Short answer
For an installer, Annex IV reads in three steps. First decide whether the equipment is self-contained (point 8) or split (point 9). Then find the rated capacity band. Only then compare the GWP of the refrigerant with the limit in that row.
- Single split systems containing less than 3 kg of Annex I gases can no longer be placed on the market from 1 January 2025 if they use Annex I gases with a GWP of 750 or more — Annex IV, point 9(a). That row has no safety exception.
- Split systems up to and including 12 kW lose gases with a GWP of 150 or more on 1 January 2027 if they are air-to-water and on 1 January 2029 if they are air-to-air; every fluorinated greenhouse gas goes on 1 January 2035.
- Split systems above 12 kW lose gases with a GWP of 750 or more on 1 January 2029 and gases with a GWP of 150 or more on 1 January 2033.
- Self-contained and monobloc equipment up to and including 12 kW stops on 1 January 2027 for a GWP of 150 or more, with a fallback limit of 750 where safety requirements do not allow less.
The prohibition bites on placing on the market, not on use. A unit lawfully placed on the market before the date stays lawful to run and to service, within the limits of Article 13.
No prices, no availability, no product recommendations, no delivery times. No national penalties and no dangerous-goods figures either. The choice between R-32 and R-410A is handled in R-32 or R-410A, and the general list of dates in the F-gas ban timetable.
What placing on the market actually means
Article 3, point (6) defines placing on the market as customs release for free circulation in the Union, or the supplying or making available to another person within the Union for the first time, for payment or free of charge, or the use of substances produced or equipment manufactured for own use. It is not the installation date, not the invoice date to the end customer and not the commissioning date.
Article 11(1), first subparagraph prohibits the placing on the market of the products and equipment listed in Annex IV, including parts thereof, with an exemption for military equipment, from the date specified in that Annex, differentiating where applicable according to the type or global warming potential of the gas contained.
The second subparagraph keeps spare parts alive: the placing on the market of parts required for repair and servicing of existing equipment listed in Annex IV is allowed provided the repair or servicing does not result in an increase in the capacity of the equipment, an increase in the amount of fluorinated greenhouse gas contained in it, or a change in the type of gas used that would lead to an increase of the GWP.
The fifth subparagraph is the one that catches distributors: one year following the individual dates listed in Annex IV, the subsequent supply or making available to another person in the Union of products lawfully placed on the market before the date shall be allowed only if evidence is provided that the product was placed lawfully on the market before that date. The burden of proof moves to whoever sells the stock.
Two further valves exist. Article 11(2): the prohibition does not apply to equipment for which it has been established, pursuant to ecodesign requirements adopted under Directive 2009/125/EC, that its lifecycle CO2 equivalent emissions would be lower than those of equivalent equipment meeting those requirements. Article 11(5): following a substantiated request by a competent authority, the Commission may exceptionally authorise, by implementing acts, an exemption for up to 4 years where alternatives are not available or cannot be used for technical or safety reasons, or where technically feasible and safe alternatives would entail disproportionate costs.
Point 8: self-contained, monobloc and plug-in equipment
Point 8 of Annex IV covers self-contained air-conditioning equipment and heat pumps, except chillers. Article 3, point (38) defines the term: 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. If a technician makes the refrigerant connection on site, you are not in point 8.
| Annex IV point | Equipment | GWP limit | Date of prohibition |
|---|---|---|---|
| 8(a) | Plug-in room air-conditioning equipment which is moveable between rooms by the end user | HFCs with a GWP of 150 or more | 1 January 2020 |
| 8(b) | Plug-in room, monobloc, other self-contained air-conditioning equipment and self-contained heat pumps, maximum rated capacity up to and including 12 kW | A GWP of 150 or more; where safety requirements at the site of operation would not allow less than 150, the limit is 750 | 1 January 2027 |
| 8(c) | The same categories, up to and including 12 kW | Any fluorinated greenhouse gas; where safety requirements would not allow alternatives, the limit is 750 | 1 January 2032 |
| 8(d) | Monobloc and other self-contained air-conditioning equipment and heat pumps, more than 12 kW but not exceeding 50 kW | A GWP of 150 or more; fallback limit 750 on safety requirements | 1 January 2027 |
| 8(e) | Other self-contained air-conditioning equipment and heat pumps | A GWP of 150 or more; fallback limit 750 on safety requirements | 1 January 2030 |
Notice the ordering: point (d), the 12 to 50 kW band, falls on the same date as point (b), while point (e), which catches everything else, only arrives in 2030. The capacity band matters more than intuition suggests.
Point 9: split air conditioning and split heat pumps
Article 3, point (39) defines a split system as a system consisting of a number of refrigerant piped units that form a separate but interconnected unit, requiring the installation and connection of refrigerant circuit components at the point of use. The footnote to point 9 adds a line many people miss: for the purposes of the Regulation, fixed double duct heat pump and air-conditioning equipment shall be considered split (category number 9) and be subject to the same requirements.
| Annex IV point | Equipment | GWP limit | Date of prohibition |
|---|---|---|---|
| 9(a) | Single split systems containing less than 3 kg of Annex I gases | Annex I gases with a GWP of 750 or more — no safety exception | 1 January 2025 |
| 9(b) | Split air-to-water systems, rated capacity up to and including 12 kW | A GWP of 150 or more | 1 January 2027 |
| 9(c) | Split air-to-air systems, rated capacity up to and including 12 kW | A GWP of 150 or more | 1 January 2029 |
| 9(d) | Split systems, rated capacity up to and including 12 kW | Any fluorinated greenhouse gas | 1 January 2035 |
| 9(e) | Split systems, rated capacity of more than 12 kW | A GWP of 750 or more | 1 January 2029 |
| 9(f) | Split systems, rated capacity of more than 12 kW | A GWP of 150 or more | 1 January 2033 |
Points (b) to (f) all carry the same closing formula: except if required to meet safety requirements at the site of operation. Point (a) does not. For single splits below 3 kg the 750 line of 1 January 2025 is hard, and it is precisely the line that took R-410A (GWP 2 088 under the Annex VI method) out of that segment and left R-32 (GWP 675, the binding Annex I value).
The status of the two gases is set out on the R-410A and R-32 pages, and the safety consequences of moving to A2L in refrigerant safety classes A1, A2L and A3.
The safety exception: what it is and what it is not
The Annex IV wording is "except if required to meet safety requirements at the site of operation". The term is defined in Article 3, point (42): requirements on the safety of using fluorinated greenhouse gases and natural refrigerants, or products and equipment containing or relying on them, prohibiting the use of certain fluorinated greenhouse gases or their alternatives, including when contained in a product or in equipment 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 the specific location, provided they are in accordance with the relevant law.
Three practical consequences follow.
It is not a preference. There must be a legal requirement or an applicable standard that actually prohibits the alternative at that site. An A2L refrigerant being awkward to install is not a safety requirement.
In point 8 it does not hand you a blank cheque. Points (b) to (e) say it expressly: if safety requirements at the site of operation would not allow fluorinated greenhouse gases with a GWP of less than 150, the GWP limit is 750. The exception moves the threshold, it does not remove it. In point 9(b) to (f) the text stops at the general formula, with no written fallback limit.
It has to be labelled and documented. Article 12(15) requires that in the cases referred to in points 2(b), 4, 5(c), 7(b), (c) and (d), 8(b) to (e), 9(b) to (f), 11(c), 16, 17(a), (b) and (c), and 19(a) and (b) of 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, and that those requirements or standards be specified on the label.
Article 13(19) closes the loop at commissioning: for equipment listed in points 2(b), 4, 5(c), 7(b), (c) and (d), 8(b) to (e), 9(b) to (f), 11(c), 17(c) and 19(b) of Annex IV, putting into operation after the respective prohibition date is prohibited unless the operator can provide evidence either that the relevant safety requirements at the particular location do not permit the installation of equipment using gases below the GWP value specified, or that the equipment was placed on the market before the relevant prohibition date. Article 13(20) requires the documentation to be kept for at least 5 years and made available on request.
What stays legal after the date
The Annex IV date does not empty the sites. It stops one thing only: the first making available in the Union. Around it, the text leaves several doors open.
- Units already with the operator may continue in service. Restrictions on use come from Article 13, not from Annex IV, and they have their own dates.
- Installing a unit lawfully placed on the market before the date is not prohibited by Article 11. For the equipment listed in Article 13(19), the operator must still be able to prove that the equipment was placed on the market before the prohibition date.
- Spare parts remain available under Article 11(1), second subparagraph, on three cumulative conditions: no increase in capacity, no increase in the amount of gas, and no change of gas type towards a higher GWP.
- Reselling stock is possible, but one year after the date it requires evidence of lawful placing on the market before that date — Article 11(1), fifth subparagraph.
Two duties apply in any case at the point of sale. Article 11(7): non-hermetically sealed equipment charged with gases listed in Annex I and in Section 1 of Annex II may only be sold to an end user where evidence is provided that the installation is to be carried out by an undertaking certified in accordance with Article 10. And Article 12(1), points (b) and (c) require air-conditioning equipment and heat pumps to be labelled with the information in Article 12(3): an indication that the equipment contains fluorinated greenhouse gases, the accepted industry designation of the gas and, from 1 January 2017, the quantity expressed in weight and in CO2 equivalent together with the GWP.
The sale side is set out in the guide on selling pre-charged equipment to end users, and the label content in the F-gas equipment label.
How this connects to the servicing bans
Annex IV says what you may still sell. Article 13 says what you may still put into the machine. They are separate calendars and they can collide on the same unit.
Article 13(4), first subparagraph: from 1 January 2026, the use of fluorinated greenhouse gases listed in Annex I with a GWP of 2 500 or more for the maintenance or servicing of air-conditioning equipment and heat pumps is prohibited. The second subparagraph suspends that prohibition until 1 January 2032 for two categories: reclaimed Annex I gases with a GWP of 2 500 or more used on existing equipment, provided the containers have been labelled in accordance with Article 12(7); and recycled Annex I gases with a GWP of 2 500 or more, provided they were recovered from such equipment, and used only by the undertaking that carried out the recovery as part of maintenance or servicing, or by the undertaking for which the recovery was carried out.
For a typical air-conditioning fleet, the 2 500 line catches neither R-410A (2 088) nor R-407C (1 774) nor R-134a (1 430). It does catch R-404A or R-507A type gases where they were used in heat pumps or mixed installations.
Article 13(5), the 750 step of 1 January 2032, targets stationary refrigeration equipment, with the exclusion of chillers, not air conditioning. Do not extend to heat pumps what the text does not say.
The full treatment of Article 13 is in the guide on servicing bans for high-GWP refrigerants, and the chiller position in chillers and the Annex IV bans.
Checklist before you quote
- Decide whether the equipment is self-contained or splitArticle 3, point (38) for self-contained, point (39) for split; fixed double duct falls under point 9 by the footnote.
- Read the rated capacity, not the catalogue cooling outputThe Annex IV bands are up to and including 12 kW, more than 12 kW, and at point 8(d) more than 12 kW but not exceeding 50 kW.
- For single splits, check the charge against 3 kgPoint 9(a) applies to single split systems containing less than 3 kg of Annex I gases.
- Compare the GWP with the limit in the correct row750 at points 9(a) and 9(e), 150 at points 9(b), (c) and (f), any fluorinated greenhouse gas at point 9(d).
- Do not assume the safety exceptionPoint 9(a) has none; at point 8(b) to (e) the exception lowers the threshold to 750, it does not remove it.
- Check whether the label needs the safety statementArticle 12(15) lists the points concerned and requires the requirement or standard to be specified on the label.
- For older stock, prepare the evidenceArticle 11(1), fifth subparagraph: one year after the date, resale requires evidence of lawful placing on the market before that date.
- Confirm that installation goes to a certified undertakingArticle 11(7) for charged non-hermetically sealed equipment, with the seller records in Article 7(4).
- Check the servicing side as wellArticle 13(4) for air conditioning and heat pumps from 1 January 2026, with the reclaimed or recycled window until 1 January 2032.
Frequently asked questions
Can I install in 2027 a split unit bought in 2024?
Article 11 prohibits placing on the market, not installation. If the equipment was lawfully placed on the market before the Annex IV date, that article does not stop the installation. Watch Article 13(19) though: for the equipment listed there, including points 9(b) to (f), putting into operation after the prohibition date requires evidence that the equipment was placed on the market before that date, and the documentation is kept for at least 5 years under paragraph 20.
Is a double duct unit monobloc or split?
The footnote to point 9 of Annex IV is explicit: for the purposes of the Regulation, fixed double duct heat pump and air-conditioning equipment shall be considered split, category number 9, and be subject to the same requirements. It does not sit in point 8, even though physically it is one box.
Why did R-32 replace R-410A in single splits?
Because of Annex IV, point 9(a): from 1 January 2025, single split systems containing less than 3 kg of Annex I gases may no longer be placed on the market if they use Annex I gases with a GWP of 750 or more. R-410A has a GWP of 2 088 under the Annex VI method and crosses the line. R-32 has 675, the binding Annex I value, and stays below. The detailed comparison is in R-32 or R-410A.
Does a safety requirement let me use any gas?
No. At points 8(b) to (e) the text says plainly that if safety requirements at the site of operation would not allow fluorinated greenhouse gases with a GWP of less than 150, the GWP limit is 750. The exception lowers the threshold to 750; it does not cancel it. Article 3, point (42) also requires the prohibition of the alternative to come from Union or national law or from a standard that has to be applied at that location, not from an installation preference.
Can I still sell my stock after the ban date?
Equipment lawfully placed on the market before the date may be supplied onwards. However, under Article 11(1), fifth subparagraph, one year following the individual Annex IV date the subsequent supply or making available to another person in the Union is allowed only if evidence is provided that the equipment was lawfully placed on the market before that date. Build that file now, not at the inspection.
Does the prohibition apply to spare parts too?
Article 11(1), first subparagraph covers products and equipment "including parts thereof". The second subparagraph then derogates for parts required for repair and servicing of existing equipment listed in Annex IV, on three cumulative conditions: the repair must not increase the capacity, must not increase the amount of gas, and must not change the type of gas to one with a higher GWP.
Official sources
Annex IV points 8 and 9, the footnote to point 9, and Articles 3, 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
The dates and limits on this page are reproduced from Annex IV to Regulation (EU) 2024/573 as published in the Official Journal. The Annex may be amended by delegated act, and the language versions can differ slightly in wording. Before a purchasing or design decision, check the text in force in the language of the Member State where the equipment is placed on the market.
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 the assessment of a designer or of a competent authority.
Installation, servicing, repair and decommissioning of equipment containing fluorinated greenhouse gases may only be carried out by personnel certified under Article 10. A2L and A3 refrigerants require additional safety measures at the installation site.