Regulations and compliance9 min de lectura-

How to tell whether a refrigeration installation is level 1 or level 2

Level 1 or level 2 is not just about size: the electrical power of each system, the total, the refrigerant and any artificial atmosphere all count. Here is how to classify step by step, with examples.

Ingeniería Isofred

Departamento Técnico - Isofred

How to tell whether a refrigeration installation is level 1 or level 2

Spain's Safety Regulation for Refrigeration Installations (RSIF, Royal Decree 552/2019) classifies installations as level 1 or level 2. That classification decides who may install and maintain them, what documentation they need and what must be in place before they are put into service.

Article 8 of Royal Decree 552/2019 sets the criteria, and the underlying rule is simple: an installation is level 2 as soon as it fails to meet all the level 1 conditions. The hard part is applying it correctly: identifying the systems, using the right power figure and not forgetting the refrigerant or artificial atmospheres.

Quick answer

An installation is generally level 1 when no system exceeds 30 kW of electrical power installed in compressors, the total of all systems does not exceed 100 kW, it uses L1 refrigerants and it does not cool artificial-atmosphere rooms. If it exceeds any of those limits, uses L2 or L3 refrigerants or serves an artificial-atmosphere room, it is level 2.

30 kW

Maximum per system for level 1 (electrical power)

100 kW

Maximum total of all systems for level 1

L1

The only refrigerant group allowed in level 1

Why does the level matter?

It is not just an administrative label. The level decides whether a technical report or a full design project is needed, which refrigeration company may do the work, whether site supervision is required, which certificates are issued, what maintenance contract the owner needs, whether civil liability insurance is mandatory, which inspections apply and what an expansion requires. Misclassification usually ends in an incomplete file and repeated paperwork before commissioning.

Step 1: identify the refrigeration systems

Before adding up power, you need to know how many systems there are. A refrigeration system is the set of interconnected components containing refrigerant that form a closed circuit: compressors, condenser or gas cooler, receivers, valves, evaporators, piping, controls and safety devices. Two plants in the same building can be separate systems if their circuits are independent and do not share refrigerant. They can share a panel, structure, monitoring, power supply or a secondary circuit and still be independent.

One common header, one system

Several compressors connected to the same header form a single system and their power is added together. They cannot be treated as separate systems to split the power on paper. Independence is decided from the refrigeration diagram, not from location or the number of panels.

Step 2: use the right power figure

This is the most common mistake: confusing cooling capacity, thermal power and the electrical power installed in the compressors. Article 8 uses the last one. A plant can deliver 120 kW of cooling and have 28 kW of electrical power installed in its compressors: for the level, the second figure counts.

You will find it on compressor nameplates, in the design project or technical report, the electrical diagram, certificates, manufacturer documentation or the logbook. With variable-speed drives or multi-stage compressors, use installed design power, not consumption from a one-off measurement. Then run two checks: the sum of the compressors in each system (three 12 kW compressors on the same circuit make 36 kW, even though none exceeds 30) and the sum of all systems in the installation.

Level 1 and level 2 criteria

Electrical power installed in compressors. Special provisions apply to packaged units and A2L refrigerants.
CriterionLevel 1 (all at once)Level 2 (any one)
Power of each systemUp to 30 kWAny system above 30 kW
Total of all systemsUp to 100 kWAbove 100 kW
Refrigerant groupL1L2 or L3
Artificial atmosphereNo artificial-atmosphere rooms cooledAt least one cooled

The practical consequence: level 2 does not mean large. A small unit with an L2 or L3 refrigerant, or a controlled atmosphere room of a few kilowatts, is level 2. And an installation made up of several small units can be level 2 because of the total.

Classification examples

This is how the criteria apply in common cases (provided the systems described as independent really are):

Indicative general classification: the final one is made on the real installation.
CaseElectrical powerRefrigerantLevelWhy
Small cold room1 system of 12 kWR134a (L1)1Meets every condition
Three independent systems24 + 28 + 18 = 70 kWL11None exceeds 30 kW and the total is under 100
Plant with three compressors3 × 12 kW on one circuit = 36 kWL12The system exceeds 30 kW
Two systems35 + 20 = 55 kWL12One system exceeds 30 kW, even with a low total
Four systems28 + 27 + 26 + 24 = 105 kWL12The total exceeds 100 kW
Propane cold room8 kWR290 (L3)2Because of the refrigerant, unless a specific provision applies
Ammonia installation20 kWR717 (L2)2Because of the refrigerant
Controlled atmosphere room10 kWL12Because of the artificial atmosphere
Two CO₂ systems25 + 25 = 50 kWR744 (L1)1Meets the criteria, with high-pressure requirements of its own

Step 3: the refrigerant group

The RSIF classifies refrigerants by toxicity (A, lower; B, higher) and flammability (1, no flame propagation; 2L, low and slow-burning; 2, flammable; 3, highly flammable), and groups them into L1 (high safety: A1), L2 (medium safety: A2L, A2, B1, B2L and B2) and L3 (low safety: A3 and B3). The exact class must be checked in the refrigerant's documentation and the current RSIF tables, never from its trade name:

Common examples. Classifications can be updated: check them before designing or converting an installation.
RefrigerantClassRSIF group
CO₂ (R744), R134a, R410A, R448A, R449AA1L1
R32, R454B, R1234yf, R1234zeA2LL2
Ammonia (R717)B2LL2
Propane (R290), isobutane (R600a)A3L3

Artificial atmosphere: always level 2

Installations that cool rooms or groups of rooms with an artificial atmosphere (controlled atmosphere rooms, ULO rooms, reduced-oxygen storage or nitrogen enclosures) are level 2 regardless of room volume or compressor power. The reason is that, beyond the refrigeration risk, the atmosphere itself is dangerous to people. A small room with a low-power unit is level 2 if it holds reduced oxygen.

The case of A2L refrigerants

A2L refrigerants (R32, R454A, R454B, R455A, R1234yf, R1234ze…) have low flammability and slow burning velocity and are used as lower-GWP alternatives. Being L2, they generally lead to level 2. But Royal Decree 552/2019 provides a special regime for some A2L installations that meet power, charge and use limits: they may be installed by a level 1 refrigeration company, documented with a technical report and exempted from certain general level 2 requirements.

They do not become level 1

It is a special regime for installations that remain level 2. To apply it, check power per system and in total, charge and maximum allowable charge, room category, occupant access, ventilation, detection, protective measures and instructions IF-04 and IF-20. A data sheet saying “mildly flammable” is not enough.

Packaged units and indirect systems

Packaged units

Article 8 allows packaged units of any capacity to be included in level 1 if they use an L1 refrigerant and do not cool an artificial atmosphere. A packaged unit is factory-built and assembled with an integrated circuit, not a plant assembled on site or several units linked by a pipe network. Check that the manufacturer declares it as such, that it has not been modified and that its documentation is in order.

Indirect systems

In an indirect system the refrigerant cools water or glycol, which carries the cooling to the loads. Some configurations with packaged units on the primary side have their own provisions, but a glycol installation is not level 1 by default: the secondary fluid does not replace the refrigerant when classifying the primary circuit.

What changes in the documentation?

Exact documentation also depends on the refrigerant, charge, pressure equipment and region.
RequirementLevel 1Level 2
Technical documentTechnical reportDesign project (including TEWI calculation)
Signed byRefrigeration installer or competent engineerQualified competent engineer
Site supervisionGenerally notYes, with final certificate
Installing companyLevel 1 or higherLevel 2
Maintenance contractDepending on conditionsGenerally mandatory
Periodic inspectionDepending on characteristicsGenerally every 10 years
Civil liability insuranceDepending on refrigerant and activityMandatory with L2 or L3 (minimum €500,000), with exemptions for some A2L

In both cases the document must describe the installation as actually built: if equipment or routing changes during installation, the final documentation is updated. The full list of documents needed for registration is in our RSIF, Royal Decree 552/2019 guide.

Who can install and maintain it?

Refrigeration companies are also level 1 or level 2. A level 1 company works on level 1 installations within its authorisation; a level 2 company can work on both and must prove the resources, staff and liability cover required. So a level 1 company cannot take on just any small installation: if it uses an L2 or L3 refrigerant, it may be level 2 despite its low power.

The owner of a level 2 installation must generally contract maintenance with a level 2 company, unless it is an authorised self-maintaining company. And the periodic check carried out by the refrigeration company should not be confused with an inspection by an accredited body: for level 2, as a general rule, every ten years, with shorter intervals depending on the CO₂-equivalent tonnes of fluorinated gases.

Expansions, refrigerant changes and older installations

An installation can change level as it grows. With three 25 kW systems (75 kW in total), adding a fourth of 28 kW brings the total to 103 kW: even though the new system is under 30 kW, the whole installation may become level 2. Before expanding, check the registered and actually installed power, refrigerants, the final total, the authorised company, the required technical document, site supervision, maintenance and pending inspections.

Classify first, order second

Do not order new equipment before recalculating the level. Treat a refrigerant change the same way: switching from an A1 to an A2L or A3 can take the installation to level 2 and change the maximum charge, ventilation, detection, electrical equipment, documentation and the owner's obligations.

In older or heavily modified installations, the level is not always clear from the paperwork. You need to inventory the equipment, identify circuits, read compressor nameplates, add up per system and in total, identify refrigerants and charges, check for artificial atmospheres and compare everything with the registered file. If the real installation does not match the documentation, regularisation has to be studied.

Real level 2 examples

In most of the industrial installations we carry out at Isofred, level 2 comes from more than one criterion at once:

Controlled atmosphere: Piñana / Conjuntfruit

32 controlled atmosphere rooms in Torrefarrera. They would be level 2 because of the artificial atmosphere alone, even if each unit were small.

Ammonia: PAC Aitona

A 1,550 kW NH₃ (L2) plant for fruit storage. Level 2 because of both the refrigerant and the power.

Several refrigerants: Copima

Ammonia with glycol for chilled storage, CO₂ for freezing and R-290 for meat ageing. Each circuit is analysed separately, and the site as a whole is classified as level 2.

See these and other cases in our projects.

Which mistakes come up most often?

  • Using cooling capacity instead of electrical power installed in compressors.
  • Checking each compressor separately without adding up those in the same system, or not calculating the overall total.
  • Treating connected circuits as independent.
  • Classifying by power alone, without checking the refrigerant group.
  • Assuming a small installation is always level 1, or forgetting artificial-atmosphere rooms.
  • Applying the A2L special regime automatically, or treating any unit as packaged.
  • Not recalculating the level after an expansion or a refrigerant change.
  • Hiring a company without the required level, or confusing installation level with company level.

Not sure whether your installation is level 1 or level 2?

We review your equipment and documentation, classify the installation and tell you what is missing to be fully compliant.

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Frequently asked questions

Is an installation under 30 kW always level 1? No. It is level 2 if it uses an L2 or L3 refrigerant or cools an artificial-atmosphere room.

Which power figure is used for classification? The electrical power installed in the compressors, not the system's cooling capacity.

Is an ammonia or propane installation level 2? Generally yes: R717 is L2 and R290 is L3, unless a specific provision applies to the configuration.

Can a level 1 company install an A2L system? Some installations that are level 2 only because they use A2L can benefit from special conditions that allow it, provided they meet all regulatory limits.

Can an expansion change the level? Yes. If it takes a system above 30 kW or the total above 100 kW, the installation moves from level 1 to level 2.

Does level 2 mean the installation is dangerous? No. It means that, because of its power, refrigerant or application, it has more technical, documentation and control requirements.

Technical note: this article summarises the general criteria of Royal Decree 552/2019. The final classification is made on the real installation, taking into account all special provisions, complementary technical instructions and regional criteria.

#RSIF#Regulations#Level 1 and level 2#Compliance
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