Quick answer
Regulation (EU) 2024/573 contains no charging instructions. It does not tell you whether to draw liquid or vapour from the cylinder, at what pressure, or in what order.
What it does instead is define a mixture's GWP as the weighted average by mass of its components (Annex VI). From that moment, any change in the actual composition inside the plant also changes the figure the rest of your duties rest on: the CO2 equivalent, the leak-check band, the content of the record and the text on the label.
For a blend, the phase you draw it in decides whether what reaches the plant is what the label says. The correct procedure for each product comes from the manufacturer's documentation. The legal consequences of departing from it, however, are in the regulation — and this page sets them out.
What Annex VI says
Article 3(1) defines the GWP as the 100-year global warming potential set out in Annexes I, II and III or, in the case of mixtures, calculated in accordance with Annex VI.
Annex VI calculates a mixture's GWP as the sum of the components' contributions, each taken as its weight fraction multiplied by its own GWP. Two further rules from the same annex:
- A ± 1 % tolerance on the weight fraction.
- Substances not listed in the annexes count as 0.
The conclusion that matters: GWP is not a property of the trade name. “R-407C” is not 1 774 because it is called that, but because it has a particular composition. Change the composition and the figure changes.
Why the phase matters with a blend
A zeotropic blend — R-407C, R-448A, R-449A and others — has components with different volatilities. In a partly full cylinder, the vapour phase above the liquid is richer in the more volatile component than the liquid beneath it.
Draw vapour and you preferentially remove the volatile component. The result has two faces, both problematic:
- Into the plant goes a mixture that does not have the nominal composition, and therefore not the GWP on the label.
- In the cylinder stays a remainder whose composition has drifted the other way, and which will be used on another job.
Nobody added or removed gas in any accounting sense, but the figure describing the contents has moved.
Actual composition → actual GWP → the charge's CO2 equivalent → the Article 5(6) check band → the figure in the equipment record (Article 7(1)) → the information on the label (Article 12(3)). The first link moves every one after it.
With pure refrigerants — R-32, R-134a — the question does not arise: there is no composition to shift. The phase remains a matter of good practice and compressor safety, not of GWP compliance.
The duty at transfer: Article 4(4)
The text expressly covers the moment of charging. Article 4(4) provides that during the production, storage, transport and transfer of fluorinated greenhouse gases from one container or system to another, to equipment or to a facility, the undertaking concerned shall take all necessary precautions to limit release of the gases to the greatest extent possible.
“Transfer from one container to another” is exactly the charging operation. Properly purged hoses, leak-free connections, recovery of the gas left in hoses — all of that falls within that wording.
Article 4(1) completes the picture: intentional release into the atmosphere is prohibited where it is not technically necessary for the intended use. Venting a hose to air, as a method of work, is precisely what the text is aimed at.
Recovered gas does not go straight back in
A frequent temptation when working with blends is to put the gas recovered during the job straight back into the plant. Article 8(6) closes that route:
Any recovered fluorinated greenhouse gases listed in Annex I and in Section 1 of Annex II shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed.
The technical reason ties straight back to this page's subject: gas recovered from a plant has the composition it had in that plant, contaminated with oil, moisture and possibly other gases. Recycling and reclamation are the defined processes by which a known quality is restored.
A reminder from Article 12(7): containers of reclaimed gas carry the words “100 % Reclaimed”, the batch number, and the name and Union address of the reclamation facility. Without the label you cannot demonstrate the gas's status.
Change the refrigerant, change the label
Article 12(3) lists what a piece of equipment's label has to carry: the quantity expressed in weight and in CO2 equivalent of the gases contained — or the quantity the equipment is designed for — and their GWP.
The last subparagraph of that same paragraph closes the loop:
Where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, those products or equipment shall be relabelled with updated information as referred to in this paragraph.
And Article 12(4) requires the label to be clearly legible and indelible, placed adjacent to the service ports for charging or recovering the gas or on the part containing the gas, and written in the official languages of the relevant Member State.
In practice: the old label is not amended with a marker pen. It is replaced by one that tells the truth about what is in the plant now.
What goes into the equipment record
Where the equipment is subject to leak checks under Article 5(1), Article 7(1) requires a record for each piece of equipment covering:
- the quantity and type of fluorinated greenhouse gases installed;
- the quantities added during installation, maintenance or servicing or due to leakage, with dates;
- whether the added gases were recycled or reclaimed, with the name and address of the facility and, where applicable, the certificate number;
- the quantity recovered;
- the identity of the undertaking that installed, maintained or repaired the equipment and, where applicable, its certificate number;
- the dates and results of the checks and repairs.
Note the third bullet: the origin of the added gas is a field in the record, not optional background. If you add reclaimed gas, where it came from is written down.
The record is kept for at least 5 years, and the undertaking that carried out the work keeps a copy for 5 years as well.
What you take from the manufacturer's documentation
Everything about the technical procedure itself is outside the regulation. From the refrigerant and equipment documentation take at least:
- the recommended draw phase for that product;
- the relevant physical properties — section 9 of the safety data sheet;
- classification and hazard label elements — section 2;
- safe handling — section 7.1;
- nominal charge, pressures and oil compatibility — the equipment documentation.
Where the refrigerant is flammable the certification frame shifts too: Implementing Regulation (EU) 2024/2215 places hydrocarbons in Certificates A1 and A2, CO2 in Certificate B and ammonia in Certificate C, and Article 10(5) of the F-gas Regulation requires training to cover safe handling of equipment containing flammable or toxic gases or operating under high pressure.
Checklist at charging
- You know whether the refrigerant is pure or a blendThat decides whether the fractionation question arises at all.
- The draw procedure is the one in the product documentationThe regulation does not prescribe it; the manufacturer does.
- The GWP used in the sum is the binding columnNot the 20-year column in Annex I, marked for information only.
- The charge's CO2 equivalent is recalculated after the jobIt sets the Article 5(6) band.
- Hoses are purged and recovered, not vented to airArticle 4(1) and 4(4).
- The quantity added and its origin are recordedArticle 7(1), including whether the gas was recycled or reclaimed.
- Recovered gas was not put back without recycling or reclamationArticle 8(6).
- The label reflects what is in the plant nowArticle 12(3), last subparagraph, where the refrigerant has changed.
- The verification check is scheduled where there was a leakArticle 4(5): after at least 24 hours of operating time, within one month.
Frequently asked questions
Does the regulation forbid charging in the vapour phase?
No. The regulation neither prescribes nor forbids a charging phase. What it imposes are the Article 4(4) precautions at transfer and the accuracy of the figures you go on to declare — CO2 equivalent, record and label. The technical method comes from the manufacturer's documentation.
Does the phase matter with pure refrigerants too?
From the GWP standpoint, no: a pure refrigerant has no composition to shift. The Article 4(4) precautions and the technical safety considerations in the manufacturer's documentation remain relevant.
If I charged vapour from a blend, what GWP do I put in the record?
The regulation requires the record to reflect the quantity and type of gases in the equipment. If you have reason to believe the blend in the plant no longer has the nominal composition, the correct figure cannot be read off a general table; take it up with the refrigerant supplier and, where appropriate, correct the charge as the equipment manufacturer's documentation directs.
Can I top up a plant from a part-used cylinder of a blend?
The regulation does not prohibit using a started cylinder. The problem is technical, and it turns into a compliance problem only if the outcome makes the record or the label inaccurate. The refrigerant manufacturer's documentation tells you whether and how the remainder may be used.
Do I have to relabel if I only top up with the same refrigerant?
No. The relabelling duty in the last subparagraph of Article 12(3) is triggered where the equipment has been retrofitted and the fluorinated greenhouse gases have been changed. A top-up with the same refrigerant does not change the label information, but it does go into the record under Article 7(1).
Can I use gas recovered from the same plant to refill it?
Not directly. Article 8(6) says recovered gases shall not be used for filling or refilling equipment unless they have been recycled or reclaimed. Recycling carries its own, tighter conditions where it is relied on as an exception to the Article 13 servicing bans.
Official sources
Articles 3, 4, 5, 7, 8 and 12 and Annex VI were read directly in the Official Journal text. The technical charging procedure does not come from the regulation and is not reproduced here.
Currency of this page and limits of responsibility
This page explains the legal consequences of a refrigerant's composition. It is not a work instruction and does not prescribe a charging method. The correct procedure for each product and machine comes from the manufacturer's documentation and the safety data sheet.
General information prepared by EgoLog from the regulation and official Commission material. It is not legal advice and it is not an engineering assessment.
Nominal compositions of commercial blends are set by their manufacturers. Where the figure matters, take the GWP from the product documentation.