Statute Details
- Title: Environmental Protection and Management (Regulated GHG Works) Order 2022
- Act Code: EPMA1999-S771-2022
- Type: Subsidiary Legislation (SL)
- Authorising Act: Environmental Protection and Management Act 1999 (EPMA 1999)
- Enacting Power: Section 40K of the EPMA 1999
- Commencement: 1 October 2022
- Key Provisions: Section 2 (definitions); Section 3 (designation of “regulated GHG works”); Schedule (works specified)
- Regulatory Focus: Greenhouse gas (GHG) works relating to specified water-cooled chillers
- Current Version: Current version as at 27 March 2026 (per the platform status)
- Legislative Instrument Number: S 771/2022
What Is This Legislation About?
The Environmental Protection and Management (Regulated GHG Works) Order 2022 (“the Order”) is a Singapore regulatory instrument made under the Environmental Protection and Management Act 1999 (“EPMA 1999”). In plain terms, it identifies certain activities involving greenhouse-gas-containing equipment as “regulated GHG works”. Once an activity is classified as “regulated GHG works”, it falls within the compliance framework in Part 10A of the EPMA 1999.
The Order’s practical effect is to bring specific types of work—such as charging, maintenance, and decommissioning—within a controlled regulatory regime. The Order does this by (i) defining key terms (including “refrigerant”, “specified goods”, and the operational activities that count as “charging”, “maintenance”, and “decommissioning”), and (ii) designating the GHG works listed in its Schedule as “regulated GHG works” for the purposes of Part 10A of the EPMA 1999.
Although the extract provided does not reproduce the full Schedule text, the definitions and the scope of “specified goods” make the regulatory target clear: electrically driven water-cooled chillers that use refrigerants with a global warming potential (GWP) of more than 15. The Order therefore operates as a “gateway” instrument that determines which GHG-related works are regulated and from what date they become regulated.
What Are the Key Provisions?
1. Citation and commencement (Section 1)
Section 1 provides the short title and states that the Order comes into operation on 1 October 2022. For practitioners, this is important for determining the temporal scope of regulatory obligations—particularly where work was performed before versus after the commencement date, or where transitional issues arise.
2. Definitions that drive compliance (Section 2)
Section 2 is central because it defines the concepts that determine whether a particular activity is caught by the regulatory regime. The definitions are drafted to be operational and equipment-specific.
(a) “Specified goods” and “specified water-cooled chiller”
The Order defines “specified goods” as any specified water-cooled chiller. A “specified water-cooled chiller” is an electrically driven water-cooled chiller that requires, for its use or operation, a refrigerant where the greenhouse gas (or blend/mixture containing at least one greenhouse gas) has a global warming potential of more than 15.
This definition is significant because it ties the regulatory threshold to the GWP of the refrigerant used. Practically, this means that the same type of chiller may be regulated or not regulated depending on the refrigerant’s GWP. Lawyers advising facility owners, contractors, or maintenance providers will need to verify refrigerant specifications (often via equipment documentation, refrigerant labels, and maintenance records).
(b) “Refrigerant”
The definition of “refrigerant” is broad and functional: it includes any greenhouse gas, or blend/mixture of substances (at least one greenhouse gas), used for heat transfer in a refrigerating system, absorbing heat at low temperature/pressure and rejecting heat at high temperature/pressure, and typically changing between gaseous and liquid states in the system. This is designed to capture both single-gas refrigerants and blends.
(c) “Charging”, “maintenance”, and “decommissioning”
The Order defines three categories of activities that are commonly associated with refrigerant handling and system lifecycle management:
- Charging: charging specified goods with any refrigerant.
- Maintenance: any activity that involves breaking into any part of the specified goods (including gas carrying conductors/circuits) that contains or is designed to contain any greenhouse gas, including activities such as supplying parts with refrigerant, removing refrigerant or constituents, removing and reassembling parts, and repairing leaks in such parts. The definition excludes activities that do not involve the use or handling of any greenhouse gas.
- Decommissioning: final shut-down and removal from operation or usage of specified goods or any part that contains or is designed to contain any greenhouse gas, but not where shut-down/removal does not involve the use or handling of any greenhouse gas.
From a compliance perspective, these definitions are likely to be the “trigger points” for whether a contractor’s scope of work is regulated. For example, a repair that requires opening a circuit containing refrigerant would likely fall within “maintenance”. Conversely, a purely external activity that does not involve handling greenhouse gas may fall outside the definition.
(d) Cross-reference to another instrument
The definition of “water-cooled chiller” is taken from Part 2 of the Second Schedule to the Environmental Protection and Management (Prescribed Regulated Goods) Order 2022 (G.N. No. S 272/2022). This cross-reference indicates that the regulatory architecture is layered: one instrument defines the equipment category, while this Order designates the regulated works involving that equipment.
3. Designation of “regulated GHG works” (Section 3)
Section 3 provides the operative designation. It states that the GHG works specified in the Schedule are “regulated GHG works” for the purposes of Part 10A of the EPMA 1999, from and including the date specified opposite each of such works.
This structure matters because it implies that different types of works in the Schedule may have different effective dates. Even if the Order itself commences on 1 October 2022, the regulatory obligations for each category of work may begin on the date listed in the Schedule. Practitioners should therefore consult the Schedule carefully to determine the exact start date for each regulated activity.
4. Making and consultation
The Order was made on 28 September 2022 by the Permanent Secretary, Ministry of Sustainability and the Environment, after consulting the National Environment Agency. While not a substantive compliance provision, it is relevant for understanding the administrative context and the likely policy rationale (GHG reduction, refrigerant management, and leakage prevention).
How Is This Legislation Structured?
The Order is short and is structured as follows:
- Enacting Formula: states the legal basis (section 40K of the EPMA 1999) and the authority making the Order.
- Section 1 (Citation and commencement): sets the short title and commencement date (1 October 2022).
- Section 2 (Definitions): defines the key terms used to determine whether equipment and activities are within scope.
- Section 3 (Regulated GHG works): designates the Schedule-listed works as “regulated GHG works” for Part 10A of the EPMA 1999, with effective dates specified in the Schedule.
- Schedule: lists the specific “GHG works” that are regulated, and (critically) the date specified opposite each work category.
For legal work, the Schedule is typically the most important part because it connects the definitions (charging/maintenance/decommissioning) to the regulatory regime in Part 10A of the EPMA 1999 through a time-phased designation.
Who Does This Legislation Apply To?
The Order applies to persons who carry out, or arrange for, regulated GHG works involving specified water-cooled chillers—that is, electrically driven water-cooled chillers using refrigerants with GWP > 15. While the extract does not show the enforcement provisions, Part 10A of the EPMA 1999 is the relevant framework that will typically impose obligations on regulated persons (for example, licensing/registration, standards of work, reporting, or record-keeping).
In practice, the likely affected stakeholders include: facility owners and operators (who commission works), contractors and maintenance providers (who perform charging, maintenance, and decommissioning), and potentially suppliers or service providers who handle refrigerants or modify equipment circuits. Lawyers should also consider whether procurement contracts and tender specifications need to require compliance with the Part 10A regime and the specific regulated works categories in the Schedule.
Why Is This Legislation Important?
This Order is important because it operationalises Singapore’s regulatory approach to greenhouse gas management by focusing on refrigerant-containing equipment and the activities that can release GHGs. Water-cooled chillers are widely used in commercial and industrial settings, and refrigerant leakage or improper handling can contribute to climate impact. By defining “charging”, “maintenance”, and “decommissioning”, the Order targets the lifecycle points where emissions risk is highest.
From a legal risk perspective, the designation of “regulated GHG works” means that activities falling within the Schedule may require compliance with additional statutory duties under Part 10A of the EPMA 1999. Failure to comply can expose parties to enforcement action, and it can also create contractual and insurance issues (e.g., whether a contractor’s work was performed by appropriately authorised persons, and whether documentation supports regulatory compliance).
For practitioners advising on compliance programmes, due diligence, or disputes, the key practical steps are: (i) identify whether the facility’s chillers are “specified water-cooled chillers” by confirming refrigerant GWP; (ii) map planned works to the defined activities (charging/maintenance/decommissioning); and (iii) confirm the effective dates for each Schedule item to determine whether the work is regulated at the time it is performed.
Related Legislation
- Environmental Protection and Management Act 1999 (especially Part 10A and section 40K)
- Environmental Protection and Management (Prescribed Regulated Goods) Order 2022 (G.N. No. S 272/2022) — for the definition of “water-cooled chiller”
Source Documents
This article provides an overview of the Environmental Protection and Management (Regulated GHG Works) Order 2022 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.