Quick answer
Regulation (EU) 2024/573 replaced Regulation (EU) No 517/2014 and it does not contain one ban. It contains three families of ban, and they hit different people on different dates.
- Placing on the market — Article 11(1) and Annex IV. Concerns whoever first sells or supplies a product or piece of equipment in the Union.
- Use for maintenance or servicing — Article 13(3), (4) and (5). Concerns the technician standing in front of the machine with a cylinder.
- Putting into operation — Article 13(9) and 13(19). Concerns the operator commissioning equipment.
For a refrigeration company the one that bites first is the servicing ban. Since 1 January 2025 a fluorinated gas with a GWP of 2 500 or more may not be used to maintain or service any refrigeration equipment — that is R-404A and R-507A off the van, unless the gas is reclaimed or recycled and the conditions below are met.
Regulation (EU) No 517/2014 was repealed. Quoting its article numbers in a tender, a service report or a customer letter now points at a text that no longer applies.
The three bans, side by side
Almost every argument on site comes from mixing these up. A gas that may no longer be charged can still be perfectly legal inside a running plant, and equipment that may no longer be sold can still be repaired.
| Ban | Where | Who it binds | What it forbids |
|---|---|---|---|
| Placing on the market | Article 11(1) + Annex IV | Manufacturer, importer, first supplier | Making the listed product or equipment available in the Union for the first time, from the date in Annex IV. |
| Use for servicing | Article 13(3)–(5) | Whoever charges the gas | Using a gas above a GWP threshold to maintain or service equipment already installed. |
| Putting into operation | Article 13(9), 13(19) | Operator | Commissioning listed equipment after its date, unless one of two proofs is held. |
What none of them forbid: continuing to run equipment that is already installed and charged. There is no article in the regulation that orders a working plant to be shut down because of its refrigerant.
The servicing bans — Article 13
This is the part a service company has to know by heart, because it changes what may be loaded into the vehicle.
| From | Equipment | Gas that may no longer be used |
|---|---|---|
| Already applied | Refrigeration equipment with a charge of 40 t CO2e or more | GWP 2 500 or more (Article 13(3), first sentence) |
| 1 January 2025 | Any refrigeration equipment, whatever the charge | GWP 2 500 or more (Article 13(3), second sentence) |
| 1 January 2026 | Air conditioning equipment and heat pumps | GWP 2 500 or more, Annex I gases (Article 13(4)) |
| 1 January 2032 | Stationary refrigeration equipment, chillers excluded | GWP 750 or more, Annex I gases (Article 13(5)) |
| 1 January 2035 | Electrical switchgear | SF6, unless reclaimed or recycled (Article 13(7)) |
Article 13(3) does not apply to military equipment or to equipment designed to cool products below −50 °C. Article 13(5) adds a third exclusion: equipment designed to cool nuclear power stations.
The bans in Article 13(3) and 13(4) do not apply to reclaimed gas — until 1 January 2030 for refrigeration and 1 January 2032 for air conditioning and heat pumps — provided the container is labelled in accordance with Article 12(7). Nor to recycled gas over the same periods, but with a much tighter condition: the recycled gas has to have been recovered from that kind of equipment, and it may only be used by the undertaking that recovered it, or by the undertaking on whose behalf the recovery was carried out.
In practice: recycled gas is not a commodity you can buy in. It stays inside the relationship between the recovering company and its own customer. Reclaimed gas is different — it can be bought, and the label is what proves it.
Which side of the line is your gas on
The thresholds are 2 500 and 750. Pure substances take their GWP from Annex I. Blends are not listed one by one — their GWP is calculated under Annex VI as the weighted average of the components, using the same Annex I values.
| Gas | GWP | Servicing refrigeration (2 500 line, applies now) | Stationary refrigeration from 2032 (750 line) |
|---|---|---|---|
| R-32 | 675 (Annex I) | Allowed | Allowed |
| R-134a | 1 430 (Annex I) | Allowed | Banned |
| R-407C | ≈ 1 774 (calculated) | Allowed | Banned |
| R-410A | ≈ 2 088 (calculated) | Allowed | Banned |
| R-404A | ≈ 3 922 (calculated) | Banned | Banned |
| R-507A | ≈ 3 985 (calculated) | Banned | Banned |
The calculated figures use the nominal composition of each blend and the binding Annex I values: R-404A as 44 % R-125, 52 % R-143a and 4 % R-134a gives (0.44 × 3 500) + (0.52 × 4 470) + (0.04 × 1 430) ≈ 3 922. Annex VI allows a weight tolerance of ± 1 %, so a supplier's declared value may differ slightly. Where a figure matters, take it from the product's own documentation or label.
The second column is headed “20 years-GWP — for information purposes only”. It is not the value the thresholds are measured against. Using it inflates the result several times over and can put a perfectly legal gas on the wrong side of a line.
Annex IV — what may no longer be placed on the market
Annex IV is a list of products and equipment with a date next to each. From that date the item may not be placed on the Union market. These are the rows a refrigeration and air conditioning business meets most often.
| Annex IV point | Equipment | Date |
|---|---|---|
| 1 | Non-refillable containers for Annex I gases, empty or filled | 4 July 2007 |
| 3(c) | Commercial self-contained refrigerators and freezers, other F-gases with GWP 150 or more | 1 January 2025 |
| 4 | Any self-contained refrigeration equipment except chillers, F-gas with GWP 150 or more | 1 January 2025 |
| 5(b) | Other refrigeration equipment (not chillers, not points 4 and 6), GWP 2 500 or more | 1 January 2025 |
| 5(c) | The same equipment, GWP 150 or more | 1 January 2030 |
| 6 | Multipack centralised commercial systems of 40 kW or more, Annex I gases with GWP 150 or more | 1 January 2022 |
| 2(b) | Domestic refrigerators and freezers containing F-gases | 1 January 2026 |
| 11(c) | Fire protection equipment with other Annex I gases | 1 January 2025 |
Several rows carry the words “except if required to meet safety requirements at the site of operation”. That is a narrow exception tied to the specific installation, not a general escape clause, and Article 13(19) requires the operator to be able to prove it.
Point 6 keeps one opening: in the primary refrigerant circuit of a cascade system, gases with a GWP below 1 500 may still be used.
Splits, monoblocs and chillers — the dates that decide your next quote
Points 7, 8 and 9 of Annex IV are where most equipment offers land. They are cut by rated capacity, so the same brand can be on both sides of a date.
| Equipment | Limit | Date |
|---|---|---|
| Chillers up to and including 12 kW | GWP 150 or more | 1 January 2027 |
| Chillers up to and including 12 kW | Any F-gas | 1 January 2032 |
| Chillers above 12 kW | GWP limit of 750 | 1 January 2027 |
| Self-contained AC and heat pumps up to and including 12 kW | GWP 150 or more (750 where safety requires) | 1 January 2027 |
| Monobloc and self-contained AC and heat pumps above 12 kW to 50 kW | GWP 150 or more | 1 January 2027 |
| Other self-contained AC and heat pumps | GWP 150 or more | 1 January 2030 |
| Single split systems with less than 3 kg of Annex I gases | GWP 750 or more | 1 January 2025 |
| Split air-to-water up to and including 12 kW | GWP 150 or more | 1 January 2027 |
| Split air-to-air up to and including 12 kW | GWP 150 or more | 1 January 2029 |
| Split systems above 12 kW | GWP 750 or more | 1 January 2029 |
| Split systems above 12 kW | GWP 150 or more | 1 January 2033 |
| Split systems up to and including 12 kW | Any F-gas | 1 January 2035 |
A footnote to Annex IV states that fixed double duct heat pump and air conditioning equipment is treated as split equipment — category 9 — and is subject to the same requirements.
The 1 January 2025 line on single splits is the one already behind us: below 3 kg of Annex I gas, a GWP of 750 or more is out. R-410A at roughly 2 088 does not pass; R-32 at 675 does.
Repair and servicing parts are not caught
Article 11(1) contains a derogation that is easy to miss and worth a great deal in practice. Parts of products and equipment listed in Annex IV may still be placed on the market where they are needed to repair or service existing equipment.
The condition is that the repair or servicing must not result in:
- an increase in the capacity of the product or equipment;
- an increase in the amount of fluorinated greenhouse gas it contains; or
- a change in the type of gas used that would raise the GWP of the gas used.
So a compressor for a machine already in service is fine. The same compressor built into a new unit is not. And a “repair” that quietly upsizes the plant, adds charge or swaps to a higher-GWP gas has stepped outside the derogation.
The parts derogation is about placing on the market. The gas you put in during that same job is judged separately, under Article 13. A legal spare part charged with an illegal gas is still an illegal job.
Stock on the shelf, and equipment already bought
Two rules govern what happens to goods that were legal when they arrived.
The one-year evidence rule. One year after each individual Annex IV date, supplying or making available a product or piece of equipment that was lawfully placed on the market before that date is allowed only if evidence is provided that it was placed lawfully on the market before the date. In other words: the stock does not become illegal, but after twelve months the burden of proof sits with you. Purchase invoices, customs records and serial-number documentation are what carry it.
Goods placed unlawfully. Article 11(1) is blunt about these. They may not subsequently be used, supplied or made available to anyone in the Union, for payment or free of charge, and may not be exported. They may only be stored or transported for disposal and for recovery of the gas before disposal, or re-exported where the non-compliance was established before release for free circulation.
Putting into operation. Article 13(19) closes the last gap. For a specific list of Annex IV points — including 4, 5(c), 7(b) to (d), 8(b) to (e), 9(b) to (f), 11(c) and 2(b) — commissioning or using the equipment after the prohibition date is itself prohibited, unless the operator can show either that safety requirements at that particular location do not permit lower-GWP equipment, or that the equipment was placed on the market before the date. Article 13(20) requires that documentation to be kept for at least five years and produced on request.
What to do about it now
List your installed base by refrigerant
Every contract site, with the gas and the charge in kilograms. Without this list none of the dates below can be answered.
Flag every R-404A and R-507A plant
These can no longer be topped up with virgin gas. Each one needs a decision: retrofit, replace, or run on reclaimed gas while the window lasts.
Check the reclaimed route properly
Reclaimed gas is legal for these plants until 1 January 2030, but only if the container is labelled under Article 12(7). Ask the supplier for that label before you rely on it.
Separate air conditioning and heat pumps
Their 2 500 line starts on 1 January 2026, a year later than refrigeration. Sites with both need two lists.
Put the 750 line in the long-term plan
From 1 January 2032 stationary refrigeration other than chillers loses R-134a, R-407C and R-410A as service gases. Equipment specified today will still be running then.
Review what you sell, not only what you charge
If you supply units as well as service, check each model against the Annex IV point that covers it and its rated capacity.
Keep the evidence file
Invoices for stock bought before a ban date, and the Article 13(19) proof for equipment commissioned after one. Five years minimum.
Common mistakes
- Reading a placing-on-market ban as a shutdown order. Annex IV stops new equipment being sold. It does not order existing plant off.
- Assuming recycled gas can be bought in. It cannot be traded freely: it may only be used by the undertaking that recovered it or the one it recovered for.
- Using the 20-year GWP column. Annex I marks it “for information purposes only”. The thresholds run on the first column.
- Treating a blend as unlisted. Blends are not absent from the regulation — their GWP is calculated under Annex VI.
- Upsizing during a “repair”. The moment capacity, charge or GWP goes up, the parts derogation no longer covers the job.
- Still quoting Regulation (EU) No 517/2014. It was repealed by 2024/573.
- Forgetting the one-year evidence rule. Old stock stays sellable, but after twelve months only with proof of when it was placed on the market.
Checklist
- Installed base listed by gas and chargeSite by site, in kilograms and in tonnes of CO2 equivalent.
- R-404A and R-507A plants identifiedNo virgin top-up since 1 January 2025.
- Reclaimed gas supplier confirmedContainer labelled under Article 12(7); window closes 1 January 2030.
- Air conditioning and heat pumps listed separatelyTheir GWP 2 500 ban starts 1 January 2026.
- 2032 exposure mappedStationary refrigeration other than chillers, on gases with GWP 750 or more.
- Equipment catalogue checked against Annex IVBy category and by rated capacity, not by brand.
- Pre-ban stock documentedEvidence of lawful placing on the market, for the one-year rule.
- Article 13(19) file openSafety justification or pre-ban placing evidence, kept five years.
- Old article references removedNothing in your paperwork still cites Regulation (EU) No 517/2014.
Frequently asked questions
Can I still top up an R-404A system?
Not with virgin gas. Since 1 January 2025, Article 13(3) prohibits using a fluorinated gas with a GWP of 2 500 or more to maintain or service any refrigeration equipment. Reclaimed gas remains possible until 1 January 2030 if the container is labelled under Article 12(7), and recycled gas under the narrower conditions in the same paragraph.
Do I have to shut down existing equipment?
No. The regulation restricts placing on the market, servicing with certain gases, and putting listed equipment into operation. It does not order installed and charged equipment to be decommissioned.
What is the GWP of R-404A?
It is not listed as a single value in Annex I because it is a blend. Calculated under Annex VI from its nominal composition and the binding Annex I values it comes to about 3 922 — above the 2 500 threshold. Take the exact figure from the product documentation, since Annex VI allows a ± 1 % weight tolerance.
Is R-410A affected?
Not by the servicing ban that applies today: at roughly 2 088 it sits below 2 500. It is affected from 1 January 2032, when Article 13(5) bans gases with a GWP of 750 or more for servicing stationary refrigeration other than chillers, and it is already caught by the Annex IV limit on single split systems below 3 kg since 1 January 2025.
Can I still buy spare parts for banned equipment?
Yes. Article 11(1) allows parts needed to repair or service existing equipment, provided the work does not increase the capacity, increase the amount of gas, or change to a gas with a higher GWP.
I have units in stock from before a ban date. Can I sell them?
Yes, but one year after that Annex IV date you must be able to provide evidence that they were lawfully placed on the market before it. Keep the purchase and import documentation.
What happens on 1 January 2026?
Article 13(4) starts: Annex I gases with a GWP of 2 500 or more may no longer be used to maintain or service air conditioning equipment and heat pumps. Reclaimed and recycled gas remain possible until 1 January 2032 under the stated conditions. Annex IV point 2(b) also takes effect that day for domestic refrigerators and freezers containing F-gases.
Does Regulation (EU) No 517/2014 still apply?
No. It was repealed by Regulation (EU) 2024/573. Certificates and training attestations issued under it remain valid on their original conditions, but the obligations themselves now come from the new regulation.
Official sources
Article 11, Article 13 and Annex IV were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
Annex IV can be amended and the Commission may authorise time-limited exemptions under Article 11(5). The article references here were checked on the verification date shown at the top of the page. Confirm the current text before you rely on a date commercially.
This is general information prepared by EgoLog from the regulation and official Commission material. It is not legal advice and it does not replace an assessment of your own installation.
Whether a specific machine falls under a specific Annex IV point depends on its category, its rated capacity and its charge. Where it is unclear, ask your national competent authority before ordering rather than after installing.