Quick answer
R-404A is a blend of three hydrofluorocarbons. Its GWP calculated under Annex VI, roughly 3 922, puts it far above the 2 500 threshold in Article 13.
This is not a future ban. It is one that has already taken effect. If you still have plant on R-404A, the question is no longer whether you replace it, but how you keep it running lawfully until you do.
| Situation | Value |
|---|---|
| GWP | 3 922 — calculated under Annex VI |
| Servicing today | Banned — May no longer be used to maintain or service any refrigeration equipment. |
| From 1 January 2032 | Banned — Prohibited for servicing stationary refrigeration other than chillers. |
| Leak-check threshold | 5 t CO2e ≈ 1.27 kg (Annex I) |
The GWP, and where it comes from
R-404A is a blend, so it is not listed with a single value in Annex I. Its GWP is calculated under Annex VI as the weighted average of the components, using the binding values from Annexes I and II.
| Component | Share by weight | GWP | Contribution |
|---|---|---|---|
| HFC-125 | 44.0 % | 3 500 | 1 540.0 |
| HFC-143a | 52.0 % | 4 470 | 2 324.4 |
| HFC-134a | 4.0 % | 1 430 | 57.2 |
| Total | ≈ 3 922 | ||
Annex VI allows a weight tolerance of ± 1 %, and substances not listed in the annexes count as 0. Where the figure carries commercial weight, take it from the product's own documentation or label.
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
Since 1 January 2025, Article 13(3) prohibits using a fluorinated greenhouse gas with a GWP of 2 500 or more to maintain or service any refrigeration equipment. At 3 922, R-404A is caught.
One window remains: the prohibition does not apply to reclaimed gas until 1 January 2030, for servicing existing equipment, where the container is labelled under Article 12(7) — “100 % Reclaimed”, batch number, and the reclamation facility's name and Union address. Recycled gas comes with much tighter conditions: only where it was recovered from that kind of equipment, and only for the undertaking that carried out the recovery or the one it recovered for.
For air conditioning and heat pumps the same 2 500 line starts on 1 January 2026 under Article 13(4), with the reclaimed window running to 1 January 2032.
Equipment: what may no longer be placed on the market
On the equipment side, R-404A was caught earlier than almost any other refrigerant. At 3 922 every Annex IV line reaches it, starting with the 2 500 line for HFCs in force since 2020:
| Annex IV point | Equipment | Limit | Date |
|---|---|---|---|
| 5(a) | Other refrigeration equipment (not chillers, not points 4 and 6), HFCs | GWP 2 500 or more | 1.1.2020 |
| 3(b) | Commercial self-contained refrigerators and freezers, HFCs | GWP 150 or more | 1.1.2022 |
| 6 | Multipack centralised commercial systems of 40 kW or more, Annex I gases | GWP 150 or more | 1.1.2022 |
| 4 | Any self-contained refrigeration equipment except chillers | GWP 150 or more | 1.1.2025 |
| 5(b) | The same equipment, any fluorinated greenhouse gas | GWP 2 500 or more | 1.1.2025 |
In practice R-404A has not appeared in new equipment for years. What remains is the installed base, and there Article 13(3) applies.
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-404A is 10 × 3 922 ÷ 1 000 ≈ 39.2 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).
What you may still lawfully do with an R-404A plant
You may repair the leak. The Article 13(3) prohibition concerns the gas used for maintenance or servicing, not the right to repair. Article 4(2) in fact obliges you to repair a detected leak without undue delay.
You may recover. Article 8(1) requires recovery of the gases during maintenance, servicing and decommissioning, by certified persons. The gas recovered from your plant is what feeds the reclamation chain.
You may recharge with reclaimed gas until 1 January 2030, for servicing existing equipment, where the container is labelled under Article 12(7): the words “100 % Reclaimed”, the batch number, and the name and Union address of the reclamation facility. Without that label you have no way to show you fall inside the exception.
Recycled gas is a different thing with tighter conditions: it may be used only where it was recovered from that kind of equipment, and only by the undertaking that carried out the recovery or the one it recovered for.
You may not top up with virgin gas. You may not use reclaimed gas without the Article 12(7) label. And you may not leave a known leak unrepaired while waiting to replace the plant.
From 1 January 2030 the reclaimed-gas window closes for refrigeration equipment too. If the plant has to run past that date, retrofit or replacement stops being optional.
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-404A?
3 922, calculated under Annex VI from the nominal composition and the binding values in Annexes I and II. Annex VI allows a ± 1 % weight tolerance, so take the exact figure from the product documentation.
Can I still service with R-404A?
Not with virgin gas. Since 1 January 2025, Article 13(3) prohibits gases with a GWP of 2 500 or more for maintaining or servicing any refrigeration equipment. Reclaimed gas remains possible until 1 January 2030 where the container is labelled under Article 12(7).
At what charge do leak checks start?
At 5 tonnes of CO2 equivalent. At 3 922 that is roughly 1.27 kg.
Is R-404A 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-404A?
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.