The first step to determining if your chiller is compliant is to check the nameplate or technical documentation to see which refrigerant it uses. If unclear, a qualified technician can verify. Within these slides are some of the most common refrigerant categories, their phaseout considerations under current EU F-Gas rules, and examples of each.

Examples: R11, R12, R22

Regulatory Status: CFCs or HCFCs have already been phased out in the EU for new equipment. These substances are ozone-depleting and have been banned from use in new systems for many years. Servicing existing equipment with these refrigerants is highly restricted or prohibited.

HFCs are under a gradual phasedown (not a complete phaseout) in the EU because of their relatively high global warming potential.

Examples: R410A (GWP ~2088). R134a (GWP ~1430), R407C (GWP ~1774)

Key EU Restrictions for Stationary Chillers:

• HFCs with a GWP of 2500 or higher (in certain blends) have been banned in new chillers from 1^st January 2020, unless the application requires cooling below -50°C.
• Chillers up to and including 12kW capacity that contain F-gases with a GWP of 150 or more will be banned from sale or installation after 1 January 2027 (unless site-specific safety requirements prohibit lower-GWP refrigerants.)
• Chillers above 12kW capacity that contain F-gases with a GWP or 750 or more will also be banned from sale or installation after 1^st January 2027 (again, unless a site needs a higher GWP refrigerant for safety reasons).
• Additional restrictions come into effect on 1^st January 2032 for certain F-gases in chillers up to 12kW, with possible exemptions for safety considerations.

Since R407C has a GWP of approximately 1774, it exceeds the 750 threshold for large chillers and 150 threshold for small ones, meaning that new chillers using R407C will be subject to bans starting on 1^st January 2027.

HFO-based or HFO/HFC blends have lower global warming potentials and typically face fewer restrictions under current F-Gas regulations, but it is always important to check their exact GWP values.

For instance, R454C, which has a GWP of approximately 148, remains under the 150 threshold for smaller chillers and the 750 threshold for larger chillers, so is not subject to the 1^st January 2027 bans on new chillers (unless other site-specific rules apply).

By contrast, R407C, often discussed alongside HFO/HFC blends, carries a higher GWP of 1774 and is therefore restricted under the HFC regulations outlined in the previous section.

Natural refrigerants generally have very low GWP and no ozone-depleting potential, but some come with other safety considerations such as flammability or toxicity.

For example, R290 has a GWP close to zero and zero ozone-depleting potential but is flammable and must be handled accordingly. R717 and R744 are also used extensively in industrial applications, have negligible GWP, and do not fall under the F-Gas bans, though ammonia is classified as toxic/corrosive and CO2 operates at higher pressures.

Since R290’s GWP is under 1, it is well below any F-Gas threshold that would restrict its usage in chillers, which means that it faces no GWP-related bans under current EU regulations.

• From 1^st January 2020, the EU banned the use of HFCs with a GWP of 2500 or higher in new chillers (unless the application requires temperatures below -50°C)
• From 1^st January 2027, the EU will ban new chillers up to 12kW that use F-Gases with a GWP of 150 or more, as well as new chillers above 12kW that use F-Gases with a GWP of 750 or more (unless a safety exemption applies).
• From 1^st January 2032, additional restrictions will apply to certain F-Gases in chillers up to 12kW, again with potential exemptions for safety requirements.

These deadlines primarily cover the placing on the market of new chillers in the EU and do not constitute a blanket ban on the continued use or servicing of existing equipment – although servicing restrictions may apply to refrigerants with very high GWPs.

The first step on ensuring that your chiller remains compliant is to verify which refrigerant it uses. You should check the nameplate or technical documentation of your process chiller. If you are uncertain, a qualified technician can help you to determine the refrigerant type.

Under the federal American Innovation and Manufacturing (AIM) Act, high-GWP HFCs such as R410a, R314a, and R407c are subject to production and consumption caps that began in 2022. The AIM Act establishes annual reductions of approximately 10% each year, continuing until 2036, which will result in an overall reduction of about 85% relative to baseline levels. Refrigerants with lower GWPs, such as the HFO/HFC blend R454c, are less affected by these reductions. Natural refrigerants such as R290 face no phase-down measures under the AIM Act because of their very low GWP.

In addition to these federal rules, several states have introduced or are in the process of implementing more stringent measures to further reduce the use of high-GWP refrigerants. For example, California has enacted state-specific regulations that impose stricter limits on the use of HFCs in new equipment and may require certain high—GWP refrigerants be phased out entirely by a target year that could be as early as 2030. New York has also proposed policies aimed at accelerating the phase-down of HFCs in commercial refrigeration systems, while Massachusetts has set its own equipment standards to promote the adoption of low-GWP alternatives. States like Washington have taken additional steps by reviewing and potentially tightening their refrigerant usage guidelines to align with both federal objectives and local environmental goals.

Each state’s policies can vary in terms of target dates, specific GWP thresholds, and the scope of affected applications. For the most current, state-specific details – including deadlines, restrictions on new equipment, and applicable exemptions – professionals are encouraged to review the NASRC HFC Policy Tracker.  This resource provides up-to-date information on the additional measures that have been adopted by different states.

By matching your chiller’s refrigerant type against both the federal AIM Act phase-down schedule and any applicable state-specific requirements, you can determine whether your system is compliant or if any adjustments may be necessary. Staying informed on both federal and state levels ensures that your facility can proactively manage refrigerant use, avoid regulatory penalties, and contribute to the nation’s broader efforts to reduce greenhouse gas emissions.