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R-410A: regulatory status in the EU

Many people believe R-410A was banned along with R-404A. It was not: at 2 088 it stays below the 2 500 threshold, so servicing is allowed. What has closed is the new-equipment side.

Checked against official sourcesLast verified: 26 August 20269 min read
GWP2 088

calculated under Annex VI

Servicing todayAllowed

Not caught by the servicing bans that apply today.

From 1 January 2032Banned

Prohibited for servicing stationary refrigeration other than chillers.

Leak-check threshold≈ 2.40 kg

5 t CO2e — Annex I

Quick answer

R-410A is an equal-parts blend of R-32 and R-125. The two Annex I values, 675 and 3 500, give a weighted average under Annex VI of roughly 2 088.

That figure sits just under the 2 500 threshold and explains the refrigerant's whole situation: servicing stays open, new equipment closes.

SituationValue
GWP2 088 — calculated under Annex VI
Servicing todayAllowed — Not caught by the servicing bans that apply today.
From 1 January 2032Banned — Prohibited for servicing stationary refrigeration other than chillers.
Leak-check threshold5 t CO2e ≈ 2.40 kg (Annex I)

The GWP, and where it comes from

R-410A 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.

ComponentShare by weightGWPContribution
HFC-3250.0 %675337.5
HFC-12550.0 %3 5001 750.0
Total≈ 2 088

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.

Annex I has two GWP columns

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 2 088, R-410A 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.

The next line does catch it. From 1 January 2032, Article 13(5) prohibits Annex I gases with a GWP of 750 or more for maintaining or servicing stationary refrigeration equipment, chillers excluded. At 2 088 it is above that limit.

The prohibition does not apply to military equipment, equipment designed to cool below −50 °C, or equipment designed to cool nuclear power stations. Reclaimed and recycled gas are excepted on the conditions in the same paragraph.

Equipment: what may no longer be placed on the market

At 2 088, R-410A is caught by both the 750 and the 150 limits in Annex IV. The rows that have already closed the market, or will:

Annex IV pointEquipmentLimitDate
9(a)Single split systems containing less than 3 kg of Annex I gasesGWP 750 or more1.1.2025
8(b)Self-contained air conditioning and heat pumps, up to and including 12 kWGWP 150 or more (750 where safety requires)1.1.2027
8(d)Monobloc and self-contained air conditioning and heat pumps, above 12 kW to 50 kWGWP 150 or more (750 where safety requires)1.1.2027
7(d)Chillers above 12 kWGWP limit of 7501.1.2027
9(e)Split systems above 12 kWGWP 750 or more1.1.2029
9(f)Split systems above 12 kWGWP 150 or more1.1.2033

Point 9(a) is the one that actually changed the market: single split systems containing less than 3 kg of Annex I gases with a GWP of 750 or more may no longer be placed on the market from 1 January 2025. That is why small air conditioners moved to R-32.

Point 7(d) is worth reading carefully: for chillers above 12 kW it is not a “150 or more” threshold but a GWP limit of 750 applying from 1 January 2027. R-410A is above it.

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.

ChargeCheck at leastWith a detection system
5 – 50 t CO2e12 months24 months
50 – 500 t CO2e6 months12 months
≥ 500 t CO2e3 months6 months

Worked example. 10 kg of R-410A is 10 × 2 088 ÷ 1 000 ≈ 20.9 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).

Why servicing stays lawful even though the equipment does not

The confusion comes from the regulation using different thresholds for different things. The servicing ban in Article 13(3) and (4) is measured at 2 500. The equipment bans in Annex IV are measured at 150, 750 or 2 500 depending on the row. R-410A, at 2 088, passes under the first and falls under many of the others.

The practical result: a heat pump on R-410A installed in 2023 may lawfully be serviced with virgin gas today, even though an identical unit can no longer be sold as new equipment. Nothing contradictory about it — these are two separate regimes.

The date that changes the picture is 1 January 2032. From then, Article 13(5) prohibits gases with a GWP of 750 or more for servicing stationary refrigeration equipment, chillers excluded. R-410A is caught where the installation counts as stationary refrigeration; air conditioning and heat pumps are not covered by paragraph (5).

The right question

Not “am I still allowed to use R-410A?” but “what category is this installation, and which threshold applies to it?”. The same kilograms give different answers in a display cabinet, in a chiller and in a heat pump.

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-410A?

2 088, 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-410A?

Yes. At 2 088 it is not caught by the servicing bans that apply today. From 1 January 2032, however, Article 13(5) prohibits it for servicing stationary refrigeration other than chillers.

At what charge do leak checks start?

At 5 tonnes of CO2 equivalent. At 2 088 that is roughly 2.40 kg.

Is R-410A 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-410A?

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

Please read

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.

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