Enforcement of the EU's revised fluorinated gas regulation has begun cutting off high-GWP refrigerants from the commercial refrigeration supply chain, pressing equipment makers, service contractors, and food retailers to commit to natural or low-GWP alternatives ahead of tightening deadlines through 2032. Regulation (EU) 2024/573, adopted on 7 February 2024, entered into application on 11 March 2024, establishing the most ambitious HFC phase-down schedule in the bloc's regulatory history.
Background
The revised regulation targets an 80% reduction in HFC volumes placed on the EU market by 2030 and a full phase-out by 2050, measured in CO₂ equivalents relative to a 2015 baseline. It follows its 2015 predecessor and introduces significantly more product-specific bans alongside steeper quota steps. EU HFC production is capped from 2025 at 60% of average annual output from 2011 to 2013, declining to 15% by 2036. The inclusion of metered dose inhalers in the quota system from 2025-previously exempt-means the effective reduction in available refrigerant volume is steeper than headline percentages suggest, according to the European Commission's climate directorate.
Commercial refrigeration stands at the forefront of the transition. Unlike earlier rules, which primarily targeted high-capacity centralised systems, the current regulation extends product bans to self-contained commercial refrigeration equipment. The food retail and foodservice sectors-operators of supermarket display cases, standalone freezer cabinets, and catering units-are directly and immediately affected.
Details
From 1 January 2025, the placing on the EU market of commercial refrigerators and freezers containing F-gases with a GWP of 150 or higher became prohibited. Simultaneously, the use of virgin fluorinated refrigerants with a GWP of 2,500 or more for the servicing or maintenance of any refrigeration equipment was banned from 1 January 2025, with no minimum charge-size threshold-removing the 40-tonne CO₂ equivalent floor that had applied under the 2015 rules. Reclaimed or recycled variants of those same high-GWP gases retain a derogation until 1 January 2030, providing a limited service window for operators of legacy systems running on refrigerants such as R-404A (GWP 3,920).
A narrow set of specialist commercial equipment-including blast cabinets with 25-100 kg full-load capacity, artisanal gelato makers above 2 kW cooling capacity, ice makers producing 200-2,000 kg per 24 hours, and retarder prover cabinets-received a derogation under Commission Implementing Regulation (EU) 2024/2729 allowing continued sale through 30 June 2026, provided units are labelled under Article 12(2). This transition window reflects supply-chain lead times but does not alter the underlying prohibition.
Pressure on service companies is compounding. From 1 January 2032, newly produced refrigerants with a GWP of 750 or more may no longer be used for the maintenance or servicing of stationary refrigeration equipment (excluding chillers), signalling a long-term structural shift in service contract planning.
Market data indicate that natural refrigerant adoption in Europe's commercial sector is already well underway, driven by earlier rounds of regulation. According to ATMOsphere, Europe passed 100,000 sites using transcritical CO₂ refrigeration systems in 2025, with 111,650 food retail and industrial sites recorded as of December 2025-up from 95,600 in 2024. Europe also leads globally with 19.7 million self-contained hydrocarbon refrigerant cases and 5,650 low-charge ammonia systems, according to the same report. Jan Dusek, Co-Founder and COO of ATMOsphere, stated that "the conversation around natural refrigerants in commercial and industrial refrigeration in Europe has entered a new stage."
Despite this momentum, transition barriers persist. According to MarketsandMarkets analysis, transitioning to natural refrigerants such as CO₂, ammonia, and hydrocarbons requires technicians with advanced training due to pressure, toxicity, or flammability risks, and Europe currently faces a skills gap with too few trained installers. Transitioning to low-GWP or natural refrigerants often requires entirely new systems, safety upgrades, and specialised components, all of which involve higher initial investment than traditional HFC-based equipment-a constraint particularly acute for small and medium-sized operators.
HFO-based blends are positioned as an interim pathway where natural refrigerant deployment remains technically constrained, though uncertainty persists. Five EU member states have submitted a proposal to the European Chemicals Agency to assess PFAS restrictions that could encompass certain HFO refrigerants, and a European Commission decision on that question is anticipated.
Outlook
From 1 January 2026, bans on domestic refrigerators and self-contained standalone refrigeration equipment using F-gases with a GWP of 150 or more take effect, extending the compliance perimeter to a broader equipment category. Stationary chiller restrictions phase in between 2027 and 2030 for units below 12 kW rated capacity. The European Commission's F-Gas Portal, through which importers of pre-charged equipment exceeding 1,000 tonnes CO₂ equivalent must register and submit verified documentation, serves as the primary compliance tracking mechanism for regulators and market participants. Refrigeration contractors and procurement teams are advised to audit existing equipment, assess refrigerant GWP classifications, and initiate supplier engagement on compliant replacements ahead of each successive deadline.
