Cosmotec's response to the new F-Gas EU Regulation 2024/573

The first deadlines of EU Regulation 2024/573, aimed at limiting the use of fluorinated refrigerants (F-Gases) with high Global Warming Potential (GWP), are approaching for industrial cooling products. In the article published in May 2025, We have outlined the contents of the Regulation and the possible scenarios for Cosmotec products. In this article, we revisit the key points and present our solutions.

Restrictions on placing on the market and export

“Placing on the market” means the first supply within the EU of refrigerants or products containing them. “Export” means their removal from the customs territory of the EU. It is important to emphasize that the restrictions discussed here apply to the first supply—that is, the sale or transfer from the equipment manufacturer to its customer—and not to subsequent commercial transactions that do not involve the manufacturer.

For industrial cooling products, the next limits for placing on the EU market are listed below:

From 1 January 2027, the export of the products listed above outside the EU will only be permitted if they contain fluorinated greenhouse gases with a GWP below 1000.

Derogations

Pursuant to Article 11, paragraph 5, of Regulation (EU) 2024/573, the European Commission may authorise temporary derogations for specific product categories where alternative solutions are unavailable, are not technically or economically feasible, or would lead to disproportionate costs. However, it is unlikely that the current applications for derogation for industrial refrigeration products will be approved by 2026.

Annex IV of the Regulation also provides for an exemption for specific safety reasons related to the site or the equipment — such as an electrical panel, a cabinet, or a machine tool — where the cooling device is installed. Unlike the general derogation, the specific exemption does not require the approval of the European Commission. Exempt air conditioners and chillers will be permitted to use refrigerants with a GWP below 750.

Low GWP refrigerants: characteristics and safety

All traditional refrigerants used in industrial cooling products – R134a, R407C, R410A – exceed the limits set by the Regulation. Below is an overview of technically viable alternative refrigerants.

R290 (propane) and R744 (carbon dioxide) are non-fluorinated (natural) refrigerants, which meet the most stringent requirements of the Regulation and will remain the only ones permitted – indefinitely – even in devices with a cooling capacity of less than 12 kW.

As R290 is highly flammable, UNI EN 378:2021—the standard that defines safety and environmental requirements for refrigeration systems and heat pumps—significantly limits the maximum refrigerant charge per refrigeration circuit. In the event of a leak, released propane can also accumulate above its flammability threshold in certain areas of the unit or of the equipment in which it is integrated, creating potentially explosive atmospheres where ignition sources must not be present. The issue extends beyond the intrinsic safety of air conditioners and chillers: the electrical enclosures and machine tools that house them also require a thorough risk assessment and, in many cases, substantial redesign.

R744 (carbon dioxide) is among the most established refrigerants for low-temperature industrial refrigeration. However, in high-temperature applications, such as electrical cabinets, it exhibits reduced efficiency and high consumption, which, over the product's lifecycle, risk negating the climatic benefits of its low GWP. The very high operating pressures also necessitate the use of particularly expensive components.

The refrigerants R1234yf, R1234ze, and R454C are permitted in the first phase of the F-Gas Regulation but will no longer be allowed from 2032, when the Regulation will mandate the exclusive use of natural refrigerants for monobloc air conditioners and chillers with a capacity of less than 12 kW. They are also slightly flammable and, although to a lesser extent than propane, still require a risk assessment and appropriate precautions for electrical panels and machine tools. In the absence of codified and uniform rules and parameters for conducting such an assessment, the outcomes could be inconsistent and uncertain.

The third group – which includes R454B, R513A and R32 – has a GWP ranging between 150 and 750. The F-Gas Regulation only permits their placing on the EU market in refrigerating appliances with a cooling capacity exceeding 12 kW. As previously indicated, devices below 12 kW can only use them under derogation or exemption for safety reasons. They are also permitted for all products intended for export. Of this group, only R513A is non-flammable.

Cosmotec solutions

Following a thorough technical and safety assessment, we believe that the application-specific exemption provided for in Annex IV of the Regulation is currently the only viable option for all electrical enclosure and cabinet air conditioners as well as for WRA chillers installed on-board machinery. This approach is based on two assumptions that are explicitly recognized by the Regulation:

• the existence of non-derogable safety requirements that make the use of flammable refrigerants critical in these applications;
• the current absence of technically mature and proportionate alternatives capable of guaranteeing equivalent levels of safety, performance, and environmental impact.

Added to this is a further objective element: the still limited availability on the market of certified components, accessories and solutions for electrical panels and machine-integrated applications that are compatible with A2L and A3 refrigerants. In this context, a safe, reliable, and industrially sustainable transition to flammable refrigerants is currently not practicable.

For these reasons, and in order to ensure continuity of supply, operational safety and regulatory transparency, industrial air conditioners for electrical cabinets and integrated chillers will adopt the non-flammable refrigerant R513A. To guarantee maximum transparency and to support the correct installation and use of the equipment, all units supplied with R513A will be clearly labelled, with explicit reference to the applicable regulatory framework and the technical and safety standards considered.

For WLA Compact chillers, although they are installed on-board machinery, our safety analyses have identified only limited concerns regarding the use of mildly flammable refrigerants. We have therefore chosen to develop the new product using R1234yf.
The following is an overview of the products already developed or currently under development for release in the coming months.

Electrical cabinet air conditioners

Chillers

For applications with fewer safety-related constraints, we are developing WRA chillers below 12 kW using R1234yf. Conversely, for the most critical WLA Compact chiller applications, models covered by the exemption and using R513A refrigerant will be available on request.

Should conditions change significantly — for example, due to the widespread availability of certified components and architectures that make the use of flammable, low-GWP refrigerants safe and cost-effective — we will review our product strategy accordingly.

Cosmotec is constantly committed to collaborating with our clients, industrial partners, and competent authorities in pursuing the environmental objectives of the F-Gas Regulation, while ensuring that these objectives are achieved without compromising industrial safety, solution reliability, and legal certainty along the entire value chain.