Short answer
A chiller is not read in the refrigeration or the air-conditioning rows. It has point 7 of Annex IV to itself, and two capacity thresholds.
- Up to and including 12 kW: gases with a GWP of 150 or more may no longer be placed on the market from 1 January 2027 (point b), and any fluorinated greenhouse gas from 1 January 2032 (point c). Both rows carry the safety-requirement exception at the site of operation.
- Above 12 kW: point (d) also sets 1 January 2027 and names a GWP of 750, with the same safety exception.
- History: point (a) prohibited HFCs with a GWP of 2 500 or more from 1 January 2020, except equipment intended for applications designed to cool products below minus 50 degrees Celsius.
In operation, Article 13(5) is worth remembering the other way round: the 750 step of 1 January 2032 applies to stationary refrigeration equipment with the exclusion of chillers. It is the only paragraph that carves them out expressly.
No prices, no availability, no equipment selection and no design for a particular plant. No national penalties and no dangerous-goods figures either. For check intervals see leak-check frequency; for detection, leakage detection systems.
What a chiller is in the meaning of the Regulation
Article 3, point (44) defines a chiller as a single system whose primary function is to cool a heat transfer fluid, such as water, glycol, brine or CO2, for refrigeration, process, preservation or comfort purposes.
Three elements of that definition decide the classification. First, a single system, not an assembly of separate circuits. Second, the primary function is to cool a heat transfer fluid, not to cool air or the product directly. Third, the purpose may be refrigeration, process, preservation or comfort — so a comfort chiller sits in the same definition as a process chiller.
The Regulation reinforces that separation with explicit carve-outs in the neighbouring rows:
- Point 4 of Annex IV: any self-contained refrigeration equipment, except chillers.
- Point 5: refrigeration equipment, except chillers and equipment covered in points 4 and 6.
- Point 8: self-contained air-conditioning equipment and heat pumps, except chillers.
In other words, if the equipment meets the definition in Article 3, point (44), the other rows do not apply to it. If it does not, point 7 does not apply to it. Classification does not follow the commercial name of the machine but its primary function. The other rows are treated in the guides on commercial refrigeration and on heat pumps and split air conditioning.
Annex IV point 7, row by row
| Annex IV point | Capacity band | GWP limit and exception | Date of prohibition |
|---|---|---|---|
| 7(a) | All chillers | HFCs with a GWP of 2 500 or more, except equipment intended for applications designed to cool products below minus 50 degrees Celsius | 1 January 2020 |
| 7(b) | Rated capacity up to and including 12 kW | Fluorinated greenhouse gases with a GWP of 150 or more, except if required to meet safety requirements at the site of operation | 1 January 2027 |
| 7(c) | Rated capacity up to and including 12 kW | Fluorinated greenhouse gases, with no GWP limit, with the same safety exception | 1 January 2032 |
| 7(d) | Rated capacity above 12 kW | Fluorinated greenhouse gases with a GWP of 750, with the same safety exception | 1 January 2027 |
Two observations change the planning.
Points (b) and (d) share the same date. On 1 January 2027 both capacity bands close at once, at different thresholds: 150 below 12 kW, 750 above 12 kW. There is no transitional period in which the larger band stays open after the smaller one.
Point (d) is written in the English, German, Romanian, Spanish and Italian versions as fluorinated greenhouse gases "with a GWP of 750", without the words "or more" that appear in the other points. The Dutch version adds "of meer". Treat 750 as the limit value of the row and check the text in the language of the Member State where the equipment is placed on the market.
For a chiller above 12 kW, the 750 line takes R-410A (GWP 2 088 under Annex VI), R-407C (1 774) and R-134a (1 430) out of consideration, but leaves gases such as R-513A (629,5 under Annex VI) or R-1234ze in play, alongside the natural options. Their status is set out on the R-513A, R-134a, R-290 and R-717 pages.
Servicing: where chillers sit in Article 13
Article 13 has three paragraphs that touch stationary refrigeration, and chillers appear differently in each.
Paragraph 3 prohibits the use of fluorinated greenhouse gases with a GWP of 2 500 or more for the maintenance or servicing of refrigeration equipment with a charge size of 40 tonnes of CO2 equivalent or more, and from 1 January 2025 for any refrigeration equipment. The text does not exclude chillers. The exceptions it lists are military equipment and equipment intended for applications designed to cool products below minus 50 degrees Celsius, plus the reclaimed and recycled window until 1 January 2030 and equipment for which an exemption has been authorised under Article 11(5).
Paragraph 4 targets, from 1 January 2026, air-conditioning equipment and heat pumps, again at the 2 500 threshold, with the reclaimed and recycled window until 1 January 2032.
Paragraph 5 is where chillers appear explicitly: from 1 January 2032, the prohibition on using Annex I gases with a GWP of 750 or more covers stationary refrigeration equipment with the exclusion of chillers. The exclusion is written in the text, both in the first subparagraph and in points (a) and (b) on reclaimed and recycled gas.
The fact that paragraph 5 excludes chillers does not put a chiller outside Article 13. Paragraph 3 does not exclude them, and for a chiller used for air conditioning the question of paragraph 4 arises. The Regulation does not settle that overlap expressly. For a specific installation, confirm the classification with the competent authority before ordering gas.
In practice, for a chiller on R-404A or R-507A the 2 500 line has been crossed since 2025. For one on R-410A or R-134a, paragraph 3 does not apply and paragraph 5 expressly excludes it. The full treatment of Article 13 is in the guide on servicing bans.
Leak checks and the mandatory detection system
A mid-size chiller crosses the Article 5 thresholds on a single charge, and a large one crosses those of Article 6.
The entry threshold. Article 5(1): operators and manufacturers of equipment that contains 5 tonnes of CO2 equivalent or more of Annex I gases, or 1 kilogram or more of Section 1 Annex II gases that is not contained in foams, shall ensure the equipment is checked for leaks. Paragraph 2 lists the stationary equipment concerned: refrigeration, air-conditioning, heat pumps, fire protection, organic Rankine cycles and electrical switchgear. A chiller falls into one of the first three, depending on the use.
Frequency. Article 5(6): below 50 tonnes of CO2 equivalent, at least every 12 months, or every 24 months with a leakage detection system; from 50 to below 500 tonnes, every 6 months, or every 12 months; from 500 tonnes upwards, every 3 months, or every 6 months. The checks are carried out by natural persons certified under Article 10, per paragraph 3, second subparagraph.
The detection system. Article 6(1): at 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kilograms or more of Section 1 Annex II gases, stationary equipment listed in Article 5(2), points (a) to (d), must have a leakage detection system which alerts the operator or a service company. Paragraph 3 requires the detection system to be checked at least once every 12 months.
The arithmetic follows Article 3, point (3): tonnes of CO2 equivalent equals weight in metric tonnes multiplied by the GWP. A chiller with 120 kg of R-134a reaches 171,6 tonnes of CO2 equivalent, so the 6-month band, or 12 months with a detection system. The same chiller with 380 kg would pass 500 tonnes and make the detection system mandatory.
Records, label and recovery
Records. Article 7(1) requires a record for each piece of equipment subject to leak checks under Article 5(1), giving: the quantity and type of gases, indicating separately the quantity added during installation; the quantities added during maintenance or servicing or due to leakage, with the date; the quantity recovered; the type and provenance of the gas added, including whether it was recycled or reclaimed, with the name and address of the facility and, where applicable, the certificate number; the identity of the undertaking that carried out the work, with its certificate number and, for legal persons, also the details of the natural person performing the operation; the dates and results of the checks and of any leak repairs; and, at decommissioning, the measures taken to recover and dispose of the gases. Paragraph 2 requires them to be kept at least 5 years, by the operator and in copy by the servicing undertaking, unless they sit in a database set up by the competent authorities.
Label. Article 12(1), point (a) covers refrigeration equipment, point (b) air-conditioning equipment and point (c) heat pumps. Paragraph 3 sets out the content: an indication that the equipment contains fluorinated greenhouse gases or that its functioning relies upon them, the accepted industry designation of the gas or, if none, the chemical name, and from 1 January 2017 the quantity expressed in weight and in CO2 equivalent, together with the GWP. Paragraph 4 requires the label to be clearly legible and indelible, placed adjacent to the service ports or on the part containing the gas, and written in the official languages of the Member State where the good is placed on the market.
Recovery. Article 8(1): operators shall ensure that the gases are recovered and, after decommissioning, recycled, reclaimed or destroyed; recovery is carried out by natural persons holding the relevant certificates provided for in Article 10. Paragraph 2, point (a) names expressly the cooling circuits of refrigeration, air-conditioning equipment and heat pumps. Paragraph 6 adds the rule that matters on site: recovered gases shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed.
The detail is in the guides on the equipment records and on refrigerant recovery.
The safety exception and putting into operation
Points (b), (c) and (d) of point 7 all carry the formula "except if required to meet safety requirements at the site of operation". Point (a) does not; it carries instead the exception for applications below minus 50 degrees Celsius.
Article 3, point (42) requires the prohibition of the alternative to come from Union or national law, or from a non-legally binding act containing technical documentation or standards that have to be applied to ensure safety at that specific location, provided they are in accordance with the relevant law. It is not a matter of design preference.
Unlike point 8, point 7 does not provide a fallback limit of 750 where the exception applies. The text stops at the general formula.
Where the exception is relied on, two written duties follow.
- Labelling. Article 12(15) includes point 7(b), (c) and (d) in the list of cases where the equipment must be labelled with an indication that it shall be used only where required by the safety requirements or national safety standards, and those requirements must be specified on the label.
- Evidence at commissioning. Article 13(19) also includes point 7(b), (c) and (d): putting into operation after the prohibition date is prohibited unless the operator can provide evidence either that the relevant safety requirements at the particular location do not permit the installation of equipment below the GWP value specified, or that the equipment was placed on the market before that date. Paragraph 20 requires the documentation to be kept for at least 5 years and made available on request.
The general Article 11 rules also stand: the repair-parts derogation in paragraph 1, second subparagraph, the evidence required on resale one year on under the fifth subparagraph, and the exceptional exemption of up to 4 years under paragraph 5.
Checklist for a chiller
- Confirm that the equipment is a chiller under Article 3, point (44)A single system whose primary function is to cool a heat transfer fluid, for refrigeration, process, preservation or comfort.
- Read the rated capacity against the 12 kW lineUp to and including 12 kW, points (b) and (c) apply; above 12 kW, point (d) applies.
- Compare the GWP with the limit in the row150 at point (b), no limit at point (c) because any fluorinated greenhouse gas is caught, and 750 at point (d).
- Remember that points (b) and (d) share a date1 January 2027 for both capacity bands, at different thresholds.
- Compute the charge in tonnes of CO2 equivalentArticle 3, point (3); compare with 5, 50 and 500 tonnes for Articles 5 and 6.
- Check whether the leakage detection system becomes mandatoryArticle 6(1) at 500 tonnes of CO2 equivalent or 100 kg of Section 1 Annex II gases; checked at least every 12 months, paragraph 3.
- Open the record before the first interventionArticle 7(1), points (a) to (g), kept at least 5 years under paragraph 2.
- Check the label and, if applicable, the safety statementArticle 12(1), (3) and (4), plus paragraph 15 for point 7(b), (c) and (d).
- Prepare the evidence for commissioningArticle 13(19) and (20): a safety requirement at that location, or placing on the market before the prohibition date.
- Plan recovery at decommissioningArticle 8(1) and (2), point (a), by persons certified under Article 10; paragraph 6 for reuse.
Frequently asked questions
Does a comfort chiller also fall under point 7?
Yes, if it meets the definition. Article 3, point (44) expressly includes comfort purposes alongside refrigeration, process and preservation. The test is not the use of the building but the primary function of the system: cooling a heat transfer fluid such as water, glycol, brine or CO2.
Why does point 5 not apply to chillers?
Because its own text excludes them. Point 5 of Annex IV covers refrigeration equipment "except chillers and equipment covered in points (4) and (6)". The same exclusion appears in point 4 and in point 8. The Regulation built a separate row for chillers, point 7, precisely to take them out of the others.
Does point (d) mean 750, or 750 and above?
The official text of point (d) names fluorinated greenhouse gases "with a GWP of 750" for chillers above 12 kW, without the "or more" wording used in the other points; the Dutch version, however, adds "of meer". This page reproduces the row as written. In practice, treat 750 as the limit value and check the text in the language of the Member State where the equipment is placed on the market.
Does the 750 servicing ban of 2032 affect my chiller?
Article 13(5) refers to stationary refrigeration equipment with the exclusion of chillers, and the exclusion is repeated in points (a) and (b) on reclaimed and recycled gas. Paragraph 3 remains applicable though, with no chiller carve-out: from 1 January 2025 gases with a GWP of 2 500 or more may no longer be used for the maintenance or servicing of refrigeration equipment.
When does the leakage detection system become mandatory?
Article 6(1): at 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kilograms or more of Section 1 Annex II gases, for stationary equipment listed in Article 5(2), points (a) to (d). The system must alert the operator or a service company, and paragraph 3 requires it to be checked at least once every 12 months.
Can I recharge the chiller with the gas recovered from it?
Not directly. Article 8(6) provides that 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 definitions are in Article 3, points (12) and (13), and the container labelling in Article 12(7).
Official sources
Annex IV point 7, and points 4, 5 and 8 for the carve-outs, together with Articles 3, 5, 6, 7, 8, 11, 12 and 13, were read in the Official Journal text. The official language versions were compared for point 7(d).
How current this page is, and its limits
The rows of point 7 are reproduced from Annex IV to Regulation (EU) 2024/573 as published in the Official Journal, including the wording of point (d). The Annex may be amended by delegated act. Whether a particular machine is a chiller depends on its primary function, which only the technical documentation can confirm.
General information prepared by EgoLog on the basis of the Regulation and official Commission material. It is not legal advice and it does not replace a specialist design or the opinion of a competent authority.
Installation, servicing, repair and decommissioning of chillers containing fluorinated greenhouse gases may only be carried out by personnel certified under Article 10. Ammonia and hydrocarbon chillers require additional safety measures and, where applicable, dedicated plant rooms.