Refrigerant servicing bans 2025, 2030, 2032: what is allowed?

What does the rule actually say?

The servicing bans are in Article 13 of the F-gas Regulation, Regulation (EU) 2024/573. They cover the use of F-gases to maintain and service existing equipment. New equipment falls under different rules, the product bans in Annex IV. For most refrigeration contractors and equipment owners, three dates matter:

• •1 January 2025, refrigeration: virgin refrigerant with a GWP of 2,500 or more may no longer be used to maintain or service any refrigeration equipment. For equipment with a charge of 40 tonnes of CO2 equivalent or more, this already applied from 2020. Reclaimed and recycled refrigerant remains allowed until 1 January 2030.
• •1 January 2026, air conditioning and heat pumps: the same ban on virgin refrigerant with a GWP of 2,500 or more. Reclaimed and recycled refrigerant remains allowed here until 1 January 2032.
• •1 January 2032, stationary refrigeration: virgin refrigerant with a GWP of 750 or more may no longer be used for maintenance or servicing. Chillers are excluded. For reclaimed and recycled refrigerant, the Regulation sets no end date here.

The refrigeration bans do not apply to military equipment or to equipment designed to cool products below minus 50 °C. The 2032 ban also does not apply to equipment that cools nuclear power stations.

Which refrigerants are affected?

It comes down to GWP, the global warming potential relative to CO2 as set out in Annex I of the Regulation. A few common refrigerants:

• •R404A (GWP 3,922) and R507A (GWP 3,985): above 2,500, so caught by the 2025 ban and later by the 2032 ban as well.
• •R410A (GWP 2,088), R407C (GWP 1,774) and R134a (GWP 1,430): below 2,500, so not affected by the 2025 and 2026 bans. In stationary refrigeration other than chillers, they do fall under the 2032 ban.
• •R448A and R449A (GWP around 1,400): common R404A replacements. No restriction today, but above 750, so in stationary refrigeration they are also caught by the 2032 ban.

What conditions apply to reclaimed and recycled refrigerant?

Both exemptions come with conditions. Reclaimed refrigerant must be in a cylinder labelled in line with Article 12(7): a statement that it has been reclaimed, the batch number, and the name and address of the reclamation facility in the EU.

Recycled refrigerant must have been recovered from the same kind of equipment, and may only be used by the company that recovered it or by the company for which the recovery was carried out. In other words, you cannot simply buy recycled gas on the market. A certified contractor can buy reclaimed refrigerant.

I own an R404A system. What now?

Your system may keep running. Using an existing R404A system is not prohibited. The problem only arises when it needs topping up, after a leak or during maintenance. Broadly, you have three options:

1. 01Retrofit to a lower-GWP refrigerant such as R448A or R449A. Often the quickest route, but these refrigerants also fall under the 2032 ban for stationary refrigeration if you still want to top up with virgin gas by then.
2. 02Replace the system with one using a natural refrigerant or a low-GWP alternative. More expensive in the short term, but the servicing bans no longer affect you.
3. 03Keep running on reclaimed or recycled R404A until 1 January 2030. That works if the system is leak-tight and your contractor can source reclaimed refrigerant. After that, something still has to change.

Which option fits depends on the age and condition of the system, the charge size and how often it leaks. For an old system that regularly loses refrigerant, running on reclaimed gas is usually a postponement rather than a solution.

Where does reclaimed R404A come from?

From systems being decommissioned or retrofitted. Virgin R404A may no longer go into existing refrigeration equipment, so no new gas is entering the servicing market. Every kilogram of R404A recovered during a retrofit or strip-out is feedstock for the reclaimed R404A that other owners need to keep their systems running until 2030.

Anyone decommissioning an R404A system is holding something other people need. Recovered refrigerant is not just a disposal cost. It is the stock the rest of the market will run on for the next few years.