably) doesn't fall under BRL 100?

Work on your own installations (self-managed). This is the most concrete exception that emerges from the sources: the legal obligation applies to work "for third parties — clients". A company that works exclusively on its own refrigeration installations — for example a supermarket chain with its own technical service department that does not supply services to external customers — appears, based on this wording, not to fall under the legal BRL 100 certification obligation. Please note: this does not automatically release a company from other obligations, such as the technician's personal certificate (see BRL 200 F-gas personal certificate) or the logbook obligation for the installation itself. If in doubt about your specific situation, contact a certifying body.

No separate minimum quantity of refrigerant for the certification obligation itself. Important not to confuse two things: there *is* a CO2-equivalent threshold that determines *how often* a leak check is mandatory (see F-gas leak checks: how often are they mandatory? and the GWP values table for the underlying calculation). But for the question "does my company need a BRL 100 certificate", we found no separate minimum quantity in the official sources consulted — the obligation appears to arise as soon as you work on the refrigerant circuit for third parties, regardless of the charge. Confirm this for your situation with your CI before basing decisions on it.

BRL 100 is not the same as STEK or BRL K25000

A few common scope confusions, listed:

• STEK is a separate, older assessment framework with its own scope focus on refrigeration-engineering-specific professional competence. See STEK vs BRL 100 for the full difference.
• BRL K25000 is about CO safety in gas-fired combustion installations under the Gasketelwet and has nothing to do with refrigerants — see what is the Gasketelwet?.
• ISO 9001 is a generic quality management system, not a replacement for the legally required F-gas company certificate — see BRL 100 vs ISO 9001.

Sole trader? Same scope rules

If you work as a sole trader in refrigeration engineering for clients, the same "for third parties" rule applies: you need both the personal certificate and the company certificate. The full explanation is in sole trader in refrigeration engineering: certificates and insurance.

How Koldwerk helps with this

Whether an installation does or doesn't fall within your BRL 100 scope is a legal question that your certifying body has to answer — but as soon as the answer is "yes", you have to demonstrably keep records of it. Koldwerk's installation management lets you record per installation whether it falls within the BRL 100 scope, so that your file and your refrigerant module automatically apply the right fields and checks.

Disclaimer: this article is a practical explanation based on the official explanations from Kiwa, Techniek Nederland, DEKRA and the Informatiepunt Leefomgeving (IPLO). For borderline cases — such as self-managed situations, mobile applications or work that does not directly affect the refrigerant circuit — the explanation from your own certifying body is authoritative, not this article.