Quick answer
R-32 is a pure hydrofluorocarbon, listed in Annex I as HFC-32. Its position in the regulation follows from a single number: 675. That is below 750 and above 150.
The first half of that sentence gives it a long life in servicing. The second half ends its life in new equipment sooner than many expect.
| Situation | Value |
|---|---|
| GWP | 675 — value listed in Annex I |
| Servicing today | Allowed — Not caught by the servicing bans that apply today. |
| From 1 January 2032 | Allowed — Still allowed after that date. |
| Leak-check threshold | 5 t CO2e ≈ 7.41 kg (Annex I) |
The GWP, and where it comes from
R-32 is a pure substance and is listed directly in Annex I at 675.
The second 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.
Servicing: what you may charge, and until when
At 675, R-32 sits below the 2 500 threshold in Article 13(3) and 13(4). It may still be used to maintain and service refrigeration, air conditioning and heat pump equipment.
It clears the next line as well. The 750 threshold that takes effect on 1 January 2032 for stationary refrigeration other than chillers stays above its value.
Equipment: what may no longer be placed on the market
At 675, R-32 clears every 750 limit in Annex IV but is caught by every 150 limit. The rows relevant to air conditioning and heat pumps:
| Annex IV point | Equipment | Limit | Date |
|---|---|---|---|
| 9(b) | Split air-to-water, up to and including 12 kW | GWP 150 or more | 1.1.2027 |
| 9(c) | Split air-to-air, up to and including 12 kW | GWP 150 or more | 1.1.2029 |
| 8(b) | Self-contained air conditioning and heat pumps, up to and including 12 kW | GWP 150 or more (750 where safety requires) | 1.1.2027 |
| 7(b) | Chillers up to and including 12 kW | GWP 150 or more | 1.1.2027 |
| 9(f) | Split systems above 12 kW | GWP 150 or more | 1.1.2033 |
| 9(d) | Split systems up to and including 12 kW | any fluorinated greenhouse gas | 1.1.2035 |
Also at 675, R-32 is not caught by point 9(a) — single splits with less than 3 kg, limit 750, from 1 January 2025 — nor by 9(e), nor by the 750 limit for chillers above 12 kW in point 7(d). That is precisely the commercial reason it displaced R-410A in smaller equipment.
Points 8 and 9 carry an important derogation: where safety requirements at the point of use demand it, the limit stays 750 instead of 150. R-32 is classified A2L, mildly flammable, so this discussion concerns it directly. The derogation does not apply automatically — it has to follow from the safety requirements applicable at the site.
Leak checks and the detection system
Article 5(1) sets what has to be checked and Article 5(6) how often. The duty falls on operators and on manufacturers of the equipment.
| Charge | Check at least | With a detection system |
|---|---|---|
| 5 – 50 t CO2e | 12 months | 24 months |
| 50 – 500 t CO2e | 6 months | 12 months |
| ≥ 500 t CO2e | 3 months | 6 months |
Worked example. 10 kg of R-32 is 10 × 675 ÷ 1 000 ≈ 6.8 t CO2e — the bottom band, so checks at least every 12 months (24 with a detection system).
Article 6(1) makes a leakage detection system mandatory for the stationary equipment in Article 5(2), points (a) to (d), from 500 t CO2e of Annex I gases. The detector itself is checked at least once every 12 months under Article 6(3).
The 7.41 kg figure and the hermetically sealed exemption
A low GWP does not mean you escape leak checks. The Article 5(1) threshold is 5 tonnes of CO2 equivalent, and at 675 that is reached at roughly 7.41 kg. Plenty of commercial air conditioning installations pass that figure.
There is an exemption worth knowing, though. The second subparagraph of Article 5(1) provides that hermetically sealed equipment is not checked for leaks, provided it is labelled as such and contains less than 10 tonnes of CO2 equivalent of Annex I gases. At 675, that limit means around 14.8 kg of R-32.
And where hermetically sealed equipment is installed in residential buildings, the third subparagraph raises the exemption to less than 3 kg of fluorinated greenhouse gases, again on condition that it is labelled as hermetically sealed.
First: is it hermetically sealed and labelled as such? If so, check the exemption limits. Only if it does not qualify do you move on to the CO2 equivalent sum and the Article 5(6) bands.
Label and record
The label. Article 12(1)(g) puts all fluorinated greenhouse gas containers under the labelling requirement, and Article 12(3) requires the designation, the quantity in weight and in CO2 equivalent, and the GWP. Implementing Regulation (EU) 2024/2174 requires the text “contains fluorinated greenhouse gases” and points at the “GWP” column of the annexes.
The record. Where the equipment has to be checked under Article 5(1), Article 7(1) requires a record for each piece of equipment: quantity and type, quantities added with dates, quantity recovered, origin of any added gas, the identity of the undertaking and the person who did the work, and the dates and results of checks and repairs. Five years, held by the operator and in copy by the servicing undertaking.
Who may buy it. Article 11(6) allows the purchase only by certified persons or undertakings employing them, and the seller records the certificate number and the quantity under Article 7(3).
What the regulation does NOT tell you
Physical properties, safety class and flammability are not in the regulation. Take them from the product's safety data sheet (sections 2 and 9) and the manufacturer's documentation.
The regulation also does not say whether the gas suits a particular installation. Capacity, pressures, oil compatibility and component ratings are engineering questions answered by the equipment manufacturer's documentation.
Where the refrigerant is flammable, the certification side moves too: Implementing Regulation (EU) 2024/2215 places hydrocarbons inside Certificates A1 and A2, CO2 in Certificate B and ammonia in Certificate C, and Article 10(5) of the F-gas Regulation requires training to cover safe handling of equipment containing flammable or toxic gases or operating under high pressure.
Checklist
- The GWP used is the binding columnNot the 20-year column, marked for information only.
- Charge recorded in kg and in tonnes of CO2 equivalentThe figure that sets the check interval.
- Servicing status checked against Article 13And the next date, not only today's.
- Equipment purchases checked against Annex IVBy category and rated capacity.
- Check interval assignedArticle 5(6), with or without a detection system.
- Detector question answeredArticle 6(1).
- Label complete on the cylinderDesignation, weight, CO2 equivalent, GWP.
- Equipment record currentArticle 7(1), kept five years.
- Safety data sheet available where the work happensNot only in the office.
Frequently asked questions
What is the GWP of R-32?
675, the value listed in Annex I to Regulation (EU) 2024/573. That is the binding column, not the 20-year one.
Can I still service with R-32?
Yes. At 675 it is not caught by the servicing bans that apply today. It stays below the 750 limit that takes effect on 1 January 2032.
At what charge do leak checks start?
At 5 tonnes of CO2 equivalent. At 675 that is roughly 7.41 kg.
Is R-32 banned as a substance?
No. The regulation does not ban substances as such. It restricts use for servicing above certain GWP thresholds (Article 13) and the placing on the market of certain equipment containing them (Annex IV). Those are different things with different dates.
Who may buy R-32?
Under Article 11(6), only certified natural persons or undertakings employing such persons, for installing, maintaining, servicing or repairing the covered equipment. The seller records the certificate number and the quantity under Article 7(3).
What has to be on the cylinder?
Article 12(3): an indication that it contains fluorinated greenhouse gases, the accepted industry designation, the quantity in weight and in CO2 equivalent, and the GWP. Implementing Regulation (EU) 2024/2174 adds the text “contains fluorinated greenhouse gases”.
Where do I find the safety class and the properties?
Not in the regulation. In the product's safety data sheet — section 2 for classification and label elements, section 9 for physical and chemical properties — and in the manufacturer's documentation.
Official sources
Annexes I, II, IV and VI and Articles 5, 6, 7, 11, 12 and 13 were read directly in the Official Journal text through the EU Publications Office.
Currency of this page and limits of responsibility
This is a regulatory status page, not a technical data sheet. It carries no thermodynamic properties, safety classes or application recommendations. For those, use the product's safety data sheet and the manufacturer's documentation.
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.