Commercial refrigeration: the Annex IV bans and the duties that follow

Short answer

Commercial refrigeration is covered by four Annex IV rows, and they do not overlap: each carries an exclusion that separates it from the others.

• Point 3 — refrigerators and freezers for commercial use, self-contained equipment: HFCs with a GWP of 2 500 or more from 1 January 2020, HFCs with a GWP of 150 or more from 1 January 2022, other fluorinated greenhouse gases with a GWP of 150 or more from 1 January 2025. No safety exception.
• Point 4 — any self-contained refrigeration equipment, except chillers, with gases of a GWP of 150 or more: 1 January 2025, except if required to meet safety requirements at the site of operation.
• Point 5 — refrigeration equipment, except chillers and the equipment covered in points 4 and 6: 2 500 from 1 January 2020 for HFCs and from 1 January 2025 for fluorinated greenhouse gases, then 150 from 1 January 2030.
• Point 6 — multipack centralised refrigeration systems for commercial use with a rated capacity of 40 kW or more: Annex I gases with a GWP of 150 or more are prohibited from 1 January 2022, with one carve-out only, the primary refrigerant circuit of cascade systems, where gases with a GWP of less than 1 500 may be used.

After installation, three further articles take over: Article 13 for what you may still charge, Article 5 for leak checks and Article 6 for the mandatory detection system.

Three definitions that decide the row

Before the tables, read Article 3. A wrong classification moves the ban date by years.

Commercial use, Article 3, point (29): use for the storage, display or dispensing of products, for sale to end users, in retail and food services. An identical freezer installed in a restaurant kitchen and one installed in an industrial warehouse do not necessarily fall in the same place.

Self-contained, Article 3, point (38): a complete factory-made system in a suitable frame or casing, fabricated and transported complete or in two or more sections, which can contain isolation valves and in which no gas-containing parts are connected on site.

Multipack centralised refrigeration systems, Article 3, point (34): systems with two or more compressors operated in parallel, connected to one or more common condensers and to a number of cooling devices such as display cases, cabinets and freezers, or to chilled store rooms. That is the definition of the supermarket rack.

Two more matter. The primary refrigerant circuit of cascade systems, Article 3, point (35): the primary circuit in indirect medium temperature systems where two or more separate refrigeration circuits are connected in series such that the primary circuit absorbs the condenser heat from a secondary circuit for the medium temperature. And chiller, Article 3, point (44): 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. Chillers are expressly carved out of points 4 and 5 and have their own row, point 7, treated in the guide on chillers.

Points 3, 4 and 5: cabinets and the rest of the equipment

The difference between point 3 and point 4 is worth underlining. Point 3 speaks of refrigerators and freezers for commercial use and leaves no safety door open. Point 4 covers any self-contained refrigeration equipment, whatever its purpose, and does leave that door open. If your cabinet sits in point 3, the date that matters is 2022 for HFCs, not 2025.

In point 5 the exception is not about safety but about temperature: equipment intended for applications designed to cool products to temperatures below minus 50 degrees Celsius stays outside points (a) and (b). Point (c), by contrast, returns to the usual safety-requirement formula.

Point 6: centralised supermarket racks

The text of point 6 is short and has to be read word by word: multipack centralised refrigeration systems for commercial use with a rated capacity of 40 kW or more that contain, or whose functioning relies upon, fluorinated greenhouse gases listed in Annex I with a GWP of 150 or more may not be placed on the market from 1 January 2022, except in the primary refrigerant circuit of cascade systems, where fluorinated greenhouse gases with a GWP of less than 1 500 may be used.

Four elements have to be checked separately.

• Commercial use within the meaning of Article 3, point (29). An identical rack in a food production hall is not automatically in the same category.
• A rated capacity of 40 kW or more. Below that, point 6 does not apply; the equipment falls into point 5, with its own dates.
• Annex I gases. Point 6 does not say "fluorinated greenhouse gases" in general but gases listed in Annex I. The wording differs from points 4 and 5(b) and (c).
• The cascade carve-out. It applies to the primary circuit only, in the sense of Article 3, point (35), and only up to a GWP of less than 1 500. It is not an exemption for the whole system.

For a new store, the practical consequence is that the medium-temperature and the freezing circuits move towards low-GWP solutions, and the cascade stays the only structure in which a fluorinated greenhouse gas with a GWP below 1 500 is admitted on the primary side. The most common natural alternative in this segment is covered in R-744 (CO2) in commercial refrigeration.

What you may still charge: Article 13

Annex IV stops the sale of the equipment. Article 13 stops the filling of it. For commercial refrigeration, two paragraphs matter.

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, whatever the charge. The second subparagraph takes out military equipment and equipment intended for applications designed to cool products to temperatures below minus 50 degrees Celsius. The third subparagraph suspends the prohibition until 1 January 2030 for reclaimed Annex I gases with a GWP of 2 500 or more used on existing equipment, provided the containers are labelled in accordance with Article 12(7), and for recycled gases with a GWP of 2 500 or more, provided they were recovered from such equipment and are used only by the undertaking that carried out the recovery or by the one for which it was carried out. The fourth subparagraph adds equipment for which an exemption has been authorised under Article 11(5).

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 minus 50 degrees Celsius and equipment intended to cool nuclear power stations. Reclaimed and recycled gas with a GWP of 750 or more remains allowed, on the same labelling and provenance conditions — and here the text sets no end date, unlike paragraphs 3 and 4.

For a fleet on R-404A (GWP 3 922 under Annex VI) or R-507A (3 985), the 2 500 line has already been crossed. For a fleet on R-448A (1 386) or R-449A (1 396), the 2 500 line does not apply, but the 750 line of 2032 does. The full treatment is in the guide on servicing bans, and the replacement route in replacing R-404A.

Leak checks, the detection system and the records

A medium-sized shop crosses the Article 5 thresholds quickly, and a supermarket crosses those of Article 6.

Who, and from what threshold. Article 5(1): operators and manufacturers of equipment that contains 5 tonnes of CO2 equivalent or more of gases listed in Annex I, or 1 kilogram or more of gases listed in Section 1 of Annex II that is not contained in foams, shall ensure that the equipment is checked for leaks. Paragraph 2 lists the stationary equipment concerned, and point (a) is refrigeration equipment itself.

Frequency. Article 5(6): below 50 tonnes of CO2 equivalent, at least every 12 months, or every 24 months where a leakage detection system is installed; from 50 to below 500 tonnes, at least every 6 months, or every 12 months with a detection system; from 500 tonnes upwards, at least every 3 months, or every 6 months with a detection system. For Section 1 Annex II gases the thresholds are expressed in kilograms: below 10, from 10 to below 100, and from 100 upwards.

The detection system. Article 6(1): operators of 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 Section 1 Annex II gases, shall ensure that the equipment has a leakage detection system which alerts the operator or a service company. Paragraph 3 requires the detection system itself to be checked at least once every 12 months.

The records. Article 7(1) requires a record for each piece of equipment subject to leak checks, with the quantity and type of gas, the quantities added on installation and on servicing, the quantity recovered, the provenance of the gas added, the identity of the undertaking that carried out the work, the dates and results of the checks and of any leak repairs, and the measures taken at decommissioning. Paragraph 2 requires them to be kept for at least 5 years, by the operator and, in copy, by the servicing undertaking, unless the records are stored in a database set up by the competent authorities.

The detail is in the guides on leak-check frequency, leakage detection systems and the equipment records.

The safety exception, the label and putting into operation

The "except if required to meet safety requirements at the site of operation" exception appears in commercial refrigeration only at point 4 and at point 5(c). It does not appear at point 3 and it does not appear at point 6.

Article 3, point (42) defines safety requirements as requirements on the safety of using fluorinated greenhouse gases and natural refrigerants, or products containing them, prohibiting the use of certain gases or their alternatives, including at a specific place of intended utilisation due to site and application specificities, set out in Union or national law or in a non-legally binding act containing technical documentation or standards that have to be applied to ensure safety at that location.

Where the exception applies, two duties follow.

• A label. Article 12(15) includes points 4 and 5(c) 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 points 4 and 5(c): 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 equipment below the GWP value specified, or that the equipment was placed on the market before the prohibition date. Paragraph 20 requires the documentation to be kept for at least 5 years.

The general rules also stay in force: Article 11(1), second subparagraph for repair parts, which must not increase the capacity, the amount of gas or the GWP; Article 11(5) for the exceptional exemption of up to 4 years authorised by the Commission; Article 12(1), point (a) and Article 12(3) for labelling refrigeration equipment; and Article 8(1) and (2), point (a) for recovery of the gas from the cooling circuits at decommissioning, by persons certified under Article 10.

Checklist for a store

• Establish whether the use is commercial within Article 3, point (29)Storage, display or dispensing of products for sale to end users, in retail and food services.
• Classify the equipment: self-contained, multipack or something elseArticle 3, point (38) for self-contained, point (34) for multipack; chillers have their own row, point 7.
• Check whether the rack crosses 40 kW rated capacityAnnex IV point 6 applies from 40 kW upwards; below that the equipment falls into point 5.
• Compute the charge in tonnes of CO2 equivalentArticle 3, point (3): weight in metric tonnes multiplied by the GWP; the Article 5 and 6 thresholds are read on that figure.
• Compare the GWP with the applicable Article 13 limit2 500 from 1 January 2025 for any refrigeration equipment, 750 from 1 January 2032 for stationary equipment other than chillers.
• Check whether a leakage detection system is mandatoryArticle 6(1): 500 tonnes of CO2 equivalent or 100 kg of Section 1 Annex II gases; the system itself is checked at least every 12 months, paragraph 3.
• Open the equipment record before the first interventionArticle 7(1), points (a) to (g); kept at least 5 years by the operator and by the servicing undertaking, paragraph 2.
• Prepare the evidence if you rely on a safety requirementArticle 13(19) and (20) for points 4 and 5(c), plus the label required by Article 12(15).
• Confirm that recovery is planned for decommissioningArticle 8(1) and (2), point (a): the cooling circuits, by persons certified under Article 10.

Frequently asked questions

Official sources

Annex IV points 3 to 6 and Articles 3, 5, 6, 7, 8, 11, 12 and 13 were read in the Official Journal text. The official language versions were consulted for terminology.

How current this page is, and its limits

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 refrigeration equipment containing fluorinated greenhouse gases may only be carried out by personnel certified under Article 10. CO2 systems work at high pressure and hydrocarbons are flammable: both require specific procedures on site.