Short answer
A refrigerant is not picked off a GWP table. It is picked by passing, in order, through seven filters, only two of which are technical. The rest are dates and duties written into Regulation (EU) 2024/573.
The order matters, because a refrigerant that passes the technical test can fail at the next step. A gas that suits the machine perfectly but is banned from being placed on the market for that equipment type at the date of commissioning is not an option. And a gas that is allowed today but fails at the plant's servicing horizon is a problem postponed, not solved.
The filter that catches people out most often is Annex IV: the prohibitions there are written by equipment type, with a GWP limit and a date. There is no list of banned refrigerants; there are pieces of equipment that can no longer be placed on the market with a gas above a certain limit, from a certain date.
No thermodynamic data, capacities, efficiencies, pressures, glide or oil compatibility. No recommendation of any particular product and no prices. Whether a refrigerant suits a specific machine is settled by the equipment manufacturer's documentation and the safety data sheet, not by a regulatory page.
The method, step by step
1. Application and temperature range
Commercial refrigeration, industrial refrigeration, air conditioning, heat pump, chiller, transport. This is where the candidate families narrow, on the basis of the equipment manufacturer's documentation. The Regulation does not decide this step.
2. Annex IV: which prohibitions touch your equipment type
Article 11(1) prohibits the placing on the market of the products and equipment listed in Annex IV from the date specified there, differentiated where applicable by the type or GWP of the gas. Find the row that describes your equipment exactly.
3. The servicing horizon
Article 13(3), (4) and (5) limit the gas used for maintenance and servicing: 2 500 for refrigeration from 1 January 2025, 2 500 for air conditioning and heat pumps from 1 January 2026, and 750 for stationary refrigeration excluding chillers from 1 January 2032. A plant that will still be running after those dates has to pass this filter too.
4. Safety class and site constraints
The A1, A2L, A3 or B2L classification comes from the safety data sheet and the manufacturer's documentation. Annex IV points 8 and 9 provide expressly that where safety requirements at the site of operation would not allow a gas below 150, the GWP limit is 750.
5. Quota exposure and CO2 equivalent
Article 16(1) ties the placing on the market of hydrofluorocarbons to quota, and Annex VII sets the maximum annual quantities. For your plant, work out the charge in tonnes of CO2 equivalent — that is the figure that triggers everything else.
6. Leak-check and detection consequences
Article 5(6) sets the intervals by charge band, and Article 6(1) requires a leakage detection system above 500 tonnes of CO2 equivalent. These consequences are decided when the gas is chosen, not after commissioning.
7. The paperwork that results
The label under Article 12(3) and (4), the equipment records under Article 7(1) and, where relevant, the certificates required by Article 10. Choosing the gas also chooses the documents you will keep for five years.
Step 1: the application narrows the families
The first filter is not legal. Temperature range, plant type, location and service access narrow the candidate families before the Regulation says anything. The source for suitability is the equipment manufacturer's documentation and the product safety data sheet, in the format required by Regulation (EU) 2020/878.
This site carries a regulatory-status page for each family, with the calculated GWP, the position against the thresholds and the Annex IV rows that touch it:
- HFC and HFO blends: R-454B, R-454C, R-513A, R-452A and R-507A.
- Natural refrigerants: R-290, R-600a, R-744 and R-717.
For decisions already framed as a choice between two options, see R-32 or R-410A and replacing R-404A. For the difference between changing the gas and changing the plant, drop-in or retrofit.
Annex I lists individual substances. For blends, Annex VI gives the method: a weighted average of the masses, calculated as the sum of the weight percentages multiplied by the GWP of each substance, including the non-fluorinated components, with a weight tolerance of plus or minus 1 % and a default value of zero for substances not listed. The Annex I values used most often: HFC-32 = 675, HFC-125 = 3 500, HFC-134a = 1 430, HFC-143a = 4 470. From Section 1 of Annex II, HFO-1234yf = 0.501.
Step 2: Annex IV fixes the date
Article 11(1) prohibits the placing on the market of the products and equipment listed in Annex IV, with an exemption for military equipment, from the date specified in that Annex, differentiated where applicable according to the type or global warming potential of the gas contained.
The second subparagraph allows, by way of derogation, the placing on the market of parts required for the repair and servicing of existing equipment listed in Annex IV, provided the work does not result in an increase in the capacity of the equipment, an increase in the amount of gas it contains, or a change of gas type leading to a higher global warming potential.
The rows below are the ones most often met in a design decision.
| Point | Equipment | Limit | Date |
|---|---|---|---|
| 4 | Any self-contained refrigeration equipment except chillers | GWP 150 or more | 1.1.2025 |
| 5(b) | Other refrigeration equipment (not chillers, not points 4 and 6), any fluorinated greenhouse gas | GWP 2 500 or more | 1.1.2025 |
| 5(c) | The same equipment | GWP 150 or more | 1.1.2030 |
| 6 | Multipack centralised commercial systems of 40 kW or more, Annex I gases | GWP 150 or more | 1.1.2022 |
| 7(b) | Chillers up to and including 12 kW | GWP 150 or more | 1.1.2027 |
| 7(d) | Chillers above 12 kW | GWP limit of 750 | 1.1.2027 |
| 8(b) | Self-contained air conditioning and heat pumps, up to and including 12 kW | GWP 150 or more (750 where safety requires) | 1.1.2027 |
| 9(a) | Single split systems containing less than 3 kg of Annex I gases | GWP 750 or more | 1.1.2025 |
| 9(b) | Split air-to-water, up to and including 12 kW | GWP 150 or more | 1.1.2027 |
| 9(e) | Split systems above 12 kW | GWP 750 or more | 1.1.2029 |
The full timetable, with every point, is in the guide on the ban timetable.
Step 3: the plant's servicing horizon
A plant commissioned today will need gas in ten years' time. Article 13 decides whether that gas will still be usable then.
- Article 13(3): 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 is prohibited; from 1 January 2025 the prohibition applies to any refrigeration equipment. It does not apply to military equipment or to equipment intended to cool products below −50 °C.
- Article 13(4): from 1 January 2026, the same 2 500 limit applies to the maintenance and servicing of air-conditioning equipment and heat pumps.
- Article 13(5): from 1 January 2032, the use of Annex I gases with a GWP of 750 or more for the maintenance or servicing of stationary refrigeration equipment, with the exclusion of chillers, is prohibited. The exceptions are military equipment, equipment intended to cool below −50 °C and equipment intended to cool nuclear power stations.
Each of those paragraphs carries a time-limited exception for reclaimed or recycled gas, conditional on labelling under Article 12(7) and, for recycled gas, on its use by the undertaking that carried out the recovery or for which it was carried out. The differences are explained in reclaimed, recycled and virgin refrigerant.
If the plant will still be running after 1 January 2032 and is stationary refrigeration equipment that is not a chiller, choosing a gas with a GWP of 750 or more means servicing with virgin gas will no longer be possible at that date. The 750 line separates, for example, refrigerants around the 600 mark from those around 1 400.
Step 4: safety class and what it triggers
The Regulation does not classify refrigerants for flammability or toxicity. That classification comes from the industry safety standard and appears in the manufacturer's documentation. Its structure, as a manufacturer's technical bulletin describes it, is this: toxicity is divided into two classes — A for lower toxicity and B for higher toxicity — and flammability into four classes: 1, 2L, 2 and 3.
Hence the combinations met in practice: hydrocarbons such as propane and isobutane are rated A3; many HFOs and some HFCs are A2L; ammonia, with higher toxicity and mild flammability, is B2L. The exact class of your product comes from its safety data sheet, not from an analogy.
Where the Regulation comes in. Annex IV recognises site safety constraints and gives them legal effect. At point 8(b), for self-contained air conditioning and heat pumps up to and including 12 kW, the text says that if safety requirements at the site of operation would not allow using fluorinated greenhouse gases with a GWP of less than 150, the GWP limit is 750. The same construction appears at points 8(c), 8(d) and 8(e). At point 9, subpoints (b) to (f) carry the wording "except if required to meet safety requirements at the site of operation".
Certification follows the choice. Article 10 requires the certification of persons who install, maintain, repair or decommission the equipment, and Implementing Regulation (EU) 2024/2215 expressly covers, in Article 2(1) and (2), ammonia, carbon dioxide and hydrocarbons as well. Its Article 3(2) sets the types: A1 for fluorinated greenhouse gases and hydrocarbons, A2 for the same activities on small charges, B for carbon dioxide, C for ammonia, D for recovery from small equipment and E for leak checks that do not break into the circuit.
In other words, choosing a natural refrigerant does not take the work out of the certification regime: it changes the type of certificate you need. More in safety classes A1, A2L and A3 and in low-GWP refrigerants on site.
Steps 5, 6 and 7: quota, checks and paperwork
Quota. Article 16(1) allows the placing on the market of hydrofluorocarbons only to the extent that producers and importers have been allocated quota, and Annex VII, point 1 sets the maximum annual quantity in tonnes of CO2 equivalent. The practical consequence for a project is indirect but real: the larger the charge in CO2 equivalent, the more the plant depends on a resource that shrinks year by year.
CO2 equivalent. It is the weight of the gas in metric tonnes multiplied by its GWP. For blends the GWP comes from the Annex VI method. The calculation can be done directly in the F-gas calculator.
Leak checks. Article 5(1) requires checks on equipment containing Annex I gases in quantities of 5 tonnes of CO2 equivalent or more, or 1 kilogram or more of gases listed in Section 1 of Annex II. The intervals are in Article 5(6):
| Charge | Interval | With a leakage detection system |
|---|---|---|
| Below 50 tonnes CO2e (Annex I) or below 10 kg (Annex II Section 1) | At least every 12 months | At least every 24 months |
| 50 – 500 tonnes CO2e or 10 – 100 kg | At least every 6 months | At least every 12 months |
| 500 tonnes CO2e or more | At least every 3 months | At least every 6 months |
The detector. Article 6(1) is not optional: operators of the stationary equipment listed in Article 5(2), points (a) to (d), that contains Annex I gases in quantities of 500 tonnes of CO2 equivalent or more, or 100 kilograms or more of gases listed in Section 1 of Annex II, shall ensure that the equipment has a leakage detection system which alerts the operator or a service company. Article 6(3) requires that system to be checked at least once every 12 months. More in leak-check frequency.
The paperwork. The equipment label must meet Article 12(3) and (4), in the format set by Implementing Regulation (EU) 2024/2174. The equipment records, with the seven categories of information in Article 7(1), are kept for any equipment subject to leak checks and retained for at least 5 years. See F-gas equipment records.
Decision checklist
- The application and temperature range are settled before any GWP discussionThe source is the equipment manufacturer's documentation, not a regulatory page.
- The Annex IV row that describes the equipment has been identifiedArticle 11(1): the prohibition is by equipment type, with a GWP limit and a date.
- The commissioning date has been compared with the Annex IV datePlacing on the market after that date is no longer possible with that gas.
- The servicing horizon has been checked against Article 132 500 for refrigeration from 1 January 2025, 2 500 for air conditioning and heat pumps from 1 January 2026, 750 for stationary refrigeration excluding chillers from 1 January 2032.
- The safety class has been read from the safety data sheetA1, A2L, A3 or B2L; the classification is not inferred by analogy with another product.
- Site safety constraints have been assessedAnnex IV points 8 and 9 raise the limit to 750 where safety at the site of operation does not allow a gas below 150.
- The charge has been calculated in tonnes of CO2 equivalentWeight in tonnes multiplied by the GWP; for blends, the GWP from Annex VI.
- The leak-check band is knownArticle 5(6): 12, 6 or 3 months, doubled where a leakage detection system is fitted.
- The need for a detection system has been establishedArticle 6(1): mandatory from 500 tonnes of CO2 equivalent or 100 kilograms.
- The certificates needed for the work have been confirmedArticle 10 and Regulation (EU) 2024/2215, including type B for carbon dioxide and type C for ammonia.
Frequently asked questions
Why not start from the lowest GWP?
Because GWP is not the only filter, and the lowest GWP often brings a more demanding safety class and site constraints with it. Annex IV recognises this expressly at points 8 and 9, where the limit rises to 750 when safety requirements at the site of operation would not allow a gas below 150. The right decision is the one that passes all seven filters, not the one that optimises a single one.
Does Annex IV ban the refrigerant or the equipment?
The equipment. Article 11(1) prohibits the placing on the market of the products and equipment listed in Annex IV from the date specified there, differentiated by the type or GWP of the gas. There is no list of banned substances; there are combinations of equipment type, GWP limit and date.
Can I keep using existing equipment after the Annex IV date?
Annex IV is about placing on the market, not about use. Use is governed by Article 13, which limits the gas used for maintenance and servicing. The two sets of dates are different and have to be checked separately.
How do I calculate the GWP of a blend?
With the Annex VI method: a weighted average of the masses, that is, the sum of the weight percentages multiplied by the GWP of each substance, including the non-fluorinated components, with a weight tolerance of plus or minus 1 % and a default value of zero for substances not listed in the annexes. The result can be checked in the F-gas calculator.
Does a natural refrigerant take me out of the certification duties?
No. Implementing Regulation (EU) 2024/2215 covers ammonia, carbon dioxide and hydrocarbons in Article 2(1) and (2), and Article 3(2) provides distinct certificates: B for carbon dioxide and C for ammonia, alongside A1, which covers fluorinated greenhouse gases and hydrocarbons. What changes is the type of certificate, not the existence of the duty.
Is a leakage detection system a cost option?
No. Article 6(1) imposes it on operators of the stationary equipment in Article 5(2), points (a) to (d), containing 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kilograms or more of those listed in Section 1 of Annex II. A side effect is that the Article 5(6) checking interval doubles.
What if no refrigerant passes all the filters?
Then the blocking filter is usually the equipment type, not the gas. Go back to step 1 with a different architecture — an indirect system, a different capacity, a different location — and check whether the applicable Annex IV row changes. Article 11(5) also provides for an exemption authorised by the Commission, for up to 4 years, following a substantiated request by a competent authority, where alternatives are not available or would entail disproportionate costs.
Official sources
Articles 5, 6, 7, 10, 11, 12, 13 and 16, and Annexes I, II, IV, VI and VII, were read directly in the Official Journal text. The structure of the safety groups comes from a manufacturer's technical bulletin; the classification of a specific product comes from its own safety data sheet.
How current this page is, and the limits of our liability
This page describes a decision method based on the Regulation. It does not recommend a product, contains no thermodynamic data and does not confirm that a refrigerant may be used in a particular plant. Technical suitability is settled with the equipment manufacturer and with the product safety data sheet.
General information prepared by EgoLog on the basis of the Regulation, the implementing regulations and official Commission material. It is not legal advice and it is not engineering design.
Work on the refrigerant circuit is carried out by competent persons certified under Article 10 of the Regulation and Implementing Regulation (EU) 2024/2215. Annex IV may be amended; check the text in force before relying commercially on a date.