Regulation (EU) 2024/573, known as “F-Gas III,” entered into force on March 11, 2024 and radically transforms the rules governing R404A use in Europe (EUR-Lex, 2024). The short answer: no, virgin R404A is no longer allowed for servicing since January 1, 2025. But the full answer is far more nuanced.
Reclaimed R404A is still permitted. And existing systems can continue to operate. The distinctions between “placing on the market,” “use for servicing,” and “operation of existing equipment” are essential for staying compliant. This guide breaks down every scenario, with precise dates, applicable penalties, and available alternatives for refrigeration professionals in France.
Key Takeaways
- Virgin R404A (GWP 3,922, known as PRG in French regulations) has been banned for servicing and maintenance of all refrigeration equipment since January 1, 2025 (EU Regulation 2024/573, Art. 13(3)).
- Reclaimed or recovered R404A remains allowed for servicing existing installations until January 1, 2030.
- Existing systems containing R404A can continue to operate with no immediate replacement obligation.
- Penalties range from a EUR 1,500 fine to EUR 75,000 and 2 years’ imprisonment depending on the severity of the offense (French Environmental Code, or Code de l’environnement).
Is R404A still allowed in France in 2026?
Since January 1, 2025, the use of virgin fluorinated gases with a Global Warming Potential (GWP) of 2,500 or above has been banned for servicing and maintenance of all refrigeration equipment, except military equipment or systems cooling below -50 °C (Dalkia Froid Solutions, 2024). R404A, with a GWP of 3,922, clearly falls under this ban.
But “banned” doesn’t mean “gone.” Three situations coexist in 2026:
| Situation | Status in 2026 | Deadline |
|---|---|---|
| Virgin R404A for servicing | ❌ Banned | Since January 1, 2025 |
| Reclaimed R404A for servicing | ✅ Allowed | Until January 1, 2030 |
| Existing systems in operation | ✅ Allowed | No deadline (until decommissioning) |
| Virgin R404A for heat pumps / air conditioning | ❌ Banned (servicing) | Since January 1, 2026 |
| Placing on the market of gases with GWP ≥ 2,500 | ❌ Banned (new) | Since January 1, 2026 |
Virgin R404A has been banned for servicing all refrigeration equipment in Europe since January 1, 2025 (EU Regulation 2024/573, Article 13(3)). Only reclaimed or recovered R404A, properly labeled and certified compliant, remains usable for servicing existing installations until January 1, 2030 (EUR-Lex, 2024).
In practical terms, what does this change for a refrigeration technician in April 2026? You can no longer purchase a new cylinder of virgin R404A to recharge an installation. You must order reclaimed gas from a certified supplier, and that gas must carry specific labeling indicating it is reclaimed refrigerant. That’s the only legal option.
What exactly does F-Gas Regulation 2024/573 say about R404A?
Regulation (EU) 2024/573, published in the Official Journal on February 7, 2024, replaces the former Regulation 517/2014 and significantly accelerates the HFC phaseout timeline in Europe (EUR-Lex, 2024). It’s a European regulation, not a directive. It applies directly in France without transposition into national law. No room for interpretation.
What many professionals don’t realize: F-Gas III doesn’t target only R404A. It targets all gases with a GWP above 2,500, which also includes R507A (GWP 3,985). And the restrictions don’t stop there. Starting in 2032, the GWP threshold of 750 will apply, banning even R134a (GWP 1,430) and R407C (GWP 1,774) for servicing, except with reclaimed gas. R404A is just the beginning of a much broader wave of restrictions.
The three pillars of F-Gas III
- HFC quota phasedown: progressive reduction of HFC production and imports. Quotas drop to 60% of the baseline level (2024-2028), then 30% (2029-2033), 20% (2034-2035), and 15% from 2036 onward (European Environment Agency, 2025).
- Sector-specific bans: for each application (refrigeration, air conditioning, heat pumps), GWP thresholds progressively prohibit the most polluting gases.
- Control obligations: reinforced leak check frequencies, mandatory reporting, refrigerant traceability via equipment registers.
Regulation (EU) 2024/573, applicable since March 11, 2024, imposes an HFC quota phasedown to 60% of the baseline level between 2024 and 2028, then 30% from 2029 to 2033, with a target of 80% reduction by 2030 and complete elimination of virgin HFCs by 2050 (EEA, 2025; EUR-Lex, 2024).
What are the key R404A ban dates?
The ban timeline isn’t a single date. F-Gas Regulation III sets out at least six successive deadlines that directly affect R404A and other high-GWP HFC use (ABCClim, 2024). Missing even one of these dates exposes a business to administrative and criminal penalties.
Based on our analysis of the complete regulatory text, here is the summary timeline that every refrigeration professional should pin up in their workshop:
The F-Gas III timeline imposes six successive deadlines for R404A: virgin gas banned in refrigeration (2025), extension to heat pumps and air conditioning (2026), end of reclaimed gas in refrigeration (2030), GWP 750 threshold for servicing (2032), and complete elimination of virgin HFCs by 2050. Systems in operation are not subject to a replacement deadline (EUR-Lex, 2024).
Is reclaimed R404A still allowed? Conditions and limits
Reclaimed R404A, properly labeled, can be used without charge-size restrictions for servicing existing refrigeration equipment until January 1, 2030, under Article 13(3) of EU Regulation 2024/573 (Framacold, 2024). This is the exception that allows existing installations to keep running during the transition.
But be careful: “reclaimed” and “recovered” are not the same thing. The regulation clearly distinguishes between the two:
| Term | Definition | Requirements |
|---|---|---|
| Reclaimed | Processed in a licensed facility to restore virgin product specifications (AHR 700 standard) | Reclamation certificate, specific labeling, full traceability |
| Recovered | Extracted from a system without complete purification treatment | Can be reused in the same system or sent for reclamation |
| Recycled | Cleaned through basic filtration and dehydration without meeting AHR 700 standard | Usable for servicing under the same conditions as reclaimed gas until 2030 |
From experience, the main pitfall is labeling. A cylinder of reclaimed R404A must carry an explicit mention of its status. Without this label, it will be treated as virgin gas during an inspection, and your company will be in violation. We’ve seen HVAC contractors penalized for this exact reason. Always verify the reclamation certificate before accepting a delivery.
In terms of pricing, reclaimed R404A costs between EUR 446 and EUR 499 per 10 kg cylinder in France, with prices rising 15% to 30% per year since 2021 . For a detailed analysis of costs and availability, see our R404A pricing guide for 2026.
Reclaimed R404A, certified to AHR 700 standard and properly labeled, remains the only legal option for servicing existing refrigeration equipment in Europe between 2025 and 2030. The gas must come from a licensed facility and carry traceable labeling, or it risks being reclassified as banned virgin gas, with penalties of up to EUR 15,000 (EUR-Lex, 2024).
What are the penalties for F-Gas non-compliance in France?
Penalties for F-Gas non-compliance are not symbolic. Article L.541-46 of the French Environmental Code (Code de l’environnement) provides for up to EUR 75,000 in fines and 2 years’ imprisonment for failure to comply with hazardous waste traceability rules, a category that includes refrigerants (Helexia, 2025). And inspections have intensified since the rollout of TrackDéchets.
Here is the most common penalty schedule:
| Violation | Penalty | Legal basis |
|---|---|---|
| Leak check not performed | EUR 1,500 fine | French Environmental Code (Code de l’environnement) |
| Venting without recovery | EUR 1,500 fine | French Environmental Code (Code de l’environnement) |
| Non-compliance with inspection frequencies | Up to EUR 15,000 | DREAL (France’s regional environmental authority) administrative sanctions |
| Hazardous waste traceability violation | EUR 75,000 + 2 years’ imprisonment | Art. L.541-46 French Environmental Code |
| Operating without attestation de capacité (French F-gas certification) | Suspension / revocation of certification | French decree of February 29, 2016 (Arrêté du 29 février 2016) |
DREAL (France’s regional environmental authority, or Direction Régionale de l’Environnement, de l’Aménagement et du Logement) is the agency responsible for inspections in France. Since 2024, inspectors also verify compliance through TrackDéchets, the national hazardous waste traceability system. A refrigeration technician who uses virgin R404A for servicing will be flagged through the traceability chain, even without an on-site inspection.
In practical terms, the risk is real. Is it worth taking the risk to save a few euros on a gas cylinder?
In France, penalties for F-Gas non-compliance range from EUR 1,500 for a missed leak check to EUR 75,000 and 2 years’ imprisonment for hazardous waste traceability violations (Article L.541-46, French Environmental Code). DREAL has intensified inspections since the rollout of TrackDéchets, making virgin R404A use detectable across the supply chain (Helexia, 2025; CerfaGaz, 2026).
What alternatives to R404A are available in 2026?
The market offers three families of R404A alternatives, each with its own advantages and constraints. R449A (GWP 1,397) is the most popular retrofit in commercial refrigeration, compatible with existing POE oil and offering comparable cooling capacity (INTARCON, 2024). But it’s only a transitional solution: its GWP will also be targeted by the 750 threshold in 2032.
For long-term compliance, two options stand out:
| Alternative | GWP | Type | Key advantages | Limitations |
|---|---|---|---|---|
| R449A | 1,397 | HFC-HFO blend | Direct R404A retrofit, POE compatible | Banned in 2032 (GWP > 750) |
| R448A | 1,387 | HFC-HFO blend | Similar performance to R449A | Banned in 2032 (GWP > 750) |
| R454C | 148 | HFO blend (A2L) | Very low GWP, compliant 2032+ | A2L: specific equipment, training required |
| R290 (propane) | 3 | Natural (A3) | Near-zero GWP, high efficiency | Flammable, charge limits, strict standards |
| R744 (CO₂) | 1 | Natural | Lowest GWP, no F-Gas restrictions | High pressures, specialized equipment |
A point that few guides mention: choosing R449A in 2026 solves the immediate problem but creates a new one in 2032. When the GWP 750 threshold takes effect, you’ll have to go through the transition again. The most forward-thinking refrigeration technicians are investing directly in R290 or R744 for new installations, even if the initial investment is higher. Over 10 years, it’s the most cost-effective strategy.
In 2026, R404A alternatives fall into three categories: transitional HFC-HFO blends (R449A and R448A, GWP ~1,400, compliant until 2032), low-GWP HFOs such as R454C (GWP 148, A2L), and natural refrigerants (R290 at GWP 3, R744 at GWP 1) that are not subject to F-Gas restrictions. The choice depends on the target compliance horizon and acceptable investment level (INTARCON, 2024).
How should you plan the transition away from R404A?
HFC quotas drop to 30% of the baseline level between 2029 and 2033, the steepest reduction in the phasedown schedule. This is the stage when reclaimed gas prices will spike (EEA, 2025). Businesses that wait until 2029 to act will pay the highest price, both in refrigerant cost and conversion urgency.
Here is a realistic action plan for 2026-2028:
Step 1: Inventory (immediate)
Catalog all your equipment containing R404A. For each installation: initial charge, year of commissioning, general condition, historical leak rate. This is the foundation of any planning.
Step 2: Prioritization (Q2-Q3 2026)
Rank your installations by urgency:
- High priority: equipment over 12 years old, high leak rate, large charge
- Medium priority: equipment aged 7-12 years in good condition
- Low priority: recent equipment (< 7 years) with low charge and good leak history
Step 3: Strategy selection (Q3-Q4 2026)
For each installation, three options:
- R449A retrofit: fast, moderate cost, but a transitional solution (compliant only until 2032)
- Replacement with a natural refrigerant system: R290 or R744, higher investment but long-term compliant
- Continue with reclaimed R404A: acceptable for end-of-life equipment (< 4 years of remaining use)
Step 4: Execution (2027-2028)
Schedule conversions before quotas drop to 30% in 2029. Suppliers and installers will be overloaded as the deadline approaches. Planning ahead means saving money.
For equipment compatible with a retrofit, check our certified refrigerant catalog for available alternatives.
Frequently Asked Questions
Can I still buy R404A in France in 2026?
Yes, but only reclaimed or recovered R404A. Virgin (new) R404A has been banned for servicing since January 1, 2025 (EU Regulation 2024/573, Article 13(3)). The reclaimed gas must come from a certified supplier and carry specific labeling indicating its status. This authorization expires on January 1, 2030 for refrigeration.
Does my R404A installation need to be replaced immediately?
No. F-Gas Regulation III does not require the replacement of existing equipment in operation. Your system can continue to run as long as it is properly maintained and you use reclaimed gas for recharges. However, with R404A prices rising 15-30% per year since 2021, replacement is becoming increasingly cost-effective (Gasco France, 2024).
What is the difference between virgin, reclaimed, and recovered R404A?
Virgin R404A is produced from raw materials. Reclaimed R404A has been processed in a licensed facility to restore virgin product specifications (AHR 700 standard). Recovered R404A is simply extracted from a system without complete treatment. In 2026, only reclaimed and recycled gas are allowed for servicing existing refrigeration equipment.
Do leak check requirements change under F-Gas III?
Leak check frequencies remain unchanged in principle (5, 12, or 24 tonnes CO₂ equivalent), but enforcement is stricter. DREAL (France’s regional environmental authority) inspectors now verify compliance through TrackDéchets and digital registers. A missed inspection carries a EUR 1,500 fine, and repeated non-compliance can lead to suspension of the attestation de capacité (French F-gas certification) (CerfaGaz, 2026).
Is R449A a good alternative to R404A in 2026?
R449A (GWP 1,397) is the most common retrofit because it’s compatible with POE oil and offers performance close to R404A. However, its GWP exceeds the 750 threshold that will apply in 2032 for servicing. For long-term compliance, natural refrigerants (R290, R744) or very low GWP HFOs (R454C, GWP 148) are preferable.
Conclusion: Act now, not in 2029
R404A is not fully banned in 2026. But the legal framework is tightening fast. Virgin gas is already off the table. Reclaimed gas remains available, but only for four more years in refrigeration. And prices keep climbing every year.
The question is no longer “is R404A allowed?” but “for how much longer?” For end-of-life installations, servicing with reclaimed gas makes sense. For everything else, transitioning to compliant alternatives is the most cost-effective choice over the medium term.
Check our R449A solutions and reclaimed R404A for your immediate needs, or contact our team for personalized advice on your transition plan.
