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R-452A: regulatory status in the EU

R-452A has a calculated GWP of roughly 2 139, below the 2 500 threshold and above 750. That gives it a clear place among the R-404A replacements: you may charge it today, but it carries a 2032 deadline in stationary refrigeration. This page shows exactly where it stands and what that deadline does not reach.

Checked against official sourcesLast verified: 15 September 202610 min read
GWP≈ 2 139

Calculated under Annex VI from 11 % R-32, 59 % R-125 and 30 % R-1234yf.

Servicing todayAllowed

Below the 2 500 threshold in Article 13(3) and 13(4).

From 1 January 2032Banned

Above 750: Article 13(5), stationary refrigeration, chillers excluded.

Leak-check threshold≈ 2.34 kg

5 t CO2e — Annex I.

Quick answer

R-452A is a blend of R-32, R-125 and R-1234yf. Calculated under Annex VI from the manufacturer's nominal composition — 11 % R-32, 59 % R-125 and 30 % R-1234yf — its GWP is roughly 2 139.

That places it between two lines: below 2 500 and above 750. Below 2 500 means it clears the prohibition that took R-404A and R-507A out of servicing. Above 750 means Article 13(5) catches it from 1 January 2032 for maintaining stationary refrigeration equipment other than chillers.

So it is a replacement that solves today's problem and leaves a date open. Anyone installing stationary refrigeration on R-452A now should already be planning the answer for after 2032.

SituationValue
GWP≈ 2 139 — calculated under Annex VI
Servicing todayAllowed — not caught by the servicing bans that apply today
From 1 January 2032Banned for servicing stationary refrigeration other than chillers
Leak-check threshold5 t CO2e ≈ 2.34 kg (Annex I)
What this page does not contain

It carries no thermodynamic properties, no capacity or discharge-temperature data, no oil compatibilities, no glide values, no retrofit procedure and no transport thresholds. None of those are in the F-gas Regulation. Take them from the safety data sheet and from the equipment manufacturer's documentation.

The GWP, and where it comes from

R-452A is a blend, so it is not listed with a value of its own in Annex I. Its GWP is calculated under Annex VI as the weighted average of the mass fractions, using the binding values from Annexes I and II.

ComponentShare by weightGWPContribution
HFC-3211.0 %67574.3
HFC-12559.0 %3 5002 065.0
HFC-1234yf30.0 %0.5010.150
Total≈ 2 139

Look at what each component does. Thirty per cent of the mass, the HFO part, contributes fifteen hundredths of one unit. Almost the entire result comes from the 59 % of R-125, which on its own brings more than 2 000.

That also shows why R-452A cannot drop below 750 without a completely different recipe: as long as R-125 is the majority component, the result stays in the upper band.

Annex VI allows a weight tolerance of ± 1 %, and substances not listed in the annexes count as 0. The figure on the label or in the product documentation may be rounded; where it carries commercial weight, use that one.

The manufacturer's documentation gives a lower figure

The product bulletin for Opteon XP44 states a GWP of 1 945, calculated on AR5 values. The regulation does not use those: the thresholds in Article 13 and Annex IV are measured against the binding “GWP” column of Annexes I and II. For any compliance decision the figure is ≈ 2 139. The difference changes no classification, though: both numbers sit between 750 and 2 500.

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

Article 13 contains three GWP lines for maintenance and servicing. R-452A clears the first two and is caught by the third.

  • Article 13(3) prohibits fluorinated greenhouse gases with a GWP of 2 500 or more for maintaining or servicing refrigeration equipment with a charge size of 40 tonnes of CO2 equivalent or more; from 1 January 2025 the prohibition covers any refrigeration equipment. At ≈ 2 139, R-452A is not caught.
  • Article 13(4) brings the same 2 500 limit to air conditioning and heat pumps from 1 January 2026. Not caught there either.
  • Article 13(5) prohibits, from 1 January 2032, Annex I gases with a GWP of 750 or more for maintaining or servicing stationary refrigeration equipment, chillers excluded. At ≈ 2 139, R-452A is caught.
What the 2032 date means in practice

The prohibition does not apply to military equipment, equipment designed to cool below −50 °C, or equipment designed to cool nuclear power stations. And points (a) and (b) of Article 13(5) take out of the prohibition reclaimed gas labelled under Article 12(7) and recycled gas recovered from such equipment, used only by the undertaking that carried out the recovery or the one it recovered for. Unlike the exceptions in Article 13(3), these carry no expiry date.

So after 1 January 2032, a stationary refrigeration system on R-452A can be serviced with reclaimed or recycled gas on those conditions, converted, or replaced. What can no longer be done is topping up with virgin gas.

Article 13(6) lets the Commission authorise time-limited exemptions from the prohibitions in paragraphs 4 and 5 where it finds a verified shortage of reclaimed or recycled gas.

Equipment: what may no longer be placed on the market

On equipment, R-452A clears the 2 500 line and is caught by every 150 and 750 line.

Annex IV pointEquipmentLimitDate
3(b) and 3(c)Commercial self-contained refrigerators and freezersGWP 150 or more1.1.2022 / 1.1.2025
6Multipack centralised commercial systems of 40 kW or more, Annex I gasesGWP 150 or more1.1.2022
4Any self-contained refrigeration equipment except chillersGWP 150 or more1.1.2025
7(b)Chillers up to and including 12 kWGWP 150 or more1.1.2027
7(d)Chillers above 12 kWGWP limit of 7501.1.2027
5(c)Other refrigeration equipment (not chillers, not points 4 and 6)GWP 150 or more1.1.2030

Points 3(b) and 3(c) deserve a note. 3(b) is written for HFCs, 3(c) for other fluorinated greenhouse gases. R-452A is an HFC and HFO blend, so which of the two applies can be argued — but the outcome is the same, because both dates have passed.

What does not catch it: point 5(b), which since 1 January 2025 prohibits any fluorinated greenhouse gas with a GWP of 2 500 or more in the same equipment. That is exactly the line that took out R-404A and R-507A. It is also the reason R-452A was designed.

The cascade exception in point 6 does not apply

Point 6 allows fluorinated greenhouse gases with a GWP of less than 1 500 in the primary refrigerant circuit of cascade systems. At ≈ 2 139, R-452A is above that limit and does not fall inside the exception.

Leak checks and the detection system

Article 5(1) sets from what quantity equipment is checked, and Article 5(6) how often. The duty falls on operators and on manufacturers of the equipment.

For Annex I gases the threshold is 5 tonnes of CO2 equivalent. At ≈ 2 139 that means 5 000 ÷ 2 139 ≈ 2.34 kg.

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-452A is 10 × 2 139 ÷ 1 000 ≈ 21.4 t CO2e — the bottom band, so checks at least every 12 months. The middle band starts at about 23.4 kg, and the 500 t CO2e threshold in Article 6(1), which makes a detection system mandatory, at about 234 kg. The detector itself is checked at least once every 12 months under Article 6(3).

Mobile equipment is inside the regime too

Article 5(3) brings in refrigeration units of refrigerated trucks and trailers, those of refrigerated light-duty vehicles, intermodal containers including reefers, and train wagons, as well as air conditioning and heat pumps in heavy duty vehicles, vans, non-road mobile machinery used in agriculture, mining and construction, trains, metros, trams and aircraft. For operators of the equipment in points (b) and (c), Article 5(5) defers paragraphs 1 and 6 until 12 March 2027.

Checks on the equipment in Article 5(2), points (a) to (e), and Article 5(3), points (a) and (b), are carried out by persons certified under Article 10. For the mobile equipment in point (c), Article 5(4) requires at least a training attestation.

For the intervals, see the guide to leak-check frequency.

Where R-452A stands as an R-404A alternative

The comparison is made on thresholds, not impressions. R-404A has a GWP calculated under Annex VI of roughly 3 922 and R-507A of 3 985. Both are above 2 500. R-452A, at ≈ 2 139, is not.

ThresholdR-404A / R-507AR-452A (≈ 2 139)
Article 13(3), servicing, limit 2 500CaughtNot caught
Annex IV point 5(b), from 1.1.2025, limit 2 500CaughtNot caught
Article 13(5), stationary refrigeration, from 1.1.2032, limit 750CaughtCaught
Annex IV points 4, 5(c), 6, limit 150CaughtCaught
Annex IV point 7(d), chillers above 12 kW, limit 750CaughtCaught

The result reads simply: R-452A solves today's problem for an R-404A type system, namely that it can no longer be serviced, but it does not solve the 2032 problem for stationary refrigeration. It is a transitional answer, and the length of the transition is known from the start.

Transport refrigeration is a different case

The manufacturer also offers R-452A for transport refrigeration. The classification differs there in two verifiable ways. First: the prohibition in Article 13(5) is expressly limited to stationary refrigeration equipment, so it does not reach the refrigeration units of trucks and trailers. Second: Annex IV contains no row for transport refrigeration units, so they are not touched by the placing-on-the-market limits in the table above. What does apply in full are the checks in Article 5(3), certification, the label and the record.

The manufacturer's documentation classifies R-452A as A1, that is, non-flammable in the industry classification scheme. The class does not come from the regulation, but it matters when choosing the alternative: many of the options below 750 are A2L, and there the site safety requirements come into play.

Work on the refrigeration units of trucks, trailers, light-duty vehicles, intermodal containers and train wagons falls expressly within the scope of Implementing Regulation (EU) 2024/2215, which sets out the certificate types.

For the full comparison of options, including the refrigerants below 150, see the guide to replacing R-404A and the R-404A page.

Label and record

The label. Article 12(1)(g) puts all fluorinated greenhouse gas containers under the labelling requirement, and Article 12(3) requires an indication that fluorinated greenhouse gases are contained, the accepted industry designation, the quantity in weight and in CO2 equivalent, and the GWP. Article 12(4) requires the label to be clearly legible and indelible and written in the official languages of the Member State of commercial destination.

Implementing Regulation (EU) 2024/2174 adds, in Article 1(3), the mandatory text “contains fluorinated greenhouse gases”, and in Article 1(4) points at the “GWP” column of Annexes I, II and III.

On retrofit. The last subparagraph of Article 12(3) requires equipment whose fluorinated greenhouse gases have been changed to be relabelled with updated information. If you move a system from R-404A to R-452A, the old label becomes false the moment you charge.

The record. For each piece of equipment subject to checks, Article 7(1) requires the quantity and type of gas, quantities added with dates, the quantity recovered, the origin of any gas added and whether it was recycled or reclaimed, the identity of the undertaking and of the person who did the work, and the dates and results of checks and repairs. Five years, by the operator and in copy by the servicing undertaking.

Who may buy it. Article 11(6) allows 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, temperature glide and discharge temperature are not in the regulation. Take them from the product's safety data sheet — section 2 for classification, section 3 for composition, section 9 for physical and chemical properties, section 14 for transport — in the format required by Regulation (EU) 2020/878, and from the manufacturer's documentation.

Hazard classification and labelling come from Regulation (EC) No 1272/2008, a separate regime from the F-gas label.

The regulation does not say whether R-452A suits a system designed for R-404A. Capacity, pressures, oil and seal compatibility, settings and the equipment manufacturer's approval are engineering and warranty questions.

For the difference between a straight changeover and a full retrofit, see the drop-in or retrofit guide.

Checklist

  • The GWP used is the binding column≈ 2 139 under Annex VI, not the AR5 figure in the product bulletin.
  • 1 January 2032 is in the plan for the installationArticle 13(5) catches it where it is stationary refrigeration other than a chiller.
  • Charge recorded in kg and in tonnes of CO2 equivalent≈ 2.34 kg is the 5 t CO2e threshold; 23.4 kg moves into the 6-month band.
  • Detector question answered above ≈ 234 kgArticle 6(1), with the annual detector check in Article 6(3).
  • Equipment purchases checked against Annex IVPoints 4, 5(c), 6, 7(b) and 7(d) catch it; point 5(b) does not.
  • For mobile equipment, the Article 5(3) regime is checkedWith the deferral to 12 March 2027 in Article 5(5) where it applies.
  • Equipment relabelled after the gas is changedArticle 12(3), last subparagraph.
  • Equipment record currentArticle 7(1), kept five years.
  • The servicing answer for after 2032 is decided in good timeReclaimed or recycled gas on the Article 13(5) conditions, conversion or replacement.

Frequently asked questions

What is the GWP of R-452A?

Roughly 2 139, calculated under Annex VI from the nominal composition 11 % R-32, 59 % R-125 and 30 % R-1234yf, with the binding values 675 and 3 500 from Annex I and 0.501 from Section 1 of Annex II. Annex VI allows a ± 1 % weight tolerance.

Can I service with R-452A today?

Yes. At ≈ 2 139 it is below the 2 500 threshold in Article 13(3) and 13(4), so it is not touched by the servicing bans that apply today.

What happens on 1 January 2032?

Article 13(5) prohibits, from that date, Annex I gases with a GWP of 750 or more for maintaining or servicing stationary refrigeration equipment other than chillers. R-452A is above the limit. Reclaimed gas with the Article 12(7) label and recycled gas on the conditions in that paragraph remain possible, with no expiry date.

Does the 2032 deadline apply to transport refrigeration?

No. Article 13(5) is expressly limited to stationary refrigeration equipment. The refrigeration units of trucks and trailers are outside it. The leak checks in Article 5(3) and the rest of the duties still apply.

Is R-452A a good replacement for R-404A?

In regulatory terms it solves the immediate problem: it clears the 2 500 line that stopped servicing with R-404A and R-507A. It does not solve the 2032 deadline for stationary refrigeration. The full comparison of options is in the guide to replacing R-404A.

At what charge do leak checks start?

At 5 tonnes of CO2 equivalent of Annex I gases, which is roughly 2.34 kg of R-452A.

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. The nominal composition and the safety class come from the manufacturer's documentation, cited separately.

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, no capacity data, no oil compatibilities and no retrofit procedure, and it does not confirm that R-452A may be used in any particular system. For those, use the safety data sheet, the equipment manufacturer's documentation and the refrigerant manufacturer's instructions.

General information prepared by EgoLog from the regulation and official Commission material. It is not legal advice and it is not an engineering assessment.

Work on the refrigerant circuit is carried out by competent persons certified under Article 10 of the regulation and Implementing Regulation (EU) 2024/2215. Annex IV can be amended, and the Commission may authorise time-limited exemptions under Article 13(6). Confirm the current text before you rely on a date commercially.

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