F-Gas Regulation for refrigeration systems: Continue operating, relieve, or replace?

The refrigeration system is operating, the facility is comfortably cool, and production is stable. From an operational perspective, there is little reason to focus on refrigerants. Nevertheless, the F-Gas Regulation (EU) 2024/573 is changing the framework within which refrigeration systems are operated, maintained, and upgraded. This article explains what this means for existing refrigeration systems, their economic viability, and upcoming investment decisions, while distinguishing between legal, technical, and economic aspects.

This is not a legal guide; the obligations for a specific system can only be clarified on a case-by-case basis. Knowing where your system stands now allows you to make decisions calmly rather than reacting under time pressure later.

‍Key Facts: KNOW THE DEADLINES, QUESTION YOUR REFRIGERANT NEEDS

• The Regulation (EU) 2024/573 has been in effect since March 11, 2024, and has replaced Regulation (EU) No. 517/2014.
• Operators have their own obligations: leak checks, record-keeping, and certified personnel. Whether and to what extent these apply depends on the refrigerant, the charge amount, and the type of system.
• For maintenance, the regulation distinguishes between refrigeration systems and air conditioning/heat pump systems: As of January 1, 2025, F-gases with a GWP of 2,500 or more are generally prohibited for use in refrigeration systems, and as of January 1, 2026, for air conditioning and heat pumps. Limited exceptions apply.
• A blanket operating ban for existing systems is not provided for in the regulation, but it does change maintenance, cost risks, and planning certainty.
• Operators have three options: continue operation, reduce the chiller load, or replace it. Even without a complete new build, you can proceed step by step: first load and air distribution, then load reduction, then targeted supplementation.
• Refrigerant-free hall cooling is possible with two-stage adiabatic cooling, but not for every application. For tight tolerances, hybrid solutions are an option.
• The F-Gas Regulation is not a PFAS ban; the ECHA's PFAS process is a separate matter.
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F-Gas Regulation for refrigeration systems: What it means for operators

Regulation (EU) 2024/573 addresses three key areas:

• Quantity: A quota system is gradually reducing the amount of hydrofluorocarbons (HFCs) available in the EU until they are phased out in 2050.
• Usage and new equipment: Bans based on global warming potential (GWP) affect new equipment and the maintenance of existing systems. Article 13 regulates maintenance according to system type: For refrigeration systems, F-gases with a GWP of 2,500 or more have generally been prohibited since January 1, 2025 (this already applied to large systems previously), and for air conditioning systems and heat pumps since January 1, 2026. Temporary or specific exemptions apply to recycled and reclaimed gases as well as certain applications.
• Operator obligations: The operator is the party that exercises actual control over the technical functioning of the system. They must arrange for leak checks, keep records, and employ certified personnel. Whether and to what extent these obligations apply depends on the refrigerant, the charge size, and the type of system, and there are exceptions. As a rule, the larger the charge, the more frequent the inspections, and very large systems additionally require a leak detection system.

The regulation applies directly in all EU member states; Germany and Austria supplement it with national regulations, for example regarding certification and enforcement. Switzerland is not an EU member and has its own refrigerant regulations. For locations in multiple countries, the requirements should be clarified for each site.

This leads to the guiding question of this article: Must an existing refrigeration system actually be replaced by a new chiller, or can the cooling demand be reduced through a different technical approach?

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The misconception: "My existing system is exempt"

This assumption is widespread but only partially correct. The regulation does not provide for a blanket ban on the operation of existing refrigeration systems. However, it does change what can be used to maintain a system, and it requires operators to carry out inspections and maintain documentation. Anyone who overlooks this is planning the remaining service life of their system based on an assumption that does not apply equally to all refrigerants.

Added to this is an economic assessment that is not found in the text of the law: As the available quantity of fluorinated refrigerants decreases over the years, this can affect availability and prices. The extent and timing depend on the refrigerant, the market, and the region, and cannot be predicted in general terms. For systems with a long remaining service life, this is a risk.

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First the load, then the machine: the INFRANOMIC^® Engineering perspective

Many refrigeration systems are oversized because the assumed cooling load is higher than necessary. The approach taken by INFRANOMIC^® Engineering starts from the value-added process and looks at the entire system rather than individual units. For the refrigeration issue, this means:

• Identify heat loads: Where does the heat come from, and what portion can be reduced or dissipated at the source?
• Check air distribution: It is a key factor in determining how much cooling reaches where it is actually needed.
• Relieve the existing chiller: With pre-cooling and retrofitting, the existing machine can operate under better conditions, provided the system is suitable for it.
• Evaluate refrigerant-free hall cooling: Sustainable hall conditioning can replace compression cooling entirely or in part; suitability is project-specific.
• Hybrid solutions for tight tolerances: Where defined temperature and humidity conditions apply, a mechanical stage remains, the size of which is determined by the project.

This does not mean that two-stage adiabatic cooling can replace every refrigeration system. It is the order of the questions that matters before a replacement investment is decided upon.

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Three paths for operators: continue operation, relieve, replace

There is more room for maneuver between "do nothing" and "replace everything" than many assume. The paths differ in their dependence on fluorinated refrigerants and in the required investment:

Continue operation: when the system is fulfilling its purpose

Continuing operation makes sense if the system is running reliably, has performance reserves in summer, and the service partner is certified and well-coordinated. A prerequisite is a comprehensive system inventory: refrigerant, refrigerant charge, inspection and documentation obligations, and the consequences of maintenance regulations for the remaining service life.

The economic risk lies less in the law than in predictability: Refrigerant prices, availability, and service costs can change. Anyone continuing operation should set a date for a re-evaluation.

Reduce the load: improving operating conditions for the existing chiller

A chiller loses performance in midsummer because the intake air or the air at the dry cooler is hot. With two-stage adiabatic pre-cooling, this air is cooled before it reaches the machine. The chiller can then provide greater cooling capacity or consume less electricity at the same load. Whether and to what extent this is possible is project-specific and depends on the cooling technology, location, operating hours, and load profile, as the article Renewing refrigeration systems: When is a retrofit worth it instead of a complete replacement? shows.

Relieving the system can be a comparatively small intervention; whether the system is suitable for this is checked on a case-by-case basis. It does not eliminate the refrigerant issue: the chiller remains in the system, with its refrigerant and its obligations. A calculation for the specific system will show whether and how quickly the measure pays off.

Replace: when a new solution makes sense, but not automatically the same one

Replacing can make sense if the system is at the end of its service life, central components are no longer working reliably, or production requirements have changed. The obvious choice is then to replace it with a similar unit. Whether a new compression chiller of the same size is the best solution should only be decided after checking the actual cooling load. Two questions help with this: How much cooling capacity is required after load reduction and improved airflow, and what temperature and humidity requirements actually apply? Depending on the answer, three directions are possible:

• New compression refrigeration using low-GWP or natural refrigerants. This brings its own set of requirements, such as flammability or toxicity, and can also trigger mandatory testing obligations.
• Refrigerant-free hall cooling with two-stage adiabatic cooling, which uses water evaporation instead of a refrigerant circuit. Compared to compression refrigeration, energy consumption for cooling can be significantly reduced. The exact extent is determined by a project-specific simulation using weather data, load profiles, and a comparison system. Water consumption is also project-dependent. Read more in the article: Cooling a hall without air conditioning.
• Hybrid solutions: where defined temperature and humidity conditions apply, such as in precision air conditioning, the adiabatic stage can handle part of the cooling, allowing the mechanical stage to be downsized and run only when necessary. The extent to which this is possible and the required size of the mechanical stage depend on the project. The issue of refrigerants does not disappear, but it may involve a smaller machine.

Economic considerations extend beyond the initial investment: energy costs based on operating hours and load profile, maintenance and refrigerant costs, space requirements, water availability, expandability, and the risk of summer downtime. Reliable statements regarding savings or amortization are only possible once a calculation has been performed for the specific facility.

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Even without a complete rebuild: A step-by-step approach to the right solution

Not every facility needs a new system, and not every budget allows for one. INFRANORM^® therefore plans solutions that can be implemented in stages and incorporate existing technology wherever possible. A typical approach:

1. Understand existing conditions and loads: The inventory assessment reveals the sources of heat and identifies improvements that can be made to airflow and operating methods.
2. Relieve the existing chiller: Where the system is suitable, pre-cooling or a retrofit can be the first, relatively small step.
3. Targeted conditioning of facility areas: Sustainable Hall Conditioning is a modular system. You can start in individual areas and expand later.
4. Mechanical stage only when needed: If temperature and humidity requirements demand it, a chiller is added in hybrid operation, sized according to the project requirements.

One example is the project Ceramdis in Elsau: There, an existing two-stage adiabatic hall cooling system was supplemented during ongoing operations with a continuously variable chiller providing up to 154 kW. According to the project page, operating costs are up to 76% lower than with a chiller-only system. This is an individual project; these figures cannot be applied to other facilities.

This allows the investment to be spread across several stages that can be evaluated individually.

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Where adiabatic cooling reaches its limits

Adiabatic cooling is not a universal replacement for mechanical refrigeration. Its effectiveness depends on the outside air and decreases when outdoor humidity is very high. It requires sufficient outside air, a suitable facility, and careful design of air volumes and airflow. For very tight temperature and humidity tolerances, a mechanical stage remains useful. Whether a facility is suitable is determined by design calculations based on weather data and load profiles, not by a rule of thumb.

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F-Gas Regulation and PFAS: two separate issues

The regulation itself points out that some fluorinated greenhouse gases are per- and polyfluoroalkyl substances (PFAS) or degrade into PFAS. It also refers to a proposal submitted in 2023 to the European Chemicals Agency (ECHA) to restrict PFAS, which also includes fluorinated greenhouse gases. This is a separate process with its own timeline, and the F-Gas Regulation is not a PFAS ban. Anyone planning new systems should monitor both developments.

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Five questions operators should check now

Five questions are enough for an initial assessment:

1. Refrigerant and charge: Which refrigerant does each system contain, what is the charge, and how many tons of CO₂ equivalent does that amount to?
2. Obligations: Are leak checks, records, and, if applicable, leak detection systems in place and up to date?
3. Service partner: Is the contracted company certified for these activities?
4. Maintenance regulations: Is the refrigerant subject to a usage ban during maintenance, and what does that mean for the remaining service life?
5. Load and alternatives: Is the system running at its limit, and could the heat load be reduced or the chiller relieved through pre-cooling?
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Conclusion: Check the assumptions first, then invest.

The F-Gas Regulation does not mandate an immediate replacement, but it will change the conditions for every system using fluorinated refrigerants over the coming years. Those who understand their inventory, obligations, and options early on can decide whether to continue operation, reduce the load, or replace equipment based on technical suitability and economic efficiency, rather than under time pressure. The first question is rarely "Which new chiller?" but rather "How much cooling do we actually need?". INFRANORM^® supports this process from the initial assessment and calculations through to implementation during ongoing operations.

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FAQ

What is the F-Gas Regulation (EU) 2024/573?

The EU regulation on fluorinated greenhouse gases. It has been in effect since March 11, 2024, replacing Regulation (EU) No 517/2014, and governs quantities, bans based on global warming potential, and operator obligations.

Do I have to replace my existing refrigeration system?

Not necessarily. The regulation does not impose a general ban on the operation of existing systems, but it does limit the use of F-gases during maintenance and requires operators to perform inspections and keep records. Whether a replacement makes sense depends on the refrigerant, the condition of the system, the load, and economic viability.

What obligations do refrigeration system operators have?

Depending on the refrigerant, charge size, and system type, these include leak checks, record-keeping, and the use of certified personnel. Very large systems also require a leak detection system. A certified specialist company can clarify what applies to a specific system.

Does a low GWP exempt me from inspection requirements?

Not automatically. Obligations depend on the refrigerant, the charge size, and the type of system, and there are exceptions. Therefore, a low global warming potential alone does not determine whether inspection and documentation requirements apply.

How can an existing chiller be relieved?

For example, through two-stage adiabatic pre-cooling of the intake air or the air at the dry cooler, supplemented by measures addressing heat load and airflow. Whether the system is suitable for this and how significant the effect will be must be assessed on a project-specific basis.

Can I cool halls without using fluorinated refrigerants?

Yes, for example with two-stage adiabatic cooling, which uses water evaporation instead of a refrigerant circuit. It is suitable for almost any application. If there are very strict tolerances regarding humidity, a mechanical auxiliary stage in hybrid operation may be useful, the size of which is determined on a project-specific basis.

Are all F-gases also PFAS, and is there a PFAS ban?

Some fluorinated greenhouse gases are PFAS or degrade into PFAS. The PFAS restriction is a separate process at ECHA and is not part of the F-Gas Regulation.