Quick answer
“Drop-in” and “retrofit” are trade words. Neither appears as a defined term in Regulation (EU) 2024/573, and arguing about which one a job is does not answer any legal question.
What the regulation does is set three conditions and attach a set of consequences. Get the conditions right and the parts you need stay available. Get the consequences done and the file is closed properly.
| The three conditions — Article 11(1) |
|---|
| The repair or servicing must not increase the capacity of the product or equipment. |
| It must not increase the amount of fluorinated greenhouse gas the product or equipment contains. |
| It must not change the type of gas in a way that would raise the GWP of the gas used. |
Those conditions govern one thing precisely: whether parts of products and equipment listed in Annex IV may still be placed on the market for the job. Meet them and the parts are available. Break any one of them and the derogation no longer covers what you are doing.
The GWP condition is one-way. Moving to a lower GWP is entirely consistent with it. Moving to a higher one is not.
What a gas change triggers
Once the gas in a machine changes, four separate provisions come into play. None of them depends on what the job is called.
| Provision | What it requires |
|---|---|
| Article 12(3), last subparagraph | Where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, they must be relabelled with updated information. |
| Article 5(6) | The leak-check interval runs on the charge in tonnes of CO2 equivalent — kilograms × GWP ÷ 1 000. A new GWP means a new figure and possibly a new interval. |
| Article 6(1) | A leakage detection system is mandatory for the equipment in Article 5(2)(a) to (d) at 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kg or more of Annex II Section 1 gases. |
| Article 7(1) | The equipment record has to carry the new quantity and type, the quantities added with dates, the quantity recovered, the origin of any added gas, and the identity of the undertaking and person who did the work. |
Dropping the GWP lowers the tonnes of CO2 equivalent and can lengthen the interval or remove the detector requirement. Raising the charge on the same gas does the opposite. Recalculate rather than assume, and write the new figure into the record.
What happens to the gas that comes out
The charge you remove is not a by-product of the job — it carries its own obligations.
- It must be recovered. Article 8(1) requires operators of equipment containing fluorinated greenhouse gases to ensure the substances are recovered, and that recovery is carried out by natural persons holding the relevant certificates under Article 10.
- It may not be vented. Article 4(1) prohibits intentional release into the atmosphere where the release is not technically necessary for the intended use.
- It may not go straight into another machine. Article 8(6): recovered gases listed in Annex I and Section 1 of Annex II shall not be used for filling or refilling equipment unless the gas has been recycled or reclaimed.
- The quantity goes in the record. Article 7(1)(c).
If the machine you are converting is on a gas above the Article 13 thresholds, this is also the moment the old charge stops being an asset. R-404A recovered from a plant cannot go back into the next one, and cannot be sold on as recycled gas — Article 13 confines recycled gas above the threshold to the undertaking that recovered it or the one it recovered for.
Choosing what goes in
The regulation constrains the target in two ways, and both should be checked before the parts are ordered.
The servicing bans. Article 13(3) prohibits gases with a GWP of 2 500 or more for maintaining or servicing any refrigeration equipment, since 1 January 2025. Article 13(4) does the same for air conditioning and heat pumps from 1 January 2026. Article 13(5) drops the line to 750 for stationary refrigeration other than chillers from 1 January 2032.
The Article 11(1) GWP condition. The replacement must not raise the GWP of the gas used. In practice a conversion moves downwards anyway — but a like-for-like swap between two similar blends is worth checking rather than assuming.
Whether the compressor, the oil, the expansion device, the pressure ratings and the capacity actually suit the new refrigerant is an engineering question. The manufacturer's documentation answers it. A conversion that is lawful and technically wrong is still a failed job.
If the target is a hydrocarbon, CO2 or ammonia, the certification changes as well: Implementing Regulation (EU) 2024/2215 puts hydrocarbons inside Certificates A1 and A2, CO2 in Certificate B and ammonia in Certificate C.
Doing it in the right order
Weigh and record the existing charge before you start
The old figure is what the new tonnes of CO2 equivalent will be compared against, and the record needs both.
Confirm the target clears the Article 13 line that applies
2 500 today for refrigeration and, from 1 January 2026, for air conditioning and heat pumps; 750 from 2032 for stationary refrigeration other than chillers.
Check the job against the three Article 11(1) conditions
No capacity increase, no charge increase, no GWP increase — otherwise the parts derogation does not cover it.
Get the manufacturer's position in writing
Component ratings, oil compatibility and capacity are not regulatory questions, and the answer belongs in the job file.
Recover the old charge with the right certificate
Article 8(1), by a certified person, and record the quantity under Article 7(1)(c).
Recalculate the tonnes of CO2 equivalent
New kilograms × new GWP ÷ 1 000, then re-read Article 5(6) for the interval and Article 6(1) for the detector.
Relabel before you leave
Article 12(3) requires updated information after a retrofit that changes the gas. Doing it on the next visit means the machine is mislabelled in between.
Close the record
New quantity and type, quantities added with dates, origin of the gas, the undertaking and the person, and the new check interval.
Common mistakes
- Arguing about the label “drop-in”. The regulation tests capacity, charge and GWP, not the vocabulary.
- Topping up the charge during the conversion. An increase in the amount of gas takes the job outside the Article 11(1) derogation.
- Moving to a higher-GWP gas. The third condition is explicitly one-way.
- Leaving the old label on. Article 12(3) requires relabelling with updated information.
- Keeping the old check interval. The interval follows tonnes of CO2 equivalent, which changed with the GWP.
- Not re-answering the detector question. Article 6(1) makes a leakage detection system mandatory at 500 t CO2e or more.
- Putting the recovered gas back in. Article 8(6) requires recycling or reclamation first.
- Recording only the new gas. Article 7(1) wants the recovered quantity as well as the added one.
- Treating manufacturer approval as optional because the law does not mention it. The regulation governs legality, not whether the machine will run.
Checklist
- Existing charge weighed and recordedKilograms and tonnes of CO2 equivalent before the change.
- Target gas clears the applicable Article 13 threshold2 500 now; 750 from 2032 for stationary refrigeration other than chillers.
- No capacity increaseFirst Article 11(1) condition.
- No increase in the amount of gasSecond condition.
- No increase in GWPThird condition.
- Manufacturer position on fileComponents, oil, pressures, capacity.
- Old charge recovered by a certified personArticle 8(1); quantity recorded under Article 7(1)(c).
- New tonnes of CO2 equivalent calculatedNew interval under Article 5(6); Article 6(1) detector question re-answered.
- Equipment relabelledArticle 12(3), before leaving site.
- Record completedQuantity and type, dates, origin of gas, undertaking and person.
Frequently asked questions
Does the regulation define “drop-in”?
No. Neither “drop-in” nor a general definition of “retrofit” appears as a defined term. Article 12(3) uses the word “retrofitted” once, to trigger relabelling where the fluorinated greenhouse gases have been changed.
Can I still get parts for equipment listed in Annex IV?
Yes, where they are needed to repair or service existing equipment, provided the work does not increase the capacity, increase the amount of fluorinated greenhouse gas, or change to a gas with a higher GWP. That is the derogation in Article 11(1).
Can I add a little more gas while I am there?
Not without leaving the derogation. The second condition in Article 11(1) is that the work must not increase the amount of fluorinated greenhouse gas contained in the product or equipment.
Do I have to relabel after a conversion?
Yes, where the fluorinated greenhouse gases have been changed. The last subparagraph of Article 12(3) requires relabelling with updated information.
Does the leak-check interval change?
It can. Article 5(6) sets the interval by charge in tonnes of CO2 equivalent, which is kilograms × GWP ÷ 1 000. A different GWP gives a different figure and possibly a different band.
What about the leakage detection system?
Article 6(1) makes one mandatory for the equipment in Article 5(2), points (a) to (d), containing 500 tonnes of CO2 equivalent or more of Annex I gases, or 100 kg or more of Annex II Section 1 gases. A conversion can move a plant across that line in either direction.
Can I reuse the gas I recovered?
Not as it is. Article 8(6) prohibits using recovered gases listed in Annex I and Section 1 of Annex II to fill or refill equipment unless the gas has been recycled or reclaimed.
Does the regulation say whether the conversion will work technically?
No. It governs what is permitted. Component ratings, oil compatibility, pressures and capacity are answered by the equipment manufacturer's documentation.
Official sources
Articles 4, 5, 6, 7, 8, 10, 11, 12 and 13 were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
This guide covers the regulatory side of a gas change. Whether a specific conversion is technically sound — components, oil, pressures, capacity and the safety assessment of the installation — is answered by the equipment manufacturer's documentation and takes precedence over anything here.
This is general information prepared by EgoLog from the regulation and official Commission material. It is not legal advice and it is not an engineering assessment.
Manufacturer approval and warranty conditions are contractual matters between you, the customer and the manufacturer. The regulation does not address them.