Short answer
The basic rule is a marketing condition, not a recommendation.
The following products and equipment that contain fluorinated greenhouse gases or whose functioning relies upon those gases shall only be placed on the market, subsequently supplied or made available to any other person, if they are labelled.
- What the label says comes from Article 12(3): an indication that the equipment contains fluorinated greenhouse gases or that its functioning relies upon such gases, the accepted industry designation of the gas or the chemical name, and the quantity expressed in weight and in CO2 equivalent, together with the global warming potential.
- How it is written comes from Implementing Regulation (EU) 2024/2174: the text "contains fluorinated greenhouse gases" in Article 1(3), and the units in Article 1(4).
- Where it goes and in which language comes from Article 12(4): adjacent to the service ports for charging or recovering the gas, or on the part that contains the gas, clearly legible and indelible, written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied.
Not the special texts for cylinders and other containers in Article 12(7) to (14): those are covered in the guide to the documents that travel with a cylinder. Nor any font size, colour or dimension that the acts do not state, and no national marking requirements.
Which equipment must be labelled
Article 12(1) lists nine categories. For a refrigeration contractor, the first five and the last are the ones that matter.
- point (a) refrigeration equipment;
- point (b) air-conditioning equipment;
- point (c) heat pumps;
- point (d) fire protection equipment;
- point (e) electrical switchgear;
- point (i) organic Rankine cycles.
Points (f), (g) and (h) cover aerosol dispensers, including metered dose inhalers, all containers of fluorinated greenhouse gases, and fluorinated greenhouse gas-based solvents. Containers have a regime of their own, with the special texts in paragraphs 7 to 14, dealt with separately.
The condition attaches to three distinct operations, not only to the first sale: placing on the market, subsequent supply and making available to any other person. A unit sitting in stock and resold later therefore has to carry a compliant label.
Two further categories have their own rules in the same article. Paragraph 5 provides that foams and pre-blended polyols containing fluorinated greenhouse gases listed in Annexes I and II shall not be placed on the market, made available or supplied unless the gases are identified with a label using the accepted industry designation or, if none is available, the chemical name, and that in the case of foam panels and laminated boards that information shall be clearly and indelibly stated on the panels or boards. Article 1(8) of Regulation (EU) 2024/2174 adds, for the equipment in points (a), (b) and (c) insulated with foam blown with fluorinated greenhouse gases, a label with the text "Foam contains fluorinated greenhouse gases".
The mandatory content, line by line
Article 12(3) has three tiers: information always required, information required where applicable, and a relabelling rule.
| Information | Source | Note |
|---|---|---|
| An indication that the product contains fluorinated greenhouse gases or that its functioning relies upon them | Article 12(3), point (a) | The actual wording: "contains fluorinated greenhouse gases", Article 1(3) of Regulation (EU) 2024/2174 |
| The accepted industry designation of the gas | Article 12(3), point (b) | Or the chemical name, if no such designation is available |
| The quantity in weight and in CO2 equivalent, plus the GWP | Article 12(3), point (c) | The quantity contained, or the quantity for which the equipment is designed |
| A reference to hermetically sealed equipment | Article 12(3), second subparagraph, point (a) | Only where applicable; the definition is in Article 3, point (9) |
| A tested leakage rate of less than 0,1 % per year for electrical switchgear | Article 12(3), second subparagraph, point (b) | As set out in the manufacturer's technical specification |
The units are fixed by the implementing act, not by the Regulation. Article 1(4) of Regulation (EU) 2024/2174: information on the weight shall be expressed in kilogram or gram and the CO2 equivalent shall be expressed in tonne, using the global warming potential values listed in the column "GWP" in Annexes I, II and III to Regulation (EU) 2024/573.
That gives a simple check on goods inwards: if the nameplate shows only a mass in kilograms, without the tonnes of CO2 equivalent and without the GWP, the label is incomplete. How the CO2 equivalent is worked out is explained in the CO2 equivalent guide.
Relabelling after a retrofit. The third subparagraph of paragraph 3: where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, they shall be relabelled with updated information. What that means for the conversion job is set out in the drop-in and retrofit guide.
Gas added on site: the space left on the label
The rule most often overlooked addresses exactly the situation on site: the unit arrives pre-charged from the factory and the circuit is topped up at installation.
When equipment is pre-charged with, or when its functioning relies upon, fluorinated greenhouse gases and such gases may be added outside the manufacturing site and the resulting total quantity is not indicated by the manufacturer, the label shall contain the quantity charged at the manufacturing site, or the quantity for which the equipment is designed, and shall provide space for the quantity added outside the manufacturing site, as well as for the resulting total quantity of fluorinated greenhouse gases to be inserted by the supplier or, where applicable, the installer of the equipment prior to putting the equipment into operation.
Three practical consequences, all of them written in the text.
- The manufacturer leaves the space. The label must provide room for two further figures: the quantity added outside the factory and the resulting total.
- The supplier or the installer fills it in. The text names them expressly as the persons who insert the values.
- The moment is before the equipment is put into operation. Not at the first service, not at the first leak check.
The total obtained this way does not stay on the label. It is also the basis for classifying the equipment against the leak-check thresholds, because Article 5 uses tonnes of CO2 equivalent and kilograms as thresholds. The resulting frequencies are in the leak check frequency guide, and the data that goes into the equipment record is in the equipment records guide.
Selling such pre-charged equipment to an end user adds the evidence condition of Article 11(7), explained in the guide on selling to end users.
Form, legibility, placement, language
Article 12(4) imposes three qualities and two possible locations.
- Clearly legible and indelible. The first requirement of the paragraph.
- Placement: either adjacent to the service ports for charging or recovering the fluorinated greenhouse gas, point (a), or on that part of the product or equipment that contains the gas, point (b).
- Language: the label shall be written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied. Not that of the country of manufacture, and not that of the country of despatch.
The implementing regulation adds visibility and durability requirements:
| Requirement | Legal basis | What it means in practice |
|---|---|---|
| Sufficient contrast and size | Article 1(1) | The information shall stand out clearly from the background; where it is added to an existing label, the font size shall not be smaller than the minimum size of other information on that label or on existing nameplates |
| Durability over time | Article 1(2) | The label remains securely in place and legible under normal operational conditions, at the time of the placing on the market and throughout the period during which the equipment contains the gases |
| Placement next to existing nameplates | Article 1(9) | Article 12(4) of the Regulation applies and, where possible, adjacent to existing nameplates or product information labels |
| Integration with the CLP label | Article 1(6) | Where the product must also be labelled under Regulation (EC) No 1272/2008, the information is indicated in the section for supplemental information on the label referred to in Article 25 of that Regulation |
For small products there is a release valve, but only for certain categories. Article 1(10) allows, for products under Article 12(1), points (f) to (h), whose size does not allow the legibility of the full information, the text "Contains fluorinated greenhouse gases" in the languages already used on the product to be complemented by a digitally readable link to the information in Article 12(3), points (b) and (c). Note that points (a) to (e) and (i), that is refrigeration equipment, air-conditioning equipment, heat pumps, fire protection equipment, switchgear and organic Rankine cycles, do not benefit from that derogation.
Extra mentions, manuals and advertising
On top of the basic content, Article 12 requires additional mentions in precise situations.
Exemptions. Paragraph 2: products or equipment subject to an exemption referred to in Article 11(5), as well as those containing gases listed in Section 1 of Annex I subject to an exemption referred to in Article 16(4), shall be labelled accordingly, specifying the end date of the exemption, and shall include a reference that they may only be used for the purpose for which the exemption was granted.
Safety requirements. Paragraph 15 requires that, in the cases listed there from Annex IV, the product or equipment be labelled with an indication that it shall be used only where required by the safety requirements or national safety standards, as applicable, and that those requirements or standards be specified on the label. Article 1(12) of Regulation (EU) 2024/2174 gives the exact texts, applicable from the dates of prohibition specified in Annex IV. For the equipment listed in point (a) of that paragraph, the text is "Prohibited to be operated, unless required by safety requirements that have to be applied at the site of operation", complemented by a reference to the applicable safety requirement or, where it is not feasible to specify it before placing on the market, by space on the label for the supplier, installer or operator to insert it before the equipment is put into operation.
Manuals and advertising. Paragraph 16 has two distinct subparagraphs:
- the information referred to in paragraphs 3 and 5 shall be included in the instruction manuals for the products and equipment concerned;
- in the case of products and equipment that contain fluorinated greenhouse gases listed in Annexes I and II with a global warming potential of 150 or more, that information shall also be included in descriptions used for advertising.
The second subparagraph turns a product requirement into a catalogue and online listing requirement. A listing for equipment with R-410A or R-134a falls under it; by contrast, refrigerants with a GWP below the threshold do not trigger it. The regulatory status of each gas is summarised in the product pages, for instance R-410A and R-32.
Finally, paragraphs 17 and 18 explain why the detail of form sits in a separate act: the Commission may, by implementing acts, determine the format of the labels referred to in paragraph 1 and paragraphs 4 to 15, and is empowered to adopt delegated acts to amend the labelling requirements in paragraphs 4 to 15 in view of commercial or technological development.
When these rules started to apply
Dates matter, because a unit in stock may carry a label drawn up under the previous regime.
| Date | What happens | Legal basis |
|---|---|---|
| Until 31 December 2024 | Article 12 of Regulation (EU) No 517/2014, as applicable on 10 March 2024, continued to apply | Article 37(2) of Regulation (EU) 2024/573 |
| 1 January 2025 | Article 12 of Regulation (EU) 2024/573 applies | Article 38, second paragraph |
| 1 January 2025 | Implementing Regulation (EU) 2024/2174 applies | Article 3 of that Regulation |
| From the dates in Annex IV | The texts of Article 1(12) of Regulation (EU) 2024/2174 are added | Article 12(15) and Article 1(12) |
Implementing Regulation (EU) 2024/2174 was adopted on 2 September 2024 and published on 3 September 2024; Article 3 provides that it enters into force on the twentieth day following publication and applies from 1 January 2025. Article 2 repeals Implementing Regulation (EU) 2015/2068, and references to it are to be read as references to the new act in accordance with the correlation table in the Annex.
Recital 7 of the implementing regulation records that enforcement should take into consideration the regulatory processes for changing existing labelling requirements or the process of re-labelling equipment or products already placed on the EU market. A recital creates no derogation, but it explains the approach.
If the label on a delivered unit does not match the documents that came with it, the verification route is the same as for cylinders: see what to do when the label does not match the safety data sheet.
Label check
- Look for the mandatory text'contains fluorinated greenhouse gases', Article 1(3) of Regulation (EU) 2024/2174.
- Check the gas designationArticle 12(3), point (b): the accepted industry designation or, failing that, the chemical name.
- Check the three figuresWeight, CO2 equivalent and GWP, under Article 12(3), point (c).
- Check the unitsKilogram or gram for weight and tonne for CO2 equivalent, Article 1(4) of Regulation (EU) 2024/2174.
- Look for the space for the added quantityArticle 1(5): completed by the supplier or the installer before the equipment is put into operation.
- Check the hermetically sealed referenceArticle 12(3), second subparagraph, point (a), where applicable.
- Check the languageArticle 12(4), second subparagraph: the official languages of the Member State of placing on the market, making available or supply.
- Check the placementArticle 12(4), points (a) and (b); Article 1(9) of Regulation (EU) 2024/2174.
- Check the manualArticle 12(16), first subparagraph: the information in paragraphs 3 and 5 goes into the instruction manuals.
- Check the advertising descriptionsArticle 12(16), second subparagraph, for gases with a GWP of 150 or more.
- Relabel after a retrofitArticle 12(3), third subparagraph: updated information once the gas has been changed.
Frequently asked questions
Is the exact wording 'contains fluorinated greenhouse gases' compulsory?
Yes. Article 1(3) of Implementing Regulation (EU) 2024/2174 provides that the label shall include that text. Article 12(3), point (a), of the Regulation requires an indication that the product contains fluorinated greenhouse gases or that its functioning relies upon them; the implementing act fixes the wording.
Can the label be in English only?
Not if the official language of the Member State concerned is another one. Article 12(4), second subparagraph, requires the label to be written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied.
Who fills in the quantity added at installation?
Article 1(5) of Regulation (EU) 2024/2174 names them expressly: the supplier or, where applicable, the installer of the equipment, prior to putting the equipment into operation. The manufacturer only has to provide the space on the label.
Can a very small appliance carry just a code to scan?
Only for certain categories. Article 1(10) of Regulation (EU) 2024/2174 allows the text to be complemented by a digitally readable link only for the products in Article 12(1), points (f) to (h). Refrigeration equipment, air-conditioning equipment and heat pumps are not covered by that derogation.
Do I have to relabel after a refrigerant conversion?
Yes. Article 12(3), third subparagraph, provides that where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, those products or equipment shall be relabelled with updated information.
What happens if a unit arrives without a label?
Article 12(1) makes placing on the market, supplying and making available conditional on the label, so the goods cannot be passed on in that state. Penalties are national, in the structure described in the penalties guide.
Official sources
Article 12 was read in full, paragraph by paragraph, together with Article 1 of the implementing regulation on the format of the labels. The repealed act is cited only for the reference in the correlation table.
How current this page is, and the limits of our liability
This page reproduces the European labelling requirements for equipment. It does not cover container labelling, national marking requirements, CE marking requirements arising from other acts, or hazardous substance duties beyond the reference made by the implementing regulation itself.
General information prepared by EgoLog on the basis of Regulation (EU) 2024/573 and Implementing Regulation (EU) 2024/2174. It is not legal advice.
Annex IV and the labelling requirements may be amended by delegated acts under Article 12(18). Check the text in force before ordering labels or nameplates for a production run.