What are your legal duties when buying refrigerant?
Two separate questions, often confused
Buyers usually arrive with one question — “do I need a licence?” — when there are really two, answering to two different regulators.
The first is what you are buying. That is ozone-layer law: the Ozone Depleting Substances (Regulation and Control) Rules, 2000, administered through the Ozone Cell under the environment ministry. It applies to R-22 and other HCFCs. It does not apply to R-32, R-410A, R-134a, R-404A or R-407C, which are HFCs and contain no chlorine.
The second is how much of it you keep on site. That is pressure-vessel law: the Gas Cylinders Rules, 2016, administered by PESO. It applies to every compressed gas in a cylinder, whichever gas it happens to be, and it turns on quantity rather than chemistry.
You can be fully compliant on one and in breach of the other. A workshop holding four cylinders of R-410A has no PESO problem and no ODS problem. A cold-storage operator stockpiling R-22 for a season may have both.
The purchase declaration for R-22
Rule 7 of the ODS Rules restricts who may purchase an ozone-depleting substance. In substance: a person may not purchase a listed ODS for making stock, or for using it in the regulated activities the Rules schedule, unless they have given the seller the declaration set out in Part I of Schedule XII.
The obligation is mirrored on the other side. Rule 6 forbids a seller from supplying for a regulated activity unless the buyer is registered and has given that declaration, and unless the seller has verified the registration particulars against the certificate, following the procedure in Part II of the same Schedule. So the buyer files Part I; the seller checks it under Part II. Both halves have to happen.
What this does not mean is that an ordinary technician buying a cylinder to service a customer's existing air conditioner needs a personal licence. The declaration requirement attaches to purchasing for stock and to the regulated end-use activities, not to routine over-the-counter servicing supply. If you are unsure which side of that line your purchasing sits on, the safe move is to ask your seller to show you how they classify it — a registered seller will have had to think about it.
What it does mean, for every buyer without exception: buy R-22 only from a registered seller. An unregistered seller cannot lawfully supply it, which makes the transaction a problem for you as well as for them, and it is the single easiest thing to check. Here is the four-step check, and you are welcome to run it on us.
One point of framing worth being blunt about: R-22 is supplied for servicing equipment that already exists. Manufacturing new equipment with it has been prohibited in India since 1 January 2025. If a seller is happy to supply R-22 for a new build, that tells you something about the rest of their compliance.
Storage thresholds, and when a licence bites
The Gas Cylinders Rules, 2016 exempt possession from licensing up to defined limits, provided the cylinders are for your own use and not for sale or trading. Rule 44 sets them out by gas character:
| Gas character | Exempt up to | Above that |
|---|---|---|
| Non-flammable, non-toxic | 200 cylinders | A storage licence in Form F is obligatory, applied for in Form C |
| Flammable, non-toxic | 25 cylinders or 200 kg of gas, whichever is less | |
| Toxic | 5 cylinders |
R-22, R-134a, R-410A, R-407C and R-404A are non-flammable and non-toxic, so the 200-cylinder figure is the one that applies. That is a high bar — most contractors and plant rooms never approach it, which is why most buyers need no PESO licence at all.
R-32 is the case to check. It is classified A2L, mildly flammable, and the flammable limit is far lower — 25 cylinders or 200 kg. Whether PESO treats an A2L refrigerant under the flammable head for Rule 44 purposes is a determination we would not want you to take from a supplier's website, ours included. If you hold R-32 in any quantity approaching that threshold, confirm the classification directly with PESO before relying on an exemption.
Applications go to PESO in Form C, with the storage licence issued in Form F, through the PESO portal and the National Single Window System. Note also that the Gas Cylinders (Amendment) Rules, 2025 brought in QR-coded tare-weight plates and a revised testing cycle for composite cylinders from 11 April 2025, alongside PESO's move to electronic licensing. The full licence map is here.
What to demand from any supplier
Whatever the quantity, the documentation you collect at purchase is what an auditor, an insurer or an investigating officer will ask for later. This is the checklist worth running on a new supplier before the first order, not after a problem.
| Document | What to ask for | How to check it |
|---|---|---|
| ODS seller registration (for R-22) | The registration number and its validity | Against the Ozone Cell, MoEFCC |
| GST registration | The GSTIN certificate | GST portal search |
| Udyam / MSME | Udyam registration number | Udyam portal |
| Cylinder test certificate | Test date and next test due | Cylinder stamping; PESO records |
| Safety Data Sheet | Product-specific, current | Cross-check composition and safety class |
| Batch traceability | Batch number tied to your invoice | Match delivery note to cylinder |
Our own particulars, so you can practise on us: ODS seller registration ODS/CS/17/6(12)/2024-OC dated 12.11.2024, GSTIN 36ABVPS4078C1Z5, Udyam UDYAM-TS-02-0015806.
Why the paperwork earns its keep
Three reasons, in rising order of how much they cost when ignored.
Audit. ISO 14001 and 45001 surveillance, GMP inspection and customer vendor audits all ask where a controlled substance came from. “A man in the market” is not an answer that survives.
Carbon accounting. Your purchase records are the raw data for the fugitive-emission line in your greenhouse-gas inventory. Refrigerant leaks are Scope 1, and the quantity you bought to recharge a system is the best evidence of the quantity that escaped it.
Product risk. Counterfeit refrigerant is a real and documented problem, and the failure mode is not a warranty claim — it is contaminated gas destroying a compressor, or worse. Documentation is how you avoid it. Telling genuine from counterfeit covers the physical checks that go with the paper ones.
Quick answers
Do I need a licence to buy R-22 in India?
Not as an ordinary buyer purchasing gas to service existing equipment. But if you are purchasing R-22 to hold as stock or for a regulated end-use activity, the ODS Rules require you to give the seller a declaration under Schedule XII, Part I. In every case, buy only from an Ozone Cell-registered seller.
How many refrigerant cylinders can I store without a PESO licence?
For non-flammable, non-toxic gases such as R-22, R-134a, R-410A, R-407C and R-404A, up to 200 cylinders for your own use. Flammable gases are limited to 25 cylinders or 200 kg, whichever is less. Above the applicable limit a Form F storage licence is required.
Do HFCs like R-410A need a purchase declaration?
No. The ODS purchase declaration applies to ozone-depleting substances such as R-22. HFCs contain no chlorine and fall outside it — though PESO storage rules still apply to the cylinders themselves.
- Ozone Depleting Substances (Regulation and Control) Rules, 2000 — Rules 6 and 7, Schedule XII Parts I and II — Ozone Cell, MoEFCC, ozonecell.nic.in.
- Gas Cylinders Rules, 2016 (G.S.R. 1058(E)) — Rule 44 exemption limits, Form C application and Form F storage licence; and the Gas Cylinders (Amendment) Rules, 2025 — PESO, peso.gov.in.
- Environment (Protection) Act, 1986 — the parent statute under which the ODS Rules are framed — moef.gov.in.
This guide is general information compiled from the cited sources — not legal, safety or engineering advice. Read our full disclaimer.
Related: Verify a licensed seller · PESO licence map · The seller's side · Supplier documentation