Handling fluorinated greenhouse gases in Estonia: the handling permit

A company that installs, services, repairs, leak-checks or decommissions refrigeration, air-conditioning, heat pump or fire protection equipment containing fluorinated greenhouse gases (F-gases) needs a handling permit (käitlemisluba) from the Environmental Board (Keskkonnaamet)³¹⁷ before it starts⁴¹. The permit is granted on two grounds: enough certified technicians for the expected volume of work, and the right tools and procedures²⁸²⁹. The technicians themselves must hold an EU-standard certificate or an Estonian professional certificate³⁰.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

F-gases are the substances listed in Annexes I–III of Regulation (EU) 2024/573 on fluorinated greenhouse gases, alone or in a mixture¹. Handling means every operation with F-gases that this regulation and its implementing acts regulate².

The permit is needed when one of these types of equipment is handled³:

• stationary refrigeration equipment;
• stationary air-conditioning equipment and heat pumps;
• stationary organic Rankine cycle equipment;
• refrigeration units of refrigerated trucks and trailers;
• refrigeration units of refrigerated light-duty vehicles, containers (including reefer containers) and train wagons — this point applies from 10 October 2026⁴;
• stationary fire protection equipment.

Covered operations for the cooling equipment are installation, repair, maintenance and servicing and decommissioning where the equipment contains F-gases of Annex I or Annex II Section 1 of the regulation, or ammonia (NH3), carbon dioxide (CO2) or hydrocarbons (HC); and leak checks and recovery of the gas where it contains those F-gases⁵. For fire protection equipment the same operations are covered, with three named alternative substances instead of NH3, CO2 and HC⁶. The Environmental Board notes that adding work with HC, CO2 or NH3 to an existing permit is not automatic: the company must file additional data on its tools and methods⁷.

Not covered by this permit: manufacturing at the equipment manufacturer's own site⁸, and mobile air-conditioning in cars, for which the regulation requires at least a training attestation of the natural person⁹. Electrical switchgear and solvent recovery have their own personal certification rules¹⁰ but are not among the permit's equipment types³.

The legal act and the authority

• Atmospheric Air Protection Act (atmosfääriõhu kaitse seadus, AÕKS), §§ 189–206, redaction in force from 1 October 2026¹¹.
• Regulation (EU) 2024/573 of the European Parliament and of the Council on fluorinated greenhouse gases, which repealed Regulation (EU) No 517/2014¹². Its Article 10 requires legal persons to be certified for installation, maintenance or servicing, repair or decommissioning of the listed equipment¹³.
• Commission Implementing Regulation (EU) 2024/2215 (refrigeration, air conditioning, heat pumps, ORC and transport refrigeration) and (EU) 2025/625 (stationary fire protection) set the minimum certification requirements for persons and companies¹⁴.
• General Part of the Economic Activities Code Act (majandustegevuse seadustiku üldosa seadus, MSÜS): an activity licence is an administrative act of any name without which the business may not start¹⁵; the handling permit application builds on its § 19(2)¹⁶.

The permit is issued by the Environmental Board (Keskkonnaamet)¹⁷, which also supervises compliance with the handling requirements; the Estonian Tax and Customs Board supervises imports, exports and labelling¹⁸. According to the Board's permit guidance, the application is filed electronically through the Register of Economic Activities (majandustegevuse register, MTR)¹⁹. The list of permit holders and the fields and operations each permit covers is public on the MTR website²⁰.

The FOKA register is also the state database of equipment containing F-gases and ozone-depleting substances and of the handling operations performed on them²¹. A certified technician must enter each handling operation on registrable equipment in it within five working days²².

Who must apply

The permit is compulsory for sole proprietors (FIE) and legal persons who handle the equipment listed above³. Under the EU rules, the company certificate applies to legal persons carrying out installation, repair, maintenance, servicing or decommissioning for third parties²³. An undertaking may assign such work only to another undertaking that holds the necessary certificates²⁴, and suppliers may sell F-gases for installation, servicing or repair only to undertakings with certified staff²⁵.

Exemptions named in the acts:

• manufacturing at the manufacturer's site⁸;
• persons enrolled in a certification course who work under the supervision of a certificate holder, for no more than 24 months in total (this concerns the individual's certificate)²⁶;
• a certificate issued in another EU Member State under the same EU implementing regulations proves the right to work in Estonia; the Board may require a sworn translation into Estonian²⁷.

Requirements for the applicant

The permit's control object is set by AÕKS § 198(1): the permit is given to a legal person that meets Article 6(1) of Implementing Regulation 2024/2215 and Article 5(1) of Implementing Regulation 2025/625²⁸. These require²⁹:

• Certified staff: employment of natural persons certified under the regulation, in a sufficient number to cover the expected volume of activities;
• Tools and procedures: proof that the necessary tools and procedures are available to those persons.

Each technician must hold a certificate under the relevant implementing regulation or an Estonian professional or partial professional certificate (kutse- või osakutsetunnistus)³⁰, know the Estonian legal acts of the profession³¹, and complete refresher training or re-certification at the interval set in the awarding rules³².

Whether further requirements, such as share capital, a fit-and-proper test of the management board or an anti-money-laundering programme, apply is specified for the client's situation.

Documents filed with the application

The application contains, in addition to the general data of MSÜS § 19(2)¹⁶:

General data of the company — name and registry code, contact details (telephone, e-mail, postal address), the name of the field of activity and its classification code, and the name and contact details of the signatory with the basis of representation³³.

Activity data (AÕKS § 199(1))³⁴:

• the handling operations for which the permit is sought;
• general data of the certified employees the applicant engages, with the data of their certificate or professional certificate (including one issued in another EU Member State);
• workload data showing that the applicant has enough certified employees for the described volume of work;
• a list of the tools at the applicant's disposal;
• descriptions of the work methods;
• the date of the application.

Several types of handling operations in one field are entered in one application³⁵. The permit may carry secondary conditions set in the granting decision, which the holder must follow³⁶.

State fee and processing time

• State fee for reviewing an application: EUR 270; for an application to amend the permit: EUR 48 (State Fees Act, riigilõivuseadus, § 136)³⁷.
• The Environmental Board decides to grant or refuse the permit within two months of receiving a compliant application with all documents and any additional data requested under the act³⁸. If the application is not reviewed in time, the permit is not deemed granted³⁹.

The authority may ask for additional data needed to check the requirements and set a deadline for it⁴⁰. The two-month limit is the law's time limit for the authority, not a promise of a date. The company may start the activity only once the permit is granted⁴¹.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ offers this under its general service "Activity licence application documentation" for licensed activities that have no page of their own on the site⁴²:

• the requirements of the act for the activity, taken from its official text;
• the application and the documents it needs;
• the submission and the written follow-up of the authority's questions. The service row names the Register of Economic Activities as the channel, which is also the channel the Environmental Board names for this permit¹⁹.

Price: from €3,500, one-time; no VAT is added. The state fee is separate and paid by the company⁴². Not included: legal, tax or audit advice, the state fee, meeting the capital, staff or premises requirements of the act, and any promise of the permit — the Environmental Board decides. The client describes the activity and provides what the act requires of the company, including its technicians' certificates.

Order: order form

Sources

1. AÕKS § 189(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
2. AÕKS § 191(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
3. AÕKS § 197(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
4. AÕKS § 197 in-force note — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
5. AÕKS § 197(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
6. AÕKS § 197(3) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
7. Keskkonnaamet, Fluoritud kasvuhoonegaasid — text in force from page as published (site checked 2026-11-11)
8. Implementing Regulation (EU) 2024/2215 Art. 2(3); (EU) 2025/625 Art. 1(3) — text in force from as published OJ L 2024/2215, 09.09.2024
9. Regulation (EU) 2024/573 Art. 4(7), third subparagraph — text in force from 11.03.2024 (Art. 38: 20th day after publication in OJ L 20.02.2024)
10. AÕKS § 194(2) p 2 and 4 (Implementing Regulations 2025/623, 2025/627) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
11. Riigi Teataja header — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
12. Regulation (EU) 2024/573 Art. 37(1) — text in force from 11.03.2024 (Art. 38: 20th day after publication in OJ L 20.02.2024)
13. Regulation (EU) 2024/573 Art. 10(2), Art. 4(7) second subparagraph — text in force from 11.03.2024 (Art. 38: 20th day after publication in OJ L 20.02.2024)
14. AÕKS § 194(2) p 1 and 5; Reg. 2024/2215 Art. 1 — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
15. MsÜS § 16(2) — text in force from 01.09.2025
16. AÕKS § 199(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
17. AÕKS § 201(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
18. AÕKS § 222 — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
19. Keskkonnaamet, Fluoritud kasvuhoonegaasid, section 'Käitlemisload' — text in force from page as published (site checked 2026-11-11)
20. AÕKS § 203 — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
21. AÕKS § 192(1), § 193(1); labelling § 205, reporting § 206 — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
22. AÕKS § 193(4) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
23. Implementing Regulation (EU) 2024/2215 Art. 2(2); 2025/625 Art. 1(2) — text in force from as published OJ L 2024/2215, 09.09.2024
24. Regulation (EU) 2024/573 Art. 10(12) — text in force from 11.03.2024 (Art. 38: 20th day after publication in OJ L 20.02.2024)
25. Regulation (EU) 2024/573 Art. 11(6) — text in force from 11.03.2024 (Art. 38: 20th day after publication in OJ L 20.02.2024)
26. Implementing Regulation (EU) 2024/2215 Art. 3(4); 2025/625 Art. 2(2) — text in force from as published OJ L 2024/2215, 09.09.2024
27. AÕKS § 196(1)-(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
28. AÕKS § 198(1) (and text of §§ 197–202) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
29. Implementing Regulation (EU) 2024/2215 Art. 6(1)(a)-(b); 2025/625 Art. 5(1) — text in force from as published OJ L 2024/2215, 09.09.2024
30. AÕKS § 194(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
31. AÕKS § 195(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
32. AÕKS § 195¹ — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
33. MsÜS § 19(2) p 1 with § 15(1) p 1–4, 7 — text in force from 01.09.2025
34. AÕKS § 199(1) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
35. AÕKS § 199(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
36. AÕKS § 200(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
37. Riigilõivuseadus § 136(1)-(2) — text in force from 01.11.2026 (RT I, 21.10.2026, 10)
38. AÕKS § 201(2) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
39. AÕKS § 201(3) — text in force from 01.10.2026 (RT I, 30.06.2026, 6)
40. MsÜS § 19(6) — text in force from 01.09.2025
41. MsÜS § 16(1), (4) — text in force from 01.09.2025
42. LexorCorp Global price list and service description (price list)

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

• State Fees Act — Riigi Teataja, English translation

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.