Quick answer
R-404A is a blend, so it is not listed with a single GWP in Annex I. Calculated under Annex VI from its nominal composition — 44 % R-125, 52 % R-143a, 4 % R-134a — and the binding Annex I values, it comes to about 3 922. R-507A, as a 50/50 blend of R-125 and R-143a, comes to about 3 985.
Both sit far above the first threshold. Since 1 January 2025, Article 13(3) of Regulation (EU) 2024/573 prohibits using a fluorinated greenhouse gas with a GWP of 2 500 or more to maintain or service any refrigeration equipment, whatever the charge.
So the question is no longer whether to move off R-404A. It is which of three routes you take, and by when.
| Route | Runs until | What it needs |
|---|---|---|
| Reclaimed R-404A | 1 January 2030 | Container labelled under Article 12(7) — “100 % Reclaimed”, batch number, facility name and Union address |
| Retrofit to a lower-GWP gas | Depends on the GWP you land on | Below 2 500 today; below 750 to survive the 2032 line for stationary refrigeration |
| Replace the equipment | Longest | New plant specified against the Annex IV dates for its category and capacity |
The two lines that decide everything
Article 13 draws two GWP thresholds across the servicing of refrigeration equipment, and a replacement gas has to be judged against both.
| From | Equipment | Gas prohibited for servicing |
|---|---|---|
| 1 January 2025 | Any refrigeration equipment | GWP 2 500 or more |
| 1 January 2032 | Stationary refrigeration, chillers excluded | GWP 750 or more, Annex I gases |
A replacement chosen only against the first line buys about six years. A replacement below 750 clears both.
| Gas | GWP | Servicing today | Stationary refrigeration from 2032 |
|---|---|---|---|
| R-404A | ≈ 3 922 (calculated) | Banned | Banned |
| R-507A | ≈ 3 985 (calculated) | Banned | Banned |
| R-410A | ≈ 2 088 (calculated) | Allowed | Banned |
| R-407C | ≈ 1 774 (calculated) | Allowed | Banned |
| R-134a | 1 430 (Annex I) | Allowed | Banned |
| R-32 | 675 (Annex I) | Allowed | Allowed |
Blend figures are calculated under Annex VI from nominal compositions and the binding Annex I values, with the ± 1 % weight tolerance the annex allows. Where the number matters commercially, take it from the product's own documentation or label.
The 2032 line in Article 13(5) applies to stationary refrigeration other than chillers. A chiller and a cold room are not on the same clock.
The reclaimed window, and its conditions
Article 13(3) does not apply, until 1 January 2030, to reclaimed gases listed in Annex I with a GWP of 2 500 or more used for the maintenance or servicing of existing refrigeration equipment — provided the containers are labelled in accordance with Article 12(7).
Article 12(7) requires containers of reclaimed gas to carry an indication that the substance has been reclaimed, plus the batch number and the name and address of the reclamation facility in the Union. Implementing Regulation (EU) 2024/2174 sets the wording: “100 % Reclaimed” where there are no virgin substances, or, for mixtures, where virgin additions to adjust the composition do not exceed 10 % of the mass.
Recycled gas is different. The same paragraph allows recycled gases above 2 500 only where they have been recovered from that kind of equipment, and only for use by the undertaking that carried out the recovery, or the undertaking for which the recovery was carried out. It cannot be bought in.
It closes on 1 January 2030 and it only covers existing equipment. Treat it as time to schedule the change, not as a reason to postpone the decision.
The equipment side of the problem
Servicing is one restriction; what may be sold as new equipment is another. Annex IV rows a commercial refrigeration business meets most often:
| Annex IV point | Equipment | Date |
|---|---|---|
| 6 | Multipack centralised commercial systems of 40 kW or more, Annex I gases with GWP 150 or more | 1 January 2022 |
| 3(c) | Commercial self-contained refrigerators and freezers, other F-gases with GWP 150 or more | 1 January 2025 |
| 4 | Any self-contained refrigeration equipment except chillers, F-gas with GWP 150 or more | 1 January 2025 |
| 5(b) | Other refrigeration equipment (not chillers, not points 4 and 6), GWP 2 500 or more | 1 January 2025 |
| 5(c) | The same equipment, GWP 150 or more | 1 January 2030 |
Point 6 leaves one opening: in the primary refrigerant circuit of a cascade system, gases with a GWP below 1 500 may still be used.
Parts are not caught. Article 11(1) allows parts needed to repair or service existing equipment listed in Annex IV, provided the work does not increase the capacity, increase the amount of gas, or change to a gas with a higher GWP. A compressor for a plant already in service is fine; the same compressor in a new unit is not.
What a retrofit changes besides the gas
This is the part that gets forgotten, and it is where a retrofit can pay for itself.
The leak-check interval moves. Article 5(6) sets the frequency by charge in tonnes of CO2 equivalent, which is kilograms × GWP ÷ 1 000. Change the GWP and the band can change.
| Charge (Annex I gases) | Check at least | With a leakage detection system |
|---|---|---|
| 5 to under 50 t CO2e | Every 12 months | Every 24 months |
| 50 to under 500 t CO2e | Every 6 months | Every 12 months |
| 500 t CO2e or more | Every 3 months | Every 6 months |
Worked example. A 150 kg charge of R-404A is 150 × 3 922 ÷ 1 000 ≈ 588 t CO2e — in the top band, so checks every 3 months, and because it is at or above 500 t CO2e, Article 6(1) makes a leakage detection system mandatory. Retrofit the same 150 kg to a gas with a GWP of around 1 400 and the charge becomes 150 × 1 400 ÷ 1 000 = 210 t CO2e — the middle band, checks every 6 months, and the mandatory detector requirement no longer applies.
The tonnes-of-CO2-equivalent figure is what the intervals run on, and it is not proportional to anything you can eyeball. Recalculate it every time the charge or the gas changes, and enter the new figure in the equipment record.
The label has to be redone. The last subparagraph of Article 12(3): where products or equipment have been retrofitted and the fluorinated greenhouse gases have been changed, they must be relabelled with updated information.
The record has to reflect it. Article 7(1)(a) requires the quantity and type of gases contained; (b) the quantities added with dates; (c) the quantity recovered; (d) whether added gas was recycled or reclaimed, with the facility's name, Union address and certificate number where applicable; and (e) the identity of the undertaking and the natural person who did the work.
How to work through it, site by site
List every R-404A and R-507A plant with its charge
Kilograms and tonnes of CO2 equivalent. Without the list none of the dates can be applied.
Separate what is critical from what is not
A plant whose failure stops the customer's business needs a scheduled change, not a wait-and-see.
Decide the target GWP first, then the product
Below 2 500 is the minimum to be legal today. Below 750 is what survives 1 January 2032 for stationary refrigeration other than chillers.
Check the reclaimed supply if you plan to bridge
Ask the supplier for the container label with “100 % Reclaimed”, the batch number and the reclamation facility's name and Union address. The window closes 1 January 2030.
Take the engineering answer from the manufacturer
Capacity, pressures, glide, oil and component ratings are equipment questions. The regulation says what is permitted, not what will work.
Check the certification you will need afterwards
If the replacement is a hydrocarbon, CO2 or ammonia, the certificate types under Implementing Regulation (EU) 2024/2215 differ — A1 and A2 cover hydrocarbons, B covers CO2, C covers ammonia.
Recalculate the check interval and the detector requirement
New GWP, new tonnes of CO2 equivalent, possibly a new band under Article 5(6) and a different answer under Article 6.
Relabel and update the record on the same visit
Article 12(3) for the label, Article 7(1) for the record. Doing it later means doing it twice.
Common mistakes
- Choosing a replacement only against the 2 500 line. It works until 1 January 2032 for stationary refrigeration other than chillers, and then the problem returns.
- Assuming recycled gas can be bought in. Article 13 restricts it to the undertaking that recovered it, or the one it recovered for.
- Accepting reclaimed gas without the label. The exemption is conditional on labelling under Article 12(7).
- Using the 20-year GWP column. Annex I marks it for information only; the thresholds run on the first column.
- Increasing the charge during the retrofit. That takes the job outside the Article 11(1) parts derogation.
- Leaving the old label on. Article 12(3) requires relabelling after a retrofit that changes the gas.
- Keeping the old check interval. The interval follows tonnes of CO2 equivalent, which changed with the GWP.
- Forgetting the detector question. Article 6(1) makes a leakage detection system mandatory at 500 t CO2e or more — and a retrofit can move a plant across that line in either direction.
Checklist
- Every R-404A and R-507A site listedWith charge in kilograms and in tonnes of CO2 equivalent.
- No virgin top-ups since 1 January 2025Article 13(3) applies to any refrigeration equipment.
- Reclaimed supply verified if used as a bridge“100 % Reclaimed”, batch number, facility name and Union address.
- Target GWP decided before the productBelow 750 for a stationary refrigeration answer that survives 2032.
- Equipment purchases checked against Annex IVBy category and rated capacity, including the cascade opening in point 6.
- Manufacturer sign-off on the technical changeCapacity, pressures, oil and components.
- Certification checked for the new refrigerantHydrocarbons under A1 or A2, CO2 under B, ammonia under C.
- Tonnes of CO2 equivalent recalculatedNew check interval under Article 5(6), and the Article 6 detector question re-answered.
- Label and record updated on completionArticle 12(3) and Article 7(1).
Frequently asked questions
Can I still top up an R-404A system?
Not with virgin gas. Since 1 January 2025, Article 13(3) prohibits using a gas with a GWP of 2 500 or more to maintain or service any refrigeration equipment. Reclaimed gas is possible until 1 January 2030 for existing equipment, where the container is labelled under Article 12(7).
What is the GWP of R-404A?
It is a blend, so it is not listed as a single value in Annex I. Calculated under Annex VI from its nominal composition and the binding Annex I values it comes to about 3 922. Annex VI allows a ± 1 % weight tolerance, so take the exact figure from the product documentation.
What should I replace it with?
The regulation sets the constraint, not the product: below a GWP of 2 500 to be lawful for servicing today, and below 750 to remain lawful for stationary refrigeration other than chillers from 1 January 2032. Which product fits your plant is an engineering question for the equipment manufacturer's documentation.
Do I have to change the equipment or just the gas?
That depends on the plant. A retrofit is a gas change on existing equipment; parts for it remain available under the Article 11(1) derogation provided capacity, charge and GWP do not increase. New equipment has to meet the Annex IV limits for its category and capacity.
Does a retrofit change my leak-check interval?
It can. Article 5(6) sets the interval by charge in tonnes of CO2 equivalent, which is kilograms × GWP ÷ 1 000. A lower GWP lowers the figure and can move the plant into a longer interval — and below 500 t CO2e the mandatory leakage detection system under Article 6(1) no longer applies.
Do I need to relabel after a retrofit?
Yes. The last subparagraph of Article 12(3) requires products and equipment that have been retrofitted with different fluorinated greenhouse gases to be relabelled with updated information.
Can I buy recycled R-404A from another company?
No. Article 13 allows recycled gases above the threshold only where recovered from that kind of equipment and only for use by the undertaking that carried out the recovery, or the undertaking for which it was carried out.
What happens on 1 January 2030?
The reclaimed and recycled exemption in Article 13(3) ends for refrigeration. Annex IV point 5(c) also takes effect that day, extending the placing-on-market prohibition for that equipment category to gases with a GWP of 150 or more.
Official sources
Articles 5, 6, 7, 11, 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 covers what the regulation permits. It does not recommend a refrigerant for any specific plant — capacity, pressures, glide, oil compatibility, component ratings and the safety assessment of the installation are engineering questions answered by the equipment manufacturer's documentation.
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.
Calculated GWP figures here follow Annex VI from nominal compositions. Where a figure carries commercial weight, take it from the product's own documentation or label.