Quick answer
There is no single answer, and anyone who gives you one has not read Annex IV. The prohibition that applies depends on three things: whether the unit is split or self-contained, its rated capacity, and — for splits — whether it is air-to-air or air-to-water.
The two candidates sit far apart on GWP. R-32 is listed in Annex I at 675. R-410A is a blend, so it is calculated under Annex VI from its nominal 50/50 composition of R-32 and R-125: (0,5 × 675) + (0,5 × 3 500) ≈ 2 088.
| Threshold in Annex IV | R-32 (675) | R-410A (≈ 2 088) |
|---|---|---|
| GWP 750 or more | Clears it | Caught |
| GWP 150 or more | Caught | Caught |
So R-32 buys time on the 750 lines and nothing on the 150 lines. Which of those a given unit meets, and when, is what the rest of this guide sets out.
For air conditioning, the pressure on R-410A comes almost entirely from what may be sold, not from what may be charged. The servicing side is covered further down and it is much less restrictive than people assume.
Split systems — Annex IV point 9
Point 9 is cut by capacity and by type. Each row is a prohibition on placing that equipment on the market from the date shown.
| Point | Equipment | Limit | Date | R-32 | R-410A |
|---|---|---|---|---|---|
| 9(a) | Single split systems containing less than 3 kg of Annex I gases | GWP 750 or more | 1 January 2025 | OK | Out |
| 9(b) | Split air-to-water, rated capacity up to and including 12 kW | GWP 150 or more | 1 January 2027 | Out | Out |
| 9(c) | Split air-to-air, rated capacity up to and including 12 kW | GWP 150 or more | 1 January 2029 | Out | Out |
| 9(e) | Split systems above 12 kW | GWP 750 or more | 1 January 2029 | OK | Out |
| 9(f) | Split systems above 12 kW | GWP 150 or more | 1 January 2033 | Out | Out |
| 9(d) | Split systems up to and including 12 kW | Any fluorinated greenhouse gas | 1 January 2035 | Out | Out |
Read down the R-32 column and the shape of the decision appears. On a small single split, R-410A has been unavailable since 1 January 2025 and R-32 is the answer — until 1 January 2029 for air-to-air, or 1 January 2027 if it is air-to-water. On a split above 12 kW, R-32 clears the 2029 line that removes R-410A and runs to 1 January 2033.
Point 9(b) hits air-to-water splits up to 12 kW on 1 January 2027 at GWP 150; the equivalent air-to-air line, point 9(c), is 1 January 2029. Same capacity, same cabinet size, two years apart. Check which one you are quoting.
A footnote to Annex IV adds one clarification worth knowing: fixed double duct heat pump and air conditioning equipment is treated as split equipment — category 9 — and is subject to the same requirements.
Self-contained and monobloc — Annex IV point 8
If the unit is not a split, point 8 applies instead, and the capacity bands are different.
| Point | Equipment | Limit | Date |
|---|---|---|---|
| 8(a) | Plug-in room air conditioning movable between rooms by the end user | HFCs with GWP 150 or more | 1 January 2020 |
| 8(b) | Plug-in room, monobloc, other self-contained AC and self-contained heat pumps, up to and including 12 kW | GWP 150 or more (750 where safety requires) | 1 January 2027 |
| 8(c) | The same equipment | Any fluorinated greenhouse gas (750 where safety requires) | 1 January 2032 |
| 8(d) | Monobloc and other self-contained AC and heat pumps, above 12 kW up to 50 kW | GWP 150 or more (750 where safety requires) | 1 January 2027 |
| 8(e) | Other self-contained AC and heat pumps | GWP 150 or more (750 where safety requires) | 1 January 2030 |
Neither R-32 nor R-410A clears a 150 limit. On self-contained equipment the 2027 dates therefore end the discussion for both, unless the safety derogation applies — which is the next section.
The servicing side — and the line that does not apply here
This is where a lot of confusion sits, so it is worth being precise.
Article 13(4). From 1 January 2026, Annex I gases with a GWP of 2 500 or more may not be used for the maintenance or servicing of air conditioning equipment and heat pumps. Reclaimed gas is exempt until 1 January 2032 where the container is labelled under Article 12(7), and recycled gas on the narrower conditions in the same paragraph.
R-410A is below that line. At roughly 2 088 it is not caught by Article 13(4). An installed R-410A air conditioning system can still be serviced with R-410A.
Article 13(5) does not apply to air conditioning. The 1 January 2032 threshold of GWP 750 covers stationary refrigeration equipment, with the exclusion of chillers. It is not an air conditioning provision. Applying it to a heat pump or a split air conditioner is a common and consequential mistake.
| Question | Answer |
|---|---|
| Can I still service an R-410A air conditioner? | Yes — 2 088 is below the 2 500 threshold in Article 13(4). |
| Can I still service an R-404A air conditioner or heat pump? | Not from 1 January 2026 with virgin gas — about 3 922 is above 2 500. |
| Does the 750 line hit air conditioning in 2032? | No. Article 13(5) is about stationary refrigeration other than chillers. |
An R-410A system installed today has a service route for the foreseeable future under the current text. The constraint on R-410A is that fewer and fewer new units may lawfully be placed on the market — which affects replacement, spares availability and resale value long before it affects servicing.
The safety derogation, and what it costs in paperwork
Several Annex IV rows carry the words “except if required to meet safety requirements at the site of operation”, and points 8(b), 8(c), 8(d) and 8(e) go further: if safety requirements at the site of operation would not allow using fluorinated greenhouse gases with GWP of less than 150, the GWP limit is 750.
That clause exists because lower-GWP refrigerants are frequently flammable, and some installations cannot accommodate that. It is not, however, a free pass. Three obligations attach to it.
- Label the equipment. Article 12(15): in the cases referred to in points 8(b) to (e) and 9(b) to (f) of Annex IV — among others — the product or equipment must be labelled with an indication that it shall be used only where required by the safety requirements or national safety standards, and those requirements or standards must be specified on the label.
- Be able to prove it. Article 13(19): putting into operation or using equipment covered by those points after the prohibition date is itself prohibited unless the operator can show that the safety requirements at that particular location do not permit equipment using gases below the specified GWP, or that the equipment was placed on the market before the date.
- Keep the file five years. Article 13(20) requires that documentation to be kept for at least five years and produced on request.
It is a statement about a particular installation, evidenced and labelled. A general assertion that flammable refrigerants are unsuitable is not the derogation the regulation describes.
Where the replacement refrigerant is flammable, the certification side moves too. Implementing Regulation (EU) 2024/2215 brings hydrocarbons inside Certificates A1 and A2, CO2 into Certificate B and ammonia into Certificate C, and Article 10(5) of the F-gas Regulation requires certification programmes to cover the safe handling of equipment containing flammable or toxic gases or operating under high pressure.
How to answer it on a quote
Identify the Annex IV category first
Split or self-contained. If split, air-to-air or air-to-water. Get this wrong and every date that follows is wrong.
Take the rated capacity from the data plate
The 12 kW and 50 kW boundaries decide which row applies, not the nominal marketing figure.
Read the row, then the GWP
A 750 limit lets R-32 through and stops R-410A. A 150 limit stops both.
Check the installation date against the row's date
The prohibition is on placing on the market. Equipment lawfully placed on the market before the date can still be installed, subject to Article 13(19) for the listed points.
Decide whether you are relying on the safety derogation
If so, the label has to specify the safety requirements and the operator has to hold the evidence for five years.
Check the certification you will need to service it
A flammable refrigerant changes which certificate covers the work and what the training has to have included.
Tell the customer the next date, not just this one
R-32 on a split above 12 kW clears 2029 and runs to 2033. On a small air-to-water split it stops in 2027. That difference belongs in the quote.
Common mistakes
- Treating R-32 as the permanent answer. It clears the 750 lines and fails every 150 line — points 9(b), 9(c), 9(f), 8(b), 8(d) and 8(e).
- Applying the 2032 refrigeration line to air conditioning. Article 13(5) covers stationary refrigeration other than chillers.
- Assuming R-410A can no longer be serviced. At about 2 088 it is below the 2 500 threshold in Article 13(4).
- Using the same date for air-to-air and air-to-water. Point 9(b) is 2027; point 9(c) is 2029.
- Quoting a split date for a monobloc. Point 8 and point 9 are different timetables with different capacity bands.
- Claiming the safety derogation without labelling it. Article 12(15) requires the label to specify the safety requirements or national standards relied on.
- Keeping no evidence for a commissioned unit. Article 13(19) and 13(20) put that on the operator, for five years.
- Reading the 20-year GWP column. Annex I marks it for information only.
Checklist
- Annex IV category identifiedSplit or self-contained; air-to-air or air-to-water; double duct counts as split.
- Rated capacity confirmed from the data plateAgainst the 12 kW and 50 kW boundaries.
- The applicable row and its date written downPoint 8(b) to (e) or 9(a) to (f).
- GWP checked against that row's limit675 for R-32; about 2 088 for R-410A, calculated under Annex VI.
- Placing-on-market date distinguished from installation datePlus the Article 13(19) evidence where the point is listed there.
- Safety derogation documented if relied onLabel under Article 12(15) specifying the requirements; evidence kept five years.
- Servicing route confirmed for the installed baseArticle 13(4) applies at 2 500 from 1 January 2026 for AC and heat pumps.
- Certification checked for the refrigerant chosenEspecially where it is flammable.
- The next date given to the customerNot only the one that applies today.
Frequently asked questions
Is R-410A banned?
Not as a substance. It is excluded from specific equipment categories by Annex IV — for example single split systems containing less than 3 kg of Annex I gases since 1 January 2025 under point 9(a), and splits above 12 kW from 1 January 2029 under point 9(e), both at a GWP limit of 750. At about 2 088 it fails those limits.
Can I still service an existing R-410A system?
Yes. Article 13(4) prohibits gases with a GWP of 2 500 or more for servicing air conditioning equipment and heat pumps from 1 January 2026, and R-410A at roughly 2 088 is below that threshold.
Does the 750 limit apply to air conditioning in 2032?
No. Article 13(5) applies from 1 January 2032 to stationary refrigeration equipment, with the exclusion of chillers. It is not an air conditioning provision.
Is R-32 a long-term answer?
It depends on the category. On a split above 12 kW it clears the 2029 limit of 750 and runs until the 150 limit on 1 January 2033. On a split air-to-water up to 12 kW the 150 limit arrives on 1 January 2027, which R-32 at 675 does not clear.
What is the GWP of R-410A?
It is a blend and is not listed with a single value in Annex I. Calculated under Annex VI from its nominal 50/50 composition of R-32 and R-125, using the binding Annex I values, it comes to about 2 088. Annex VI allows a ± 1 % weight tolerance.
What does “except if required to meet safety requirements at the site of operation” mean?
It is a site-specific derogation. In points 8(b) to (e) the regulation adds that where safety requirements would not allow gases below GWP 150, the limit becomes 750. Article 12(15) requires the equipment to be labelled accordingly, specifying the requirements or standards, and Article 13(19) and 13(20) require the operator to hold and keep the evidence for five years.
Does double duct equipment count as split?
Yes. A footnote to Annex IV states that fixed double duct heat pump and air conditioning equipment is considered split — category 9 — and is subject to the same requirements.
Can I install equipment bought before a ban date?
The prohibition in Annex IV is on placing on the market. For the points listed in Article 13(19) — which include 8(b) to (e) and 9(b) to (f) — putting into operation after the date is also prohibited unless the operator can prove the safety derogation applies or that the equipment was placed on the market before the date.
Official sources
Articles 12 and 13 and Annexes I, IV and VI were read directly in the Official Journal text through the EU Publications Office.
Currency of this guide and limits of responsibility
This guide sets out what the regulation permits by equipment category and date. It does not recommend a refrigerant for a specific installation — capacity, pressures, component ratings, flammability and the safety assessment of the site are engineering questions answered by the equipment manufacturer's documentation and the applicable safety standard.
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.
Annex IV can be amended, and the Commission may authorise time-limited exemptions under Article 11(5). Confirm the current text before you rely on a date commercially.