Permits for a refrigeration and air-conditioning equipment business: the high-pressure gas sales notification and Class-1 fluorocarbon charging-and-recovery operator registration

In short: a business handling commercial refrigeration and air-conditioning equipment faces separate permits for each thing it does. To sell high-pressure gas such as refrigerant, a sales notification under Article 20-4 of the High Pressure Gas Safety Act is required (for each sales office, to the prefectural governor, by 20 days before the day business begins). To charge and recover the refrigerant fluorocarbons of commercial air conditioners and commercial refrigeration/freezing equipment, a Class-1 fluorocarbon charging-and-recovery operator registration under Article 27, paragraph 1 of the "Act on Rational Use and Appropriate Management of Fluorocarbons" (Fluorocarbons Emission Control Act) is required (with the prefectural governor having jurisdiction over the area, valid for 5 years = Article 30). Installing the refrigeration equipment itself (the "manufacture" of high-pressure gas) splits into a permit or a notification under Article 5 of the High Pressure Gas Safety Act depending on refrigeration capacity, and the Refrigeration Safety Rules apply. Yotsuba Administrative Scrivener Office takes on the preparation and filing of documents submitted to public offices within the scope of Article 1-2 of the Administrative Scrivener Act under a separate contract, going only as far as providing materials and information. Equipment installation and safety supervision are for qualified contractors and safety supervisors, the property for a separate real estate business, registration for a judicial scrivener, and tax for a tax accountant — each contracted separately as an independent business. This article is general information and does not make the specific legal judgment of whether an individual registration or notification will be granted. Our office receives no referral fee.

When you handle commercial refrigeration and air-conditioning equipment, what permits do you first need?

A refrigeration and air-conditioning business changes the required procedure by "what you do." Several procedures often overlap in one business, so first separate them by act.

Act performed	Main basis	Nature of procedure
Selling high-pressure gas such as refrigerant	Article 20-4, High Pressure Gas Safety Act	Sales business notification (prefectural governor)
Charging/recovering the refrigerant fluorocarbons of commercial air conditioners and refrigeration/freezing equipment	Article 27, paragraph 1, Fluorocarbons Emission Control Act	Class-1 fluorocarbon charging-and-recovery operator registration (prefectural governor)
"Manufacturing" high-pressure gas with refrigeration equipment (where refrigeration capacity is above a level)	Article 5, High Pressure Gas Safety Act	A permit (Class-1 manufacturer) or a notification (Class-2 manufacturer), depending on refrigeration capacity

"Sale," "charging/recovery," and "manufacture (refrigeration)" are different systems, and if you fall under each, the procedure is required for each. For example, if you open your own cold-storage warehouse and go as far as topping up refrigerant and replacing equipment, sale, charging/recovery, and the installation of refrigeration equipment may each be asked of you separately. Which act you fall under changes with the shape of the business, so once the equipment and the transactions are fixed, organise them while inquiring with the prefecture's high-pressure-gas and fluorocarbon division. As a related registration system, the recovery of fluorocarbons on the automotive side (car air conditioners = Class-2 specified products) is handled separately in Collection-operator and fluorocarbon-recovery-operator registration.

Where and when is the sales notification under the High Pressure Gas Safety Act filed?

A person who intends to carry on a business of selling high-pressure gas must, for each sales office, notify the prefectural governor by 20 days before the day business begins, attaching a document stating the types of high-pressure gas to be sold (Article 20-4, High Pressure Gas Safety Act). The person who files is called a "seller."

Item	Organisation under the article
Filing destination	Prefectural governor (for each sales office)
Timing	By 20 days before the day business begins (Article 20-4)
Succession	On transfer of the whole business, inheritance, merger or split, notify without delay (Article 20-4-2)
Abolition	On abolishing the business, notify without delay (Article 21)

There are exceptions, however. In cases prescribed by Cabinet Order — such as where a Class-1 manufacturer sells, at its own establishment, high-pressure gas it has itself manufactured — no notification is required. Also, selling liquefied petroleum gas (LP gas) to general consumers is subject to the sales-business registration under the LP Gas Act, not the High Pressure Gas Safety Act, and the systems diverge. In a city's area the mayor or the fire chief may be the receiving window, and the destination, forms and attached documents differ by municipality, so once the location of the sales office is fixed, confirm with the prefecture (or the city's fire and safety division) having jurisdiction (guidance of METI and each prefecture; accessed 2026-11-03).

What are the requirements and the term of validity of the Class-1 fluorocarbon charging-and-recovery operator registration?

A person who intends to carry on, as a business, the charging and recovery of fluorocarbons charged as refrigerant in commercial air conditioners and commercial refrigeration/freezing equipment (including vending machines with a refrigeration/freezing function; these are called Class-1 specified products = Article 2, paragraph 3, Fluorocarbons Emission Control Act) must obtain the registration of the prefectural governor having jurisdiction over the area in which the business is to be carried on (Article 27, paragraph 1). Household air conditioners are not included in Class-1 specified products, and the recovery of fluorocarbons from car air conditioners (Class-2 specified products = Article 2, paragraph 4) is a separate system under the framework of the Automobile Recycling Act.

Item	Organisation under the article
Registration destination	Prefectural governor having jurisdiction over the area (Article 27, paragraph 1)
Entries in the application	Name, address, equipment used for the business, etc. (Article 27, paragraph 2)
Refusal of registration	Grounds for disqualification, or where recovery equipment does not meet the standards, etc. (Article 29)
Term of validity	5 years; loses effect unless renewed (Article 30, paragraphs 1 and 2)
Notification of change	On a change to a registered matter, notify within 30 days (Article 31)

The register is made available for public inspection (Article 32). The technical standards for recovery equipment, the specifics of the grounds for disqualification, the renewal acceptance period (from 2–3 months before expiry, etc., depending on the municipality) and the fees diverge in operation by prefecture and are also amended, so confirm them against the prefecture's latest guidance immediately before applying. If you carry on business in several prefectures, confirm with the windows whether registration is needed per area. The final application of which requirement you fall under is judged after review by the prefecture that performs the registration.

In what order do the permits line up when opening a cold-storage warehouse?

When you set up a cold-storage warehouse and carry on low-temperature logistics, equipment, safety, registration, labor and the property move in parallel. A rough order is as follows, and responsibility is divided by field.

• Selecting the property and confirming suitability (zoning, floor load, electrical capacity, etc.) → Yotsuba Real Estate Co., Ltd., a separate business (real estate broker), handles this as an independent business under a separate contract
• Designing and installing the refrigeration equipment, and the Article-5 permit (Class-1 manufacturer) or notification (Class-2 manufacturer) under the High Pressure Gas Safety Act according to refrigeration capacity → a qualified equipment/electrical contractor and a chief high-pressure-gas production safety supervisor. The administrative scrivener supports the preparation of documents
• The Class-1 fluorocarbon charging-and-recovery operator registration (Article 27, paragraph 1) if refrigerant fluorocarbons are handled
• The sales notification (Article 20-4) if high-pressure gas such as refrigerant is sold
• The Warehousing Business Act registration if operated as a warehousing business (meeting the facility/equipment standards; property requirements confirmed on the real estate side)
• Work rules, low-temperature-work occupational safety and health, and shifts for employees → a labor and social security attorney (a separate business)

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The Warehousing Business Act registration and the business permits for the food or pharmaceuticals stored are under separate jurisdictions, each contracted separately as an independent business. The property suitability of a low-temperature logistics facility is organised in Property requirements for a cold-storage warehouse (a column on the real estate side, a separate business), and the labor of low-temperature work on the labor and social security attorney side. Because the order changes with the scale of the equipment and the form of the business, decide the order of starting after drawing the whole picture.

How do the documents an administrative scrivener can prepare, and the parts to ask a qualified person for installation and safety, divide?

An administrative scrivener takes on the preparation of documents submitted to public offices and the agency for filing procedures as an exclusive business (Article 1-2, Administrative Scrivener Act). The installation of equipment and the supervision of safety, on the other hand, are the domain of other qualified persons. Responsibility divides as follows, each contracted separately as an independent business.

• The sales notification, the Class-1 fluorocarbon charging-and-recovery operator registration application, and the preparation and agency for filing of the permit/notification documents for refrigeration equipment → Yotsuba Administrative Scrivener Office (administrative scrivener). We go only as far as providing materials and information, and do not make specific legal judgments
• The installation of refrigeration equipment, piping and electrical equipment → a chief high-pressure-gas production safety supervisor, an electrician, and, depending on scale, a contractor with a construction-business licence
• Supervision of the manufacture and safety of high-pressure gas → a qualified person such as a chief high-pressure-gas production safety supervisor
• Selecting the property/warehouse site and the agency for the lease → Yotsuba Real Estate Co., Ltd., a separate business (real estate broker)
• The incorporation registration if operating by forming a company → a judicial scrivener
• Bookkeeping and tax filing after opening → a tax accountant
• Labor matters such as work rules, occupational safety and health, and shifts → a labor and social security attorney
• The agency and legal judgment of a dispute over a transaction or contract → a lawyer

Each field is on the premise that you contract separately with each window and qualified person, and our office receives no referral fee. Even while you are still unsure whether a registration or notification is needed or which window applies, please consult us before deciding the equipment and the transactions. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; for the work handled, see Services. As related permits, please also see Poisonous and Deleterious Substances sales-business registration and Electrical construction business registration.

FAQ

Q. Do I need high-pressure-gas procedures even just to sell refrigerant?
A. If you sell high-pressure gas such as refrigerant as a business, a sales notification to the prefectural governor is required for each sales office by 20 days before the day business begins (Article 20-4, High Pressure Gas Safety Act). However, in cases prescribed by Cabinet Order — such as a Class-1 manufacturer selling, at its establishment, gas it has itself manufactured — no notification is required. Because selling LP gas to general consumers requires a separate registration under the LP Gas Act and the systems diverge, confirm the gas handled and the form of sale with the prefecture having jurisdiction.

Q. Where is the Class-1 fluorocarbon charging-and-recovery operator registration filed, and for how many years is it valid?
A. You obtain registration from the prefectural governor having jurisdiction over the area in which you intend to carry on business (Article 27, paragraph 1, Fluorocarbons Emission Control Act). The term of validity is 5 years, and it loses effect unless renewed (Article 30). If a registered matter changes, notification within 30 days is required (Article 31). Because the standards for recovery equipment and the renewal acceptance period and fees diverge in operation by prefecture, confirm them against the prefecture's latest guidance immediately before applying.

Q. Are commercial air conditioners, household air conditioners and car air conditioners treated differently?
A. Yes. Commercial air conditioners and commercial refrigeration/freezing equipment are Class-1 specified products (Article 2, paragraph 3, Fluorocarbons Emission Control Act), and their charging/recovery is subject to the Class-1 fluorocarbon charging-and-recovery operator registration. Household air conditioners are not included in Class-1 specified products. Car air conditioners are Class-2 specified products (Article 2, paragraph 4), and the recovery of fluorocarbons is a separate system under the framework of the Automobile Recycling Act.

Q. Can I ask one office to handle everything from the equipment installation to the paperwork?
A. The preparation and agency for filing of documents is for an administrative scrivener; the installation of refrigeration and electrical equipment for a qualified contractor; the supervision of high-pressure-gas safety for a chief high-pressure-gas production safety supervisor; the property for Yotsuba Real Estate Co., Ltd., a separate business; registration for a judicial scrivener; tax for a tax accountant; and labor for a labor and social security attorney — each contracted separately as an independent business. We can receive your consultation at one window and organise and pass materials to each, but the engagements are separate. Our office receives no referral fee.

Sources (Primary Information)

• e-Gov Law Search, "High Pressure Gas Safety Act" (Act No. 204 of 1951), Article 5 (permit/notification of manufacture = Class-1 manufacturer / Class-2 manufacturer), Article 20-4 (sales business notification = to the prefectural governor by 20 days before the day business begins, for each sales office), Article 20-4-2 (notification of succession), Article 21 (notification of abolition, etc.) (accessed 2026-11-03)
• e-Gov Law Search, "Act on Rational Use and Appropriate Management of Fluorocarbons" (Act No. 64 of 2001 = Fluorocarbons Emission Control Act), Article 2, paragraph 3 (Class-1 specified products), Article 2, paragraph 4 (Class-2 specified products), Article 27, paragraph 1 (Class-1 fluorocarbon charging-and-recovery operator registration = prefectural governor), Article 27, paragraph 2 (entries in the application), Article 29 (refusal of registration), Article 30, paragraphs 1 and 2 (5-year term / renewal), Article 31 (notification of change = within 30 days), Article 32 (inspection of the register) (accessed 2026-11-03)
• e-Gov Law Search, "Refrigeration Safety Rules" (a METI ordinance under the High Pressure Gas Safety Act; the classification of permit/notification for refrigeration equipment and the technical standards) (accessed 2026-11-03)
• e-Gov Law Search, "Administrative Scrivener Act," Article 1-2 (the preparation of documents submitted to public offices = exclusive business) (accessed 2026-11-03)
• Guidance of METI, the Ministry of the Environment and each prefecture (the window and forms for the high-pressure-gas sales notification; the procedures for registration, renewal and reporting of a Class-1 fluorocarbon charging-and-recovery operator; registration fees — operation differs by municipality and by amendment) (accessed 2026-11-03)

This article is general information and does not guarantee or judge whether an individual registration or notification will be granted, the application of grounds for refusal, conformity of recovery or refrigeration equipment to the standards, or the classification of refrigeration capacity. Because the requirements, forms and fees, and the classification of refrigeration capacity set in the Refrigeration Safety Rules (permit or notification, whether it applies), are amended, always confirm them against the latest articles and the guidance of the prefecture (high-pressure-gas and fluorocarbon division), METI and the Ministry of the Environment. The installation of refrigeration and electrical equipment is handled by a chief high-pressure-gas production safety supervisor, an electrician and a contractor with a construction-business licence; the supervision of high-pressure-gas safety by a chief high-pressure-gas production safety supervisor; the selection and agency for the property/warehouse site by Yotsuba Real Estate Co., Ltd., a separate business (real estate broker); incorporation registration by a judicial scrivener; tax by a tax accountant; labor by a labor and social security attorney; and a transaction or contract dispute by a lawyer — each contracted separately as an independent business. Our office receives no referral fee. A specific legal judgment is made, after an interview, by a qualified person such as an administrative scrivener. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.