SF6 Switchgear 2026 – Exemption Review, Procurement Notice and Regulatory Notification | Word/PDF/Excel

Are you commissioning a medium-voltage substation with SF6 or another F-gas after the new EU ban comes into effect? For electrical substations in primary and secondary distribution up to and including 24 kV, a ban on commissioning applies from 1 January 2026 when they use, or depend on, fluorinated greenhouse gases as an insulating or switching medium – but Article 13 of Regulation (EU) 2024/573 contains several narrow exceptions. This document package helps the operator document the actual procurement, the correct exception ground, and the regulatory notification.

Practical target audience: electricity grid companies, industrial companies with their own medium-voltage substations, commercial property owners, technical project managers, energy projects, and procurement/regulatory compliance officers. It is aimed at the actual operator and their technical/legal support function, not at private individuals who want to install electrical switchgear themselves.

When do the SF6 and F-gas bans for substations come into effect?

Article 13.9 of EU Regulation 2024/573 has several separate dates and categories:

• 1 January 2026: medium-voltage substations for primary/secondary distribution, up to and including 24 kV, with F-gas as an insulating or switching medium.
• 1 January 2030: medium-voltage substations above 24 kV up to and including 52 kV, with F-gas.
• 1 January 2028: high-voltage substations above 52 kV up to and including 145 kV and at most 50 kA, with relevant F-gas and GWP 1 or higher.
• 1 January 2032: high-voltage substations above 145 kV or above 50 kA with relevant F-gas and GWP 1 or higher.

It concerns the commissioning of such substations – not a general requirement that all older, already operated substations must be scrapped immediately. Privately owned industrial electricity grids may also be covered. The Swedish Environmental Protection Agency explains these limits.

Which exceptions can be examined?

Article 13.11: Under specified conditions, the procurement result may allow substations with F-gas with GWP below 1,000. The rule distinguishes between the first two years after the relevant ban date and later years, as well as between voltage categories. There must be an actual, technically relevant procurement and evidence of bids and manufacturers.

Article 13.12: Under additional conditions, substations with GWP 1,000 or higher may be applicable if the procurement did not yield any relevant bid with GWP below 1,000. It is not a free SF6 exception.

Article 13.14: The operator can prove that an actual order was placed before 11 March 2024. A claim of an “old quote” is not sufficient without order evidence.

Article 13.15: A narrow expansion situation where equipment with lower GWP is not compatible with the existing substation and would otherwise require the replacement of the entire facility. The basis must be technically realistic.

Article 13.10: The relocation of substations already in operation within the EU to another location in the EU is treated separately. That ground requires record-keeping but is not included in the notification points 11, 12, 14, and 15 in Article 13.17.

What must be sent to the authority?

According to Article 13.17, the operator shall notify the competent supervisory authority at the time of commissioning if exceptions under 13.11, 13.12, 13.14, or 13.15 are used. In the Swedish Environmental Protection Agency's guidance, reviewed 8 July 2026, the operator's and contact person's details, municipality, voltage level, insulating/switching medium, exact legal exception, reason, procurement result, order evidence, or compatibility evidence are specified, among others.

The Swedish Environmental Protection Agency states that the notification is currently submitted to its registrar as the temporary competent authority. **Always check the current recipient when the letter is actually sent.** It is not a process for a preliminary decision before procurement. File 04 of the package is an editable draft, not a government form.

Complete File List

Excel with nine tabs and eight administrative metrics

The tabs are Overview, Substation, Procurement, Bids, Exceptions, Notifications, Decisions, Actions, and Sources & Guide. Track unique substation IDs, competent operator, actual bids and manufacturers, deviations, transmission receipts, and internal decision process. The overview shows, for example, the number of registered substations, unverified exceptions, notifications to send, missing receipts, and open actions.

An empty customer register gives 0 in all key metrics. The formulas are tested with separate sample data and only provide administrative status values. No fabricated bids, manufacturers, SF6 values, regulatory receipts, or signatures are included.

How to work with the package

1. Assess actual applicability: identify the operator, facility, nominal voltage, F-gas/GWP, and whether it is a new commissioning, EU relocation, or expansion.
2. If a procurement exception is considered: collect comparable bids and distinguish manufacturers. Select the correct two-year period in Article 13.11 and assess 13.12 separately if applicable.
3. Document the exception: use the correct point in Article 13 with order evidence, technical compatibility analysis, or procurement evidence. Stop the case if the requirements cannot be proven.
4. Prepare the regulatory notification: if 13.11/12/14/15 is used, use file 04 and check the actual authority and time of commissioning.
5. Decide and archive: perform a separate technical electrical safety test and internal decision. Retain evidence of applied exceptions under Article 13.16 for at least five years.

Frequently Asked Questions

Is a 12 kV SF6 substation prohibited from being commissioned from 2026?

As a general rule, yes for such medium-voltage substations covered by 13.9(a), but a possible exception must be examined separately and proven with actual evidence.

Does the same ban apply to 36 kV in 2026?

No, the ban in Article 13.9(b) for medium voltage above 24 kV up to and including 52 kV starts on 1 January 2030. Other rules may already apply to the equipment.

Does a procurement with only one quote always grant an exemption?

No. Articles 13.11–12 set specific time, manufacturer, technical, and GWP-related conditions. The exact requirements of the regulation and the basis for bids must be assessed.

Can I use the template for a substation order from 2023?

Yes, to document and assess Article 13.14. Actual provable order before 11 March 2024 is required. If an exception is applied, a 13.17 notification may become relevant.

Is this the same as a regular F-gas leakage register?

No. Our separate package on F-gas leakage and aftercare applies to a different work process. This package concerns substation commissioning, exception grounds, and regulatory notification.

Can Excel automatically determine that my substation can be commissioned?

No. Decisions must be made by the competent legal and technical function, with electrical safety control and legal basis. Excel calculates administrative status markings, not legal compliance.

Are all documents in English?

No. Five work templates, Swedish guide, and Excel are in Swedish. A separate English User Guide describes how the Swedish documents are used.

Legal sources, version, and limitation of liability

Official sources: Regulation (EU) 2024/573, especially Article 13.9–17, and the Swedish Environmental Protection Agency's guidance on electrical switchgear containing SF6. Check later changes and the responsible authority before operational use.

Version 1.0, AI-assisted source review 10 November 2026. The package is a professional documentation basis and does not replace individual legal advice, certified electrical installation work, measurement, technical inspection, regulatory decision, official exception approval, or automatic notification. No external legal review, regulatory submission, or physical substation inspection has been performed.