A specialist reference on the rules that decide which refrigerant may legally go into a cold room — the EU F-Gas Regulation, the global Kigali Amendment, the EN 378 safety code, and the flammable-refrigerant charge limits — written for refrigeration engineers, contractors, facility managers, and compliance officers.

Quick answer: In the EU, refrigerant choice is governed by Regulation (EU) 2024/573 (the revised F-Gas Regulation, in force since 11 March 2024). The two rules that most affect cold rooms are already live: self-contained (plug-in) commercial refrigeration with refrigerant GWP ≥ 150 is banned from 1 January 2025 (pushing plug-in units to R-290 propane), and servicing with GWP ≥ 2500 gas (e.g. virgin R-404A) is banned from the same date. A GWP-750 service limit for stationary systems follows in 2032, and a broad GWP-150 cap on most new equipment in 2030. Safety is governed separately by EN 378 / ISO 5149, with flammable-charge limits from EN IEC 60335-2-89:2022 (up to 500 g R-290 in a self-contained appliance, 150 g in a split). For new builds, specify a natural refrigerant (CO₂, R-290, low-charge ammonia) or an ultra-low-GWP HFO — not a high-GWP HFC blend.

Why refrigerant law matters before you specify

A cold room can be perfectly engineered — tight CAM-LOCK joints, correctly sized heat load, the right evaporator — and still be illegal to place on the market because of the gas inside it. Since the 2010s, refrigerant regulation has shifted from a background concern to the first design constraint: it determines which condensing units a manufacturer may sell, which gases a technician may use to service an existing plant, and how long a high-GWP installation can realistically be kept running.

This article covers the regulatory and safety framework only. For the engineering trade-offs between system architectures, see Refrigeration system selection; for the underlying chemistry and naturals/HFO landscape, see Emerging refrigerant technologies and Secondary refrigerant systems.

Two independent gates: climate and safety

Compliance is governed by two separate regimes that a design must satisfy simultaneously:

A refrigerant can clear one gate and fail the other. CO₂ (R-744) sails through the climate gate (GWP 1) but triggers high-pressure design rules; propane (R-290) clears the climate gate easily (GWP ≈ 3) but is hard-limited by flammable-charge rules. You must check both.

The climate gate: GWP and the phase-down

What GWP measures

Global Warming Potential (GWP) expresses the warming effect of 1 kg of a gas relative to 1 kg of CO₂ over 100 years, so CO₂ = 1 by definition. It is the single number around which the entire phase-down is structured. The regulatory thresholds that matter for cold rooms are GWP 150, GWP 750, and GWP 2500.

Correction to older guidance. Material written before 2024 — including the source this article is based on — recommends R-448A and R-449A as the straightforward "future-proof" choice for new small systems. That is no longer accurate. With GWPs of ≈ 1273 and 1282 (AR5 values, as used by Regulation (EU) 2024/573), both blends sit far above the GWP-150 cap and above the 750 service threshold arriving in 2032. They are now retrofit / "bridge" blends for keeping existing R-404A plant alive — not the basis for a new, long-life installation. For new builds, durable choices are natural refrigerants (CO₂, R-290, low-charge ammonia) or ultra-low-GWP HFO options.

Note on hydrocarbons. Hydrocarbon GWP is low (~3), not zero — older marketing claiming "zero GWP" for propane and isobutane is incorrect. Ammonia is genuinely GWP 0, but is toxic and mildly flammable (safety class B2L), so "zero GWP" must never be read as "hazard-free."

Regulation (EU) 2024/573 — the binding instrument

The revised F-Gas Regulation (EU) 2024/573 entered into force on 11 March 2024, replacing Regulation (EU) No 517/2014. It accelerates the HFC supply phase-down, tightens the sector bans, and sets a trajectory to effectively end most HFC use by 2050. The headline supply phase-down cuts the HFC quota in steep steps against the 2009–2012 baseline, with availability of high-GWP gas falling — and prices rising — every year.

For cold-room specification, four provisions matter:

The practical consequences:

• Self-contained units must now use R-290. The 2025 GWP-150 cap leaves essentially no compliant HFC option for plug-in equipment, which is why monoblock and integral cabinets have standardised on propane.
• R-404A is a dead end. At GWP ≈ 3922 it cannot legally receive virgin gas since 2025; a leaking R-404A system must be topped up with reclaimed gas (until 2030) or converted/replaced. Treat any R-404A plant as a near-term replacement candidate.
• The 2030 and 2032 dates reach split and built-up DX systems too. Splits are not exempt from the phase-down; they simply face the broader caps a few years later. A new split DX cold room specified today for a 15-year life should already be on an ultra-low-GWP or natural refrigerant.

Kigali — the global backdrop

The EU rules implement the Kigali Amendment to the Montreal Protocol (adopted 2016, in force 1 January 2019), a legally binding international treaty under which ratifying countries phase down HFC production and consumption. Kigali is why the phase-down is global rather than European-only: developed economies began cutting from 2019, with most developing economies following on later baselines. It also explains the regional patchwork below — every major market is implementing the same treaty obligation on its own schedule.

Regional snapshot

Because the EU regulation applies directly in every member state, a cold room placed on the market in Poland is bound by 2024/573 exactly as in Germany or France. The national layer adds certification and record-keeping obligations (certified personnel, leak-check intervals, equipment logbooks) rather than different gas rules.

The safety gate: EN 378 and charge limits

GWP compliance does not make a system safe. A second, independent regime governs flammability, toxicity, and pressure — and it frequently constrains the choice more tightly than GWP does, because the low-GWP naturals are precisely the ones with hazard flags.

Safety classification (ASHRAE 34 / ISO 817)

Refrigerants carry a two-part safety class: a toxicity letter (A = lower toxicity, B = higher) and a flammability number (1 = none, 2L = mildly flammable/low burning velocity, 2 = flammable, 3 = higher flammability).

CO₂ is A1 (non-flammable, low toxicity) but is the high-pressure outlier. Ammonia's B2L class is the reason it is generally kept out of occupied space and confined to plant rooms.

EN 378 / ISO 5149 — the system safety code

EN 378 (the EU standard, technically aligned with international ISO 5149) is the master safety standard for refrigerating systems and heat pumps. It governs how much refrigerant may be present for a given room size and occupancy, when a dedicated machinery room with ventilation and leak detection is required, pressure-equipment requirements, marking, and emergency provisions. EN 378 is structured around the refrigerant's safety class and the access category of the occupied space (general access vs. supervised vs. authorised-only).

Two design levers come straight from EN 378:

• Maximum charge for a given room volume. For flammable (A2L/A3) and toxic (B-class) refrigerants, EN 378 sets the allowable charge as a function of the smallest occupied room the refrigerant could leak into — smaller rooms allow less charge.
• Machinery-room trigger. Above defined charge thresholds (most relevant for ammonia), the system must sit in a purpose-built machinery room with mechanical ventilation, gas detection, and emergency controls — the requirement that keeps large ammonia plant out of public areas.

Flammable-charge limits: EN IEC 60335-2-89:2022

For self-contained and split commercial refrigerating appliances (those with a built-in compressor — plug-ins, integral cabinets, monoblocks for cold rooms), the governing product-safety standard is EN IEC 60335-2-89:2022, harmonised under EU law on 2 August 2023. Its 2022 revision raised the permitted flammable charge and is the reason hydrocarbon refrigeration has expanded from tiny bottle coolers into real commercial duty.

Correction to older guidance. Source material citing a 150 g propane limit is out of date. Since the 2022 standard, a self-contained appliance (such as a monoblock condensing unit for a cold room) may carry up to 500 g of R-290. The 150 g figure now survives only for split systems. This single change is what made R-290 a credible compliant answer to the 2025 GWP-150 self-contained ban.

The 500 g allowance is not unconditional: it comes with airflow, enclosure, and marking requirements, mandatory release-mitigation features on larger charges, and installation rules (e.g. ventilation around the unit). It enables a monoblock cold-room unit on propane, but the installer must still meet the standard's siting and ventilation conditions.

Frostbox standard range. Frostbox supplies plug-in and split refrigeration units from real Daikin families — including the GS and SP-O quick-connect ranges and the DB-O / RDV / SAS-SAR standard families, plus dedicated GM-R290 propane units — selected and matched automatically by the Frostbox configurator. Refrigerant per family is version- and market-dependent (for example R-134a for some medium-temperature units, R-452A for low-temperature, with legacy R-404A on older stock) — always confirm against the specific unit datasheet rather than assuming a blanket value. See Refrigeration units for the catalogue detail.

Compliance obligations across the lifecycle

Regulation does not end at gas selection. Operators carry ongoing duties under the F-Gas Regulation and EN 378:

Two points worth stressing for cold-room operators:

• Leak-check frequency is charge-driven, expressed in tonnes of CO₂-equivalent (= charge in kg × GWP ÷ 1000). A high-GWP system crosses inspection thresholds at a much smaller physical charge than a low-GWP one — another quiet penalty for sticking with HFCs.
• Recovery at end of life is mandatory. When a cold room is decommissioned or relocated (a routine event with CAM-LOCK construction), the refrigerant must be recovered by a certified technician, not released.

Practical compliance checklist for a new cold room

1. Identify the equipment type — self-contained/monoblock vs. split vs. built-up DX vs. central plant. This sets which GWP cap and date applies.
2. Pick a refrigerant that clears the climate gate for that type and for the asset's full service life — for self-contained, that means R-290; for splits and built-up systems, an ultra-low-GWP HFO or a natural. Avoid R-404A/R-507A entirely and treat R-448A/R-449A as retrofit-only.
3. Clear the safety gate — check the refrigerant's safety class against EN 378 charge limits for the room volume, and against EN IEC 60335-2-89 if it is a packaged appliance. Confirm ammonia plant has a compliant machinery room.
4. Confirm certified personnel and records — installer/servicer F-Gas certification, commissioning leak check, logbook set up.
5. Plan for serviceability — a refrigerant still legally serviceable in 10–15 years protects the asset from a stranded-gas retrofit. This is where CAM-LOCK modularity helps: pipe penetrations and evaporators can be reworked without demolition if a future refrigerant transition is needed.

Need help matching a compliant, correctly sized unit to your room? Use the Frostbox size calculator or request a quote and the configurator will pair your enclosure with an appropriate Daikin unit.

Related articles

• Refrigeration system selection (DX vs secondary vs natural)
• Refrigeration units
• Emerging refrigerant technologies
• Secondary refrigerant systems
• Energy efficiency
• Technical glossary

Sources & further reading

• Regulation (EU) 2024/573 on fluorinated greenhouse gases (consolidated text) — EUR-Lex — eur-lex.europa.eu/eli/reg/2024/573
• "F-gas legislation" and sector bans / phase-down schedule — European Commission, Climate Action — climate.ec.europa.eu
• Commission Implementing Regulation (EU) 2025/33 (self-contained equipment placing-on-market derogation) — EUR-Lex
• Kigali Amendment to the Montreal Protocol — UNEP Ozone Secretariat — ozone.unep.org/treaties/montreal-protocol/amendments/kigali-amendment-2016
• EN 378-1…4 Refrigerating systems and heat pumps — Safety and environmental requirements (aligned with ISO 5149)
• EN IEC 60335-2-89:2022 Household and similar electrical appliances — Safety — Part 2-89: commercial refrigerating appliances with an incorporated or remote refrigerant unit or compressor (500 g A3 / 1.2 kg A2L charge limits; harmonised OJEU 2 Aug 2023, Commission Implementing Decision (EU) 2023/1586)
• ANSI/ASHRAE Standard 34 Designation and Safety Classification of Refrigerants; ASHRAE Standard 15 Safety Standard for Refrigeration Systems; ANSI/IIAR standards for ammonia systems
• US framework: AIM Act and EPA Technology Transitions rule; California CARB HFC regulations — US EPA — epa.gov/climate-hfcs-reduction
• Poland national F-Gas implementation, operator register (CRO) and certification — Urząd Dozoru Technicznego (UDT) — udt.gov.pl

Regulatory dates and GWP figures reflect EU law as at the 2024/573 revision; always confirm current thresholds and the specific Daikin unit datasheet before specifying. Questions on compliant refrigeration for a Frostbox cold room — contact [email protected].