Quick answer. Regulation (EU) 2024/573 replaced 517/2014 on 11 March 2024 and tightens the placing-on-the-market rules for self-contained commercial refrigeration across 2025 and 2026, so HFC-charged plug-in cabinets are being pushed out of the EU market in favour of R290 and CO2. An importer of pre-charged equipment also needs HFC quota authorisation, a declaration of conformity, third-party verification and F-gas Portal registration before customs will clear the goods. In practice, most buyers of display cabinets, bottle coolers and wine cabinets are switching specifications to R290 with a charge under 500 g per circuit and to IEC 60335-2-89:2019 construction.
The commercial consequence is blunt: a cabinet specified in 2023 with R134a or R404A may be unsellable in the EU by the time it clears the port. Refrigerant choice is now a customs question, not an engineering preference.
Below is what changes, what it costs, and the document set we prepare per shipment.
What Regulation (EU) 2024/573 actually changes
Three mechanisms matter to an importer of finished cabinets.
First, the HFC quota phase-down. The allocation curve drops sharply after 2024 and reaches zero by 2050, with the steepest single step landing in 2025 — bulk HFC availability inside the EU falls faster than most price lists have adjusted for. R404A (GWP 3922 on the AR4 basis used in the F-gas annexes) and R134a (GWP 1430) reclaim and service prices follow that curve.
Second, product bans in Annex IV. Self-contained refrigeration equipment containing fluorinated gases with a GWP of 150 or more is barred from being placed on the EU market from 1 January 2025, and the scheduled 2026 step extends the restriction to self-contained refrigeration equipment containing fluorinated greenhouse gases at all, except where safety requirements at the installation site make it unavoidable. Centralised multipack systems of 40 kW rated capacity or above have been restricted since 2022 to primary-circuit refrigerants below GWP 150, with a cascade exception up to GWP 1500.
Third, importer obligations. Pre-charged equipment is treated as an HFC import: the quantity in the circuit counts against quota, and the paperwork must exist before the declaration, not after.
The chemical scope sits alongside REACH and the PFAS restriction dossier under assessment at ECHA, which covers several HFO and HFC substances as PFAS by the OECD definition. That file is worth tracking because it can move faster than the F-gas timetable — see the ECHA PFAS restriction pages.
Refrigerant options for imported cabinets
For plug-in commercial equipment the practical shortlist is short. Numbers below are the values used for specification and charge-limit work; verify the GWP figure against the annex version in force at the time of shipment.
| Refrigerant | GWP (AR4) | ISO 817 class | Typical charge, plug-in cabinet | EU status after 2026 step |
|---|---|---|---|---|
| R404A | 3922 | A1 | 350–900 g | Barred in new self-contained equipment |
| R134a | 1430 | A1 | 150–450 g | Barred in new self-contained equipment |
| R448A / R449A | 1387 / 1397 | A1 | 300–800 g | Above the 150 threshold; service-side only |
| R513A | 631 | A1 | 200–500 g | Above the 150 threshold |
| R290 (propane) | 3 | A3 | 60–495 g | Compliant; the volume route for display cabinets |
| R744 (CO2) | 1 | A1 | Transcritical, 90–120 bar design | Compliant; used where charge or ignition rules block A3 |
| R600a (isobutane) | 3 | A3 | 40–150 g | Compliant; small static coolers, wine cabinets |
The 500 g figure is the hinge. IEC 60335-2-89:2019 raised the permitted flammable refrigerant charge in commercial refrigerating appliances from 150 g to 500 g, which is what makes multi-deck open display cabinets and larger bottle coolers viable on R290 at all. Anything built to the pre-2019 edition is a 150 g machine, and retrofitting the charge is not a paperwork exercise — it changes evaporator circuiting, compressor selection, the electrical enclosure sealing and the leak-simulation test evidence.
Safety classification and the underlying test methods sit with the ISO refrigerant standards; the designation and safety class scheme is ISO 817, and system-side safety requirements are in ISO 5149. Independent work on hydrocarbon charge distribution and flammable-envelope duration in cabinet leak scenarios is available through the International Journal of Refrigeration.
Importer paperwork that customs will check
Quota authorisation before the bill of lading
Pre-charged equipment cannot be released for free circulation unless the HFC contained in it is covered by quota. That means an authorisation issued to the importer, drawn against a quota holder, and recorded in the F-gas Portal. Registration is a prerequisite, and the portal linkage to the EU customs Single Window means the declaration is validated electronically rather than at a desk.
Declaration of conformity and verification
Each consignment of pre-charged equipment needs a declaration of conformity stating that the contained HFCs are accounted for within the quota system, retained for five years, and verified by an independent auditor accredited under the EU ETS or by a national verifier. Practically, buyers should hold the DoC, the verification statement and the charge record per model before the container is booked.
Labelling
The equipment label must state that it contains fluorinated greenhouse gases, the industry designation of the refrigerant, the mass in kilograms, the CO2-equivalent tonnage and the GWP. Hydrocarbon units carry flammability marking under the appliance standard instead. Label wording in the destination language is the single most common reason cabinets get held.
Ecodesign and energy labelling are separate files
Refrigerating appliances with a direct sales function fall under Regulation (EU) 2019/2024 and the energy label under 2019/2018, with an EPREL registration required before placing on the market. F-gas compliance does not substitute for this. A cabinet can be fully R290 and still be blocked for a missing EPREL entry or a wrong Energy Efficiency Index declaration.
Pre-shipment compliance checklist
| # | Item | Evidence to hold on file | Owner |
|---|---|---|---|
| 1 | Refrigerant below GWP 150, or hydrocarbon | Nameplate photo + charge record per serial | Factory |
| 2 | Charge within IEC 60335-2-89:2019 limit | Test report, edition year stated | Factory / lab |
| 3 | CE marking and EU Declaration of Conformity | Signed DoC listing applied standards | Manufacturer |
| 4 | F-gas label in destination language | Artwork proof, per-market | Factory |
| 5 | Quota authorisation, if any HFC present | Portal authorisation reference | Importer |
| 6 | Independent verification statement | Auditor report, 5-year retention | Importer |
| 7 | EPREL registration and energy label | EPREL model ID, EEI calculation | Manufacturer |
| 8 | Leak-tightness and pressure test | Helium or equivalent leak test record | Factory |
| 9 | Electrical safety on flammable circuits | Component list, sealed enclosure evidence | Factory |
| 10 | Service instructions and technician requirements | Manual with A3 handling section | Manufacturer |
What the switch means on the factory floor
Moving a display cabinet line from R134a to R290 is not a drop-in. On our own builds the changes that consume engineering time are the compressor swap to a hydrocarbon-rated unit with a matched oil charge, re-circuiting the evaporator to hold capacity at a lower mass flow, replacing non-sparking electrical components inside the refrigerated volume, and re-running the pull-down test to confirm the cabinet still holds its temperature class after the charge reduction. A 380 g R290 charge behaves differently from 450 g of R134a at 32 °C / 65 % RH ambient, and the difference shows up as recovery time after door openings rather than as steady-state temperature.
Buyers should also budget for the storage and handling side: hydrocarbon charging stations, ventilation and gas detection in the charging bay, and technician training. Occupational exposure and flammable-atmosphere guidance is set out by OSHA for non-EU plants and mirrored by ATEX in the EU. On the alternatives side, the US refrigerant listing decisions published by EPA under the SNAP program are a useful cross-check when a buyer sells into both markets from one SKU.
As a manufacturer supplying direct, we handle the specification lock at the quotation stage rather than at inspection: refrigerant, charge mass, standard edition and label language are fixed in the pro forma. Custom cabinet dimensions, glass door configuration, shelving and voltage are set in the same document, so the compliance file and the production drawing carry identical data. Sample builds run at MOQ 1 unit for a new model, with 30–45 day lead time for production orders and full container loads consolidated per market.
If you are re-specifying a range for 2026, our commercial refrigeration product lines are already built around R290 and R600a circuits, and we can quote the equivalent CO2 build where the installation site rules out hydrocarbons.
FAQ
Q: Can I still import R134a bottle coolers into the EU in 2026?
New self-contained equipment containing fluorinated gases at GWP 150 or above has been barred from being placed on the EU market since 1 January 2025, and the 2026 step goes further for self-contained refrigeration. Stock already lawfully placed on the market before the cut-off is a separate question from new imports — check the exact placing-on-the-market date against the Annex IV wording in force.
Q: Does R290 need a special import licence?
No. Propane is not a fluorinated greenhouse gas, so it falls outside the quota and authorisation system. It does bring the flammability obligations: IEC 60335-2-89:2019 charge limits, ATEX considerations in the charging area, and A3 handling instructions in the manual.
Q: What is the maximum R290 charge in a commercial display cabinet?
500 g per refrigerating circuit under IEC 60335-2-89:2019, subject to the room-size and cabinet-construction conditions in that standard. Cabinets certified to the older edition are limited to 150 g, so always confirm which edition the test report cites.
Q: Who has to hold the quota authorisation — the factory or the importer?
The declarant importing pre-charged equipment into the EU. A Chinese manufacturer cannot hold EU quota on your behalf; what the factory supplies is the accurate charge data, the model-level refrigerant declaration and the label artwork the authorisation is built on.
Q: How long do I keep the compliance file?
Five years for the declaration of conformity and supporting documentation on pre-charged equipment, plus the separate retention periods under the Ecodesign and energy-labelling regulations. Store the charge record per serial number, not per model, so a customs query on one pallet does not require re-testing the range.