Can you still top up with R-410A or other high-GWP refrigerants after the ban?

Short answer

It depends on which refrigerant you mean. For R-410A the answer is simple: yes, topping up with virgin (new, unused) R-410A is fine. R-410A has a GWP of 2,088, which is below the threshold of 2,500 that the law sets for the maintenance ban. For refrigerants with a higher GWP — think of R-404A and R-507A — the situation is different: topping up existing installations with virgin material of those types has been banned since 1 January 2020, with an exception for recycled and reclaimed refrigerant.

This article is about that distinction, and about the difference with the better-known ban on placing on the market new equipment (see F-gas product ban timeline for that other topic).

The misunderstanding: R-410A is not covered by this ban

On the shop floor, "R-410A is no longer allowed" often gets mixed up with two very different rules:

• The ban on placing new equipment with certain refrigerants on the market (for example the ban on HFCs in new air conditioners above a certain GWP threshold, with its own set of dates) — that's a different topic, worked out in F-gas product ban timeline.
• The ban on servicing/topping up existing installations with virgin refrigerant above GWP 2,500 — that's the topic of this article, set out in Article 13 of the F-gas Regulation.

R-410A (GWP 2,088) is below the GWP 2,500 limit of that maintenance ban. So as far as this specific ban is concerned, your technician can simply keep topping up an existing R-410A installation with new, unused R-410A. That R-410A will eventually become more expensive and scarcer due to the quota phase-down (see F-gas quota 2027: prepare your business) and irrelevant for new installations, is a different story — but it is not a statutory top-up ban on existing equipment.

Which refrigerants are covered by the top-up ban?

The maintenance ban under Article 13 affects refrigerants with a GWP of 2,500 or higher. In practice these are mainly the older, high-GWP HFC blends you still come across in older refrigerated transport and older refrigeration/freezer installations, such as:

• R-404A
• R-507A
• Comparable high-GWP blends

If in doubt, check the GWP value of the specific refrigerant in your installation — see GWP values of refrigerants: complete table + explanation. Important: since the revision of the F-gas Regulation, this ban no longer applies only to large installations. Since 1 January 2025 it applies to refrigeration installations of any size, and since 2026 also to air conditioning and heat pumps — see the next section for the details.

The rules at a glance (Article 13 F-gas Regulation)

The rules around this maintenance ban have been tightened in recent years. There are two layers to keep apart:

• The original rule (Regulation (EU) 517/2014, since 1 January 2020): virgin refrigerant with GWP 2,500 or more could no longer be used for service/maintenance, but this only applied to refrigeration equipment with a charge of 40 tonnes CO₂ equivalent or more. For R-404A or R-507A, that threshold at the time roughly worked out to a charge from around 10 kg.
• The current rule (Regulation (EU) 2024/573, which replaced 517/2014): this 40-tonne CO₂-eq threshold has been dropped. From 1 January 2025, the ban on virgin refrigerant with GWP 2,500 or more applies to refrigeration installations of any size — so there's no longer a minimum charge your installation has to reach before the ban applies. From 2026, the same ban (GWP 2,500 or more, virgin) also applies to air conditioning and heat pumps, likewise without a lower limit on charge.

Note: sources differ on points of detail regarding the exact end date of the recycled/reclaimed exception per equipment category (see below), and for stationary refrigeration (excluding chillers) a further tightening is planned from 2032 to a GWP threshold of 750. For a specific, large or recent installation, always verify the current state via IPLO (opent in nieuw tabblad) or the consolidated legal text on EUR-Lex, or check with your certification body.

The exception: recycled and reclaimed refrigerant

The maintenance ban does not apply without limit to refrigerant that is already in circulation. There is a transitional arrangement for:

• Reclaimed refrigerant with GWP 2,500 or more, used for the maintenance of existing refrigeration equipment — provided it is labelled in accordance with the labelling requirements of the regulation (origin and batch data of the reclamation facility).
• Recycled refrigerant with GWP 2,500 or more, used for the maintenance of existing refrigeration equipment — provided it has been recovered from that same (or related) equipment, so it is not freely tradeable to third parties.

This exception doesn't run to the same date for all equipment: for refrigeration installations it ends around 1 January 2030, for air conditioning and heat pumps around 2032. Sources differ slightly on the exact end date, so check this for your specific situation via IPLO or EUR-Lex. After that, this route also lapses and you'll have to switch to an alternative refrigerant or convert the installation for service work. For the practical side of recovery and the record-keeping around it, see Refrigerant recovery: the rules, the certificate and the balance and Refrigerant balance: a practical guide.

What does this mean in practice for your work order and logbook?

When servicing an installation with a high-GWP refrigerant (GWP ≥2,500), you must be able to show what you topped up and where it came from — regardless of the size of the installation:

• Record in the F-gas logbook whether virgin, recycled or reclaimed refrigerant was used — see F-gas logbook: what needs to be in it?.
• For recycled/reclaimed refrigerant, keep the label or the certificate of origin.
• Keep track of what type of equipment it is (refrigeration versus air conditioning/heat pump) and since when it has been in operation, because the start date of the ban and the length of the exception depend on that.
• This ties in with your regular leak-check obligations, see F-gas leak checks: how often are they mandatory?.

If in doubt about the GWP threshold of a specific refrigerant or blend: check the table in GWP values of refrigerants before making a choice.

What if you top up with banned virgin refrigerant anyway?

Topping up with virgin refrigerant above GWP 2,500 after the ban's start date is a violation of the F-gas Regulation, and that is enforceable by the ILT. For the risks and rates, see ILT fines for F-gases: risks without a valid certificate and F-gas fines: what are the amounts? (ILT rates at a glance).

Alternatives if your installation runs into the limit

If a customer runs into this ban (an R-404A or R-507A installation, no more recycled refrigerant in stock), converting or replacing with a lower-GWP alternative is usually the only structural solution. See R-32 vs R-410A vs R-454B: differences and which do you choose? and Natural refrigerants: R-290, R-744 and ammonia compared for a comparison of the options.