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Choosing a gas

R-290 propane: applications, safety class and the legal framework

R-290 has a practically negligible GWP and is not an Annex I gas, so it consumes no quota. In exchange it is extremely flammable, and everything you gain on the climate side is paid for in design, in certified people and in discipline on site.

Checked against official sourcesLast verified: 15 September 202611 min read
Status under the RegulationNot an Annex I gas

No quota and none of the duties built specifically around fluorinated gases in Articles 5, 12 and 16.

GWP0.02

Table of non-fluorinated substances in Annex VI to Regulation (EU) 2024/573.

Hazard classificationH220 and H280

Extremely flammable gas, category 1, and gas under pressure. Safety data sheet, section 2.

Certificate requiredA1 or A2

Implementing Regulation (EU) 2024/2215, Article 3(2).

The short answer

R-290 is refrigerant-grade propane. Under Article 2, Regulation (EU) 2024/573 applies to the fluorinated greenhouse gases listed in Annexes I, II and III and to the products and equipment containing them. Propane appears in none of those annexes, so it does not enter the quota system and it does not trigger the duties built specifically around fluorinated gases.

That does not put it outside the Regulation. Annex VI gives it a GWP of 0.02, used when calculating the GWP of mixtures. Article 10 extends certification to relevant alternatives, natural refrigerants included. And Annex IV, through its stepped prohibitions on fluorinated gases, is the commercial engine that has put it into display cabinets and monobloc heat pumps.

The European Commission lists R-290 in its own material on climate-friendly alternatives with safety class A3 and a 100-year GWP of 0.02.

What this page does not contain

No charge limits, no minimum room sizes, no ventilation requirements and no safety distances. Those come from the product and installation standards — ISO 817 for the classification, EN 378 for refrigerating systems — which are not free documents and cannot be reproduced here. It contains no numeric ADR thresholds either. Take those figures from the applicable standard, from the equipment manufacturer's instructions and from the product safety data sheet.

What it is, exactly

The product identification comes from section 1 of the supplier safety data sheet, in the format required by Regulation (EU) 2020/878.

ItemValue
Trade nameR290, propane
Chemical namePropane
Chemical formulaC3H8
CAS number74-98-6
EC number200-827-9
INDEX number601-003-00-5
Identified usesIndustrial and professional, refrigerant among them

The sheet adds a line under identified uses that is worth reading twice: perform a risk assessment prior to use. That is not boilerplate; it reflects the fact that the product is a liquefied flammable gas under pressure.

Safety warning

R-290 is extremely flammable. Installing, servicing, charging and decommissioning hydrocarbon equipment is done exclusively by competent, trained and certified personnel, with suitable tools and procedures, after ignition sources have been removed. Do not improvise with equipment intended for non-flammable refrigerants.

What it means that it is not an Annex I gas

The Regulation builds most of its duties on the lists in its annexes. If the substance is not there, that particular duty is not triggered. That is the whole logic, and the consequences are very concrete.

DutyApplies to R-290?Why
Quota for placing on the marketNoArticle 16(1) concerns hydrofluorocarbons, that is, the substances in Section 1 of Annex I and mixtures containing them
Leak checks on tonnes-CO2e thresholdsNoArticle 5(1) refers to gases listed in Annex I and in Section 1 of Annex II
The Article 12 F-gas labelNoArticle 12 concerns products and equipment containing fluorinated greenhouse gases
Annual F-gas Portal reporting for the substance itselfNoArticle 26 refers to fluorinated greenhouse gases
A GWP assigned in the RegulationYesAnnex VI lists it among the non-fluorinated substances, with R-290 as the industrial designation and a 100-year GWP of 0.02
Certification of personnelYesArticle 10(1) also covers relevant alternatives including natural refrigerants; detailed in Regulation (EU) 2024/2215

The 0.02 value is not decorative. It enters the calculation of a mixture's GWP under Annex VI wherever propane is a component. For how that calculation works, see the CO2 equivalent guide.

What does not disappear along with the quota

Not needing quota does not exempt you from dangerous goods law in transport, from pressure equipment law, from the requirements on potentially explosive atmospheres where they apply, from occupational health and safety duties, or from product standard requirements. Each of those has its own legal basis, independent of the F-gas Regulation.

Where it is used, and why it grew so fast

The European Commission lists it in its material on climate-friendly alternatives in refrigeration across stand-alone systems, condensing units, centralised systems, industrial refrigeration and transport refrigeration. The Commission also notes that in recent years there has been a shift from high-GWP hydrofluorocarbons, R-404A in particular, to hydrocarbons such as R-290 and R-600a, with important energy efficiency gains.

The regulatory engine is Annex IV. A few markers that explain the demand:

  • Point (4): from 1 January 2025, any self-contained refrigeration equipment except chillers containing fluorinated greenhouse gases with a GWP of 150 or more may no longer be placed on the market, except if required to meet safety requirements at the site of operation.
  • Point (3)(c): from 1 January 2025, refrigerators and freezers for commercial use, self-contained, containing other fluorinated greenhouse gases with a GWP of 150 or more.
  • Point (2)(b): from 1 January 2026, domestic refrigerators and freezers containing fluorinated greenhouse gases, with the same safety exception.
  • Point (8)(b) and (c): successive thresholds for self-contained air-conditioning and heat pumps up to 12 kW, in 2027 and 2032.
The safety clause in Annex IV

Several Annex IV entries carry the exception "except if required to meet safety requirements at the site of operation". Some add an alternative limit: if safety requirements at the site of operation would not allow a fluorinated gas with a GWP of less than 150, the GWP limit becomes 750. That is the text expressly acknowledging that flammability can be a real obstacle in a given location.

In other words, R-290 is nowhere mandatory. Annex IV closes doors for high-GWP gases, and hydrocarbons are one of the routes that stay open where the site allows it. The general selection method is covered in the low-GWP refrigerants on site guide.

The safety class and the properties that matter

Refrigerant safety classes are defined in ISO 817 and applied in EN 378 for refrigerating systems. Those are paid standards and their text cannot be reproduced here. What can be said is how official sources classify it: the European Commission lists R-290 with safety class A3 in its refrigeration alternatives tables, alongside a 100-year GWP of 0.02.

The chemical hazard classification, which you find on the label and in the safety data sheet, comes from Regulation (EC) No 1272/2008:

  • Flammable gas, category 1 — hazard statement H220: extremely flammable gas.
  • Gases under pressure, liquefied gas — hazard statement H280: contains gas under pressure; may explode if heated.
  • Signal word: Danger.
  • Precautionary statements in the sheet consulted: P210 (keep away from heat, hot surfaces, sparks, open flames and other ignition sources, no smoking), P377 (leaking gas fire: do not extinguish unless the leak can be stopped safely), P381 (in case of leakage, eliminate all ignition sources), P403 (store in a well-ventilated place).
  • Other hazards noted: contact with the evaporating liquid may cause frostbite.

The physical properties in section 9 of the same sheet explain why the procedures differ from an A1 refrigerant:

PropertyValue from the safety data sheet
AppearanceLiquefied gas, colourless, odourless
Boiling point-42.1 °C at 1 013 hPa
Flash point-104 °C
Autoignition temperature450 °C
Lower flammability limit1.7 % by volume
Upper flammability limit10.9 % by volume
Vapour density (air = 1)1.56 at 0 °C

Two practical consequences read straight off the table. The gas is odourless, so you cannot rely on smell to detect a leak. And it is heavier than air, so it collects at floor level, in ducts, drains and low spaces, not under the ceiling.

Which certificate working with R-290 requires

This is the most common misunderstanding: it is not an F-gas, so no certificate is needed. Wrong. Article 10(1) of Regulation (EU) 2024/573 requires natural persons to be certified for the activities listed there when they involve fluorinated greenhouse gases or relevant alternatives to fluorinated greenhouse gases, including natural refrigerants, where relevant. Implementing Regulation (EU) 2024/2215 carries that reference through.

Regulation (EU) 2024/2215, Article 2(1), points (b) and (c)

The Regulation applies to natural persons carrying out the installation of the equipment listed in Article 1 containing fluorinated greenhouse gases listed in Annex I and Section 1 of Annex II to Regulation (EU) 2024/573 or the alternative substances ammonia, carbon dioxide or hydrocarbons, as well as the repair, maintenance or servicing and decommissioning of the same equipment. Article 2(2) extends the same rule to legal persons carrying out that work for third parties.

The equipment concerned is the list in Article 1: stationary refrigeration, stationary air conditioning and heat pump equipment, stationary organic Rankine cycles, refrigeration units of refrigerated trucks and trailers, and refrigeration units of refrigerated light-duty vehicles, intermodal containers and train wagons.

The relevant certificate types are set out in Article 3(2):

  • Certificate A1 — allows all the activities in Article 2(1) in relation to fluorinated greenhouse gases and hydrocarbons, with no charge limit.
  • Certificate A2 — the same activities in relation to fluorinated greenhouse gases and hydrocarbons, but limited to equipment with a charge size of less than 3 kilograms or, for hermetically sealed systems labelled as such, less than 6 kilograms.
  • Certificates B and C are dedicated to carbon dioxide and ammonia respectively, so they do not cover work on propane.

Annex I to that Regulation requires, for Certificates A1 and A2, hydrocarbon-specific knowledge: the characteristics of hydrocarbons in contrast to F-gas refrigerants, flammability, flame propagation, charge size restrictions and occupancy limits, the requirements and procedures for handling, filling, recovering, storing and transporting hydrocarbons, the differences in components and system design, and good servicing practice. It also requires understanding of the site-specific conditions under which equipment not meeting the Annex IV requirements may be used for safety reasons.

What the certification regulation does not cover: Article 2(3) excludes manufacturing activity undertaken at the equipment manufacturer's own site. And the recovery activity in Article 2(1), point (d), is written for fluorinated greenhouse gases. For the detail of the categories see the certificate categories guide.

Transport, storage and documents

The F-gas Regulation does not govern the carriage of dangerous goods. The framework applicable in the Union is Directive 2008/68/EC on the inland transport of dangerous goods, which makes the ADR provisions applicable inside the Union for road transport. Thresholds, exemptions, documents and vehicle marking come from there and from section 14 of the safety data sheet of the actual product, not from a summary.

The transport identifiers in the sheet consulted, section 14, in the format required by Regulation (EU) 2020/878:

ItemADR and RID
UN numberUN 1978
UN proper shipping namePROPANE
Transport hazard class2
Label2.1
Packing groupNot applicable
The right source for your product

Section 14 of the safety data sheet of the product you are actually carrying. Do not extrapolate from one refrigerant to another: R-290 and R-134a do not share a transport classification. The general precautionary duties in transport and storage are covered in the cylinder transport guide and the cylinder storage guide.

For storage, precautionary statement P403 in the sheet requires a well-ventilated place and P210 requires keeping it away from ignition sources. A vapour density of 1.56 relative to air means ventilation has to be thought through at low level, not only high up. The concrete requirements on potentially explosive atmospheres, ventilation and detection come from the law and standards applicable to the installation, not from the F-gas Regulation.

Checklist before working with R-290

  • You have read the safety data sheet of the actual productSections 2, 4, 6, 7, 9 and 14. The format is set by Regulation (EU) 2020/878.
  • The person doing the work holds Certificate A1 or A2Regulation (EU) 2024/2215, Article 3(2), points (a) and (b). Certificates B and C do not cover hydrocarbons.
  • The equipment charge is within the limit of the certificateCertificate A2 is limited to under 3 kg, or under 6 kg for hermetically sealed systems labelled as such.
  • The company holds a legal person certificate if it works for third partiesRegulation (EU) 2024/2215, Article 2(2) and Article 6.
  • Ignition sources are removed from the work areaPrecautionary statements P210 and P381 in the safety data sheet.
  • Ventilation is planned at floor level tooVapour density is 1.56 relative to air; the gas collects low.
  • You are not relying on smell to detect leaksThe sheet describes the product as odourless. Use detection suitable for flammable gases.
  • Tools and instruments are rated for flammable refrigerantsEquipment intended for non-flammable refrigerants does not transfer automatically.
  • You have checked the equipment manufacturer's instructionsCharge limits and siting requirements come from the product standard and the manufacturer's documentation.
  • The transport classification has been checked for your productSection 14 of the sheet and the regime of Directive 2008/68/EC.

Frequently asked questions

Does R-290 consume quota on import?

No. Article 16(1) ties the quota requirement to hydrofluorocarbons, and propane is not listed in Annex I. Note, though, that if you import equipment the other general product rules apply, and if the same consignment also carries fluorinated gases, those keep their own regime.

If it is not an F-gas, do I still need a certificate?

Yes. Article 10(1) of Regulation (EU) 2024/573 also covers relevant alternatives including natural refrigerants, and Regulation (EU) 2024/2215 says expressly in Article 2(1), points (b) and (c), that the installation, repair, maintenance, servicing and decommissioning of equipment containing hydrocarbons fall within its scope. Certificates A1 and A2 cover hydrocarbons.

What GWP is used officially for propane?

0.02. The value appears in the table of non-fluorinated substances in Annex VI to Regulation (EU) 2024/573, with the industrial designation R-290 and the formula CH3CH2CH3. It is used when calculating the GWP of mixtures that contain propane.

What does class A3 mean?

It is the safety class assigned to refrigerants with lower toxicity and higher flammability. The classification is defined in ISO 817 and applied in EN 378; those are paid standards whose text cannot be reproduced here. The European Commission lists R-290 with class A3 in its material on refrigeration alternatives.

Do I have to leak check an installation running on R-290?

Not under Article 5, which refers to gases listed in Annex I and in Section 1 of Annex II. That does not mean the installation needs no checking: maintenance and safety duties follow from occupational safety law, from installation standards and from the manufacturer's documentation.

Can I use the same cylinders and service equipment as for R-410A?

Do not assume so. Cylinders, hoses, vacuum pumps, detectors and recovery vessels must be suitable for flammable refrigerants. Check the marking and the documentation of your equipment beforehand, not afterwards.

What is the UN number for transport?

The safety data sheet consulted gives, in section 14, UN 1978 with the proper shipping name PROPANE, class 2 and label 2.1, with no packing group. Always confirm in the sheet of the product you are actually carrying and take the rest of the requirements from the regime of Directive 2008/68/EC.

Official sources

Articles 2, 3, 5, 10 and 16, Annex IV and Annex VI were read directly in the Official Journal text. The certification rules come from the dedicated implementing regulation. The product data comes from the safety data sheet of an EU industrial gas supplier, in the version available at the time of writing.

Currency of this page and limits of liability

Read this

This page contains no charge limits, ventilation requirements, room sizes or ADR thresholds. Those figures come from the applicable standards, from the equipment manufacturer's documentation and from the official text in force. Product data comes from the safety data sheet of the batch you actually hold.

General information prepared by EgoLog from the Regulation, the implementing regulation, official European Commission material and a public safety data sheet. It is not legal advice and it is not an engineering design.

R-290 is extremely flammable. Work on hydrocarbon equipment is carried out exclusively by competent, trained personnel certified under Article 10 of Regulation (EU) 2024/573 and Implementing Regulation (EU) 2024/2215. Confirm the applicable requirements with your supplier and your national competent authority.

Related guides

Duties during the job

Refrigerated trucks and trailers: the operator's F-gas duties

What the operator of a transport refrigeration unit has to do: thresholds, intervals, who may check, what goes in the records, which gases may still be used for servicing, and which duties do not exist.

  • Refrigerated transport
  • Article 5(3)
  • Certification
  • Recovery
Updated 22 September 202612 min read
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