Finance & Strategy

Cold Room Refrigerant: 3 Thresholds and 1 Ban

Your cold room gets topped up every summer. Since 1 January 2025 that is no longer allowed on a great many units.

In this article
  1. Why a kilo is not a kilo
  2. The three thresholds, and what each one puts on you
  3. The nine refrigerants you meet in a kitchen
  4. What is actually in your cold room?
  5. Five terms that appear on your service invoice
  6. What you do about it this week, this month and this year

An F-gas is a fluorinated greenhouse gas: the refrigerant circulating in almost every cold room, freezer, chilled counter and ice machine in a professional kitchen. European law does not measure that gas in kilograms but in tonnes of CO2 equivalent — the kilos in your unit multiplied by the warming factor of the gas inside it, divided by a thousand. That single sum decides everything you owe on it.

Every venue knows the ritual. Halfway through summer the cold room stops holding temperature, the engineers come out, something gets "topped up", and the invoice carries a line with a code in it — R-404A, R-134a, R-449A — and a number of kilos. Nobody reads that line. The unit works again, and that was what mattered.

Since 1 January 2025 that line is the most interesting thing on the whole invoice. From that date, refrigerant with a warming factor of 2,500 or more may no longer be used to service or repair refrigeration equipment — and R-404A, the gas sitting inside a very large share of existing hospitality refrigeration, is rated 3,922. What your engineer did last summer he may now only do with reclaimed gas, and that exception expires on 1 January 2030.

This guide walks the three thresholds your unit can cross, with the numbers attached. At the bottom you put in your own two figures — which gas, and how many kilos — and see which threshold applies to you, what it costs in inspections, and how many years this unit has left. Everything runs in your own browser: nothing is sent anywhere and nothing is stored.

Why a kilo is not a kilo

The nameplate on your cold room carries a number of kilos. That number appears nowhere in the legislation. What does appear is a threshold in tonnes of CO2 equivalent, and you get there like this: kilos times the warming factor of the gas, divided by a thousand. Four kilos sounds like nothing. Four kilos of R-404A is 15.7 tonnes of CO2 equivalent — over three times the threshold above which you need an annual leak check and a logbook.

The warming factor (GWP, global warming potential) is not an estimate you are free to make: every gas has one, and it is printed in the annexes of the regulation itself. R-404A is 3,922, R-410A 2,088, R-134a 1,430, R-449A 1,397, R-448A 1,387 and R-513A 631. For blends the factor is derived from the composition. Watch which source you use: the climate panels publish new figures every few years, but the number that counts for your obligations is the one in the regulation.

And then there is the distinction that surprises most operators: propane (R-290) and CO2 (R-744) are not F-gases. They do not have a low threshold — they have none. A unit running on propane falls entirely outside this regulation: no leak check, no logbook, no end date, no quota squeezing the price. That is not a footnote; it is the whole difference between two machines that look identical in your kitchen.

The three thresholds, and what each one puts on you

They are in the order a venue meets them. The first two are about how much gas is in your unit. The third is about which gas it is — and it is the only one with an expiry date.

1. 5 tonnes CO2 equivalent: where the paperwork starts

This is the threshold most hospitality units cross without anyone noticing. Above five tonnes of CO2 equivalent, a refrigeration system must be checked for leaks at least once every twelve months by a certified technician, and you must keep a record for that unit: which gas, how much, who worked on it, how much was added or recovered, and on what date. Those records have to be kept for five years.

Five tonnes is not a big machine. Below is how many kilos of each gas it takes to reach that threshold — and straight away, why the same four kilos is a completely different machine depending on what is inside it.

There is one concession attached: if the installation carries an automatic leak-detection system, the check may go to every twenty-four months instead of every twelve. For a single cold room that is rarely worth it; for a venue with several circuits in one plant room, sometimes it is.

How many kilos before the paperwork starts

The charge it takes to reach the 5-tonne CO2-equivalent threshold — the threshold above which an annual leak check and a logbook become mandatory.

R-404A 1.27 kg
R-134a 3.50 kg
R-449A 3.58 kg
R-513A 7.92 kg
R-290 not an F-gas — no threshold
R-744 not an F-gas — no threshold

Under one and a half kilos of R-404A already puts a unit over the line; with R-513A you need almost eight. On propane and CO2 the threshold does not exist however much is in there — those gases fall outside the regulation.

2. 50 and 500 tonnes: where the frequency changes

Above fifty tonnes of CO2 equivalent the rhythm doubles: every six months, or every twelve with leak detection. Above five hundred tonnes it becomes every three months and an automatic leak-detection system stops being optional and becomes mandatory.

For one cold room behind a bistro, fifty tonnes is out of reach — that would take thirteen kilos of R-404A. But a venue rarely has one unit. A cold room, a freezer room, a chilled counter, an ice machine and an air-conditioning system are five separate circuits, and the threshold applies per installation, not per building. Add that up wrongly and you get it wrong in both directions.

Practically: have your engineer copy out the nameplate of each unit once — gas, kilos, year of manufacture — and keep that list with the rest of your technical documents. It is fifteen minutes of work, and it is exactly the list an inspector asks for. Anyone who already has their opening and closing round written down knows the principle: what lives in one head is not documented.

3. GWP 2,500: where topping up became illegal

This is the threshold that has nothing to do with the size of your unit and that actually catches most venues. Since 1 January 2025, refrigerant with a warming factor of 2,500 or more may no longer be used for the maintenance or repair of refrigeration equipment. Not "above a certain charge" — the old exemption for small units is gone. It applies to the gas, not to the machine.

There is one way out, and it has a clock on it: reclaimed or recycled gas may still be used until 1 January 2030. That is real gas recovered from decommissioned installations and cleaned up, not newly produced gas — so the supply is finite by definition, and the price follows that scarcity. If you have a unit on R-404A today you do not have a problem, but you do have a deadline.

Below is where each gas sits against the lines the regulation itself draws. Note how far above the red line R-404A sits, and how invisible propane and CO2 are at the other end.

Where each refrigerant sits against the limits in law

The warming factor of each gas, with the three limits the regulation itself draws. The further right, the heavier the gas weighs in tonnes of CO2 equivalent — and the faster your unit crosses every threshold.

GWP 150 GWP 750 GWP 2,500 — service ban
R-404A 3,922
R-410A 2,088
R-449A 1,397
R-448A 1,387
R-134a 1,430
R-513A 631
R-1234ze 7
R-290 3
R-744 1

R-404A sits at almost four times the ban line; propane and CO2 are not even visible at this scale. The line at 150 is the value above which new self-contained refrigeration equipment for commercial use may no longer be placed on the market since 2025 — that applies to what you buy, not to what is already standing.

4. What a leak actually costs you, in three amounts

A refrigeration system losing gas costs you three times over, and most operators only ever see one of them. The first is the gas itself: what the engineer charges per kilo of refrigerant added. That amount is on the invoice and is therefore the only one anybody notices.

The second is electricity. A system running below its correct charge has to run longer to reach the same temperature — the compressor logs more hours, efficiency drops, and you pay for it month after month while nobody connects it to the leak. If your energy costs are climbing with no explanation, look at the refrigeration before you look at tariffs.

The third is the most expensive and arrives all at once: the night the room stops holding. What you lose then is not the gas but your stock, and on a Saturday in July that is the entire return on a service. Which is exactly why the annual leak check is not administrative overhead but the cheapest insurance in the building: a leak you find in March is a service call, the same leak in July is a full cold room.

5. Your unit runs on R-404A: three routes, and what they cost

The first route is running it out to 2030. You change nothing, you top up with reclaimed gas, and you replace the installation when it is due anyway. That is defensible for a unit that is going in five years' time regardless, on one condition: that you know the clock is running and that you are not left in 2029 with an emergency replacement at the price everybody else is paying by then.

The second is converting: moving the same unit onto a drop-in replacement with a lower factor — R-449A or R-448A, both around 1,390, or R-513A at 631. That is usually a matter of oil, expansion valve and seals rather than a new installation, and it puts the unit under the ban threshold immediately. The gas is still an F-gas, so the leak checks and the logbook stay, and the European quotas keep squeezing the supply of every F-gas in the years ahead.

The third is replacing it with a natural refrigerant — propane or CO2. That is the most expensive intervention today and the only one that takes you out of this regulation for good: no threshold, no inspection frequency, no end date. For a unit you were replacing anyway it is rarely a difficult call; for a three-year-old machine it is almost never the right one.

The nine refrigerants you meet in a kitchen

One table with everything you need to read your own nameplate: the warming factor, what one kilo of it weighs in tonnes of CO2 equivalent, how many kilos reach the 5-tonne threshold, and where the gas stands from 2025.

Refrigerants, their warming factor and their status since 2025
Refrigerant GWP t CO2e per kg kg to 5 t Status from 2025
R-404A 3,922 3.92 1.27 kg No longer for servicing
R-410A 2,088 2.09 2.39 kg Allowed, being phased down
R-449A 1,397 1.40 3.58 kg Allowed, being phased down
R-448A 1,387 1.39 3.60 kg Allowed, being phased down
R-134a 1,430 1.43 3.50 kg Allowed, being phased down
R-513A 631 0.631 7.92 kg Allowed, being phased down
R-1234ze 7 0.007 714.29 kg Below every threshold
R-290 3 0.003 Not an F-gas
R-744 1 0.001 Not an F-gas

What is actually in your cold room?

Two figures are enough, and both are on your unit or on your last service invoice: which gas is inside and how many kilos. The calculator starts on a common hospitality cold room — four kilos of R-404A — so you can see straight away how it reads; overwrite it with yours.

Add how many kilos went in at the last service and you also see what that leak cost you in money and how many tonnes of CO2 equivalent went into the air.

Refrigerant threshold checker

Your gas, your charge, and the threshold your unit lands on.

On the unit's nameplate and on every service invoice.
Filled in by your choice above. If your plate carries a different blend, type the factor printed there.
The total weight of refrigerant in this installation, per circuit — not per building.
From your service invoice. Leave at zero if nothing was added.
What your engineer charges per kilo of refrigerant, labour excluded.
Charge in tonnes CO2e
kilos × factor ÷ 1,000
Leak check
May you top it up?
What the last service cost

This checker states the European baseline from Regulation (EU) 2024/573. Member states may go further, and exactly which certification your engineer needs differs by country — ask your installer or your trade body. Everything runs in your browser; nothing is sent or stored.

Two things to know when reading it. The charge and the gas are two separate conditions and must therefore never be added together: the kilos set your inspection frequency and your logbook, the factor of the gas sets whether you may top up at all. A three-kilo R-404A unit sits under the first threshold and still may not be topped up.

And the threshold applies per installation, per separate refrigeration circuit. A cold room, a freezer room and an ice machine are three units with three sets of figures, not one sum. Work through them one at a time rather than pooling the kilos of your whole kitchen.

Five terms that appear on your service invoice

Everything on this page comes back to five concepts. Know those and you can read your own maintenance contract in two minutes.

F-gas
A fluorinated greenhouse gas — the family of refrigerants (HFCs and related substances) to which Regulation (EU) 2024/573 applies. Propane (R-290), CO2 (R-744) and ammonia are not F-gases and fall entirely outside that regulation.
GWP (warming factor)
How many times more warming one kilo of this gas causes than one kilo of CO2 over a hundred years. CO2 is 1 by definition; R-404A is 3,922. The value that counts for your obligations is the one in the annexes of the regulation itself.
Tonne of CO2 equivalent
The unit in which every threshold in the regulation is expressed: kilos of refrigerant × GWP ÷ 1,000. It is the reason you cannot read your obligations off the nameplate without doing the arithmetic first.
Service ban
The prohibition on using refrigerant with a GWP of 2,500 or more for the maintenance or repair of refrigeration equipment, in force since 1 January 2025. Reclaimed or recycled gas is exempt until 1 January 2030.
Leak check and logbook
From 5 tonnes of CO2 equivalent, a certified technician must check the installation for leaks periodically, and you must record per unit which gas is in it, how much was added or recovered, by whom and when. Those records are kept for five years.

What you do about it this week, this month and this year

Nobody replaces their refrigeration because of a blog article. This order costs you half a day and does put you in a position to make the decision when it arises rather than when the room gives up.

This week — write down what is standing there

  • Walk your kitchen with your phone and photograph the nameplate of every refrigeration installation: cold room, freezer room, counter, ice machine, air conditioning.
  • Note the refrigerant and the charge in kilos per unit, and convert every line to tonnes of CO2 equivalent with the checker above.
  • Flag every unit running on R-404A or R-507A — those are the units with an end date.
  • Dig out your last service invoices and see how many kilos went in over the past two years. That is your real leak figure.

This month — get the paperwork straight

  • Ask your installer for the leak-check record of every unit above 5 t CO2e, and check that the last inspection fell inside the interval.
  • Keep those records with your maintenance contracts in one place, digitally, and put the next inspection date in the diary.
  • Ask explicitly whether your engineer is certified for the work he carries out on your installation, and have it confirmed on the invoice.
  • Let your maintenance schedule absorb the leak check, so it does not float loose from everything else.

This year — decide before the breakdown

  • For every unit on R-404A, get two quotes side by side: converting to a replacement gas, and replacing with propane or CO2.
  • Put the residual value and the expected remaining life of the unit next to them — converting a twelve-year-old machine is rarely the cheapest route.
  • Book the chosen intervention into your capital planning for the year it fits, not the year the compressor fails.
  • Revisit the trade-off every year: the quotas squeeze the supply of F-gases further year after year, and that moves prices in one direction.

The gas in your cold room is a decision, not a detail

Almost every operator who works through this once lands in the same place: there are two or three units in the building, one of them runs on a gas that may no longer be topped up, and nobody knew because the installation was simply doing what it was supposed to do. That is not negligence — it is a rule that never reached anybody's desk, about a machine that asks for no attention as long as it stays cold.

The good news is that the whole exercise costs half a day. Photograph five nameplates, do five sums, and keep one list. After that you know exactly which unit has a deadline, which unit has to be inspected annually, and which of the two questions applies to you — because those are two different things and they rarely coincide.

And work through the rest of your technical costs in the same movement. The energy cost of poorly running refrigeration and the breakdown cost of a room that fails on a Saturday come out of the same machine — and usually out of the same leak.

Frequently asked questions

What are F-gases and are they in my cold room?

F-gases are fluorinated greenhouse gases: the family of synthetic refrigerants found in virtually all professional cold rooms, freezers, chilled counters and ice machines. On your nameplate you recognise them by a code starting with R — R-404A, R-134a, R-449A, R-448A, R-513A, R-410A. If it says R-290 (propane) or R-744 (CO2) there is no F-gas in your unit and these rules do not apply.

How do I convert kilos of refrigerant into tonnes of CO2 equivalent?

Kilos of refrigerant × the warming factor (GWP) of the gas ÷ 1,000. Four kilos of R-404A at a factor of 3,922 comes to 15.7 tonnes of CO2 equivalent. That is the unit in which every threshold in the regulation is expressed, so without that conversion you cannot read your obligations off the nameplate.

From what point must my refrigeration be checked for leaks?

From 5 tonnes of CO2 equivalent: at least every 12 months, or every 24 months if an automatic leak-detection system is fitted. From 50 tonnes that becomes every 6 months (12 with detection) and from 500 tonnes every 3 months, with a mandatory detection system. The check must be done by a certified technician and you keep a record per unit, for five years.

May my R-404A cold room still be topped up?

Not with virgin gas. R-404A has a warming factor of 3,922, which puts it above the 2,500 line beyond which refrigerant may no longer be used for the maintenance or repair of refrigeration equipment as of 1 January 2025. There is one exception: reclaimed or recycled gas is still allowed until 1 January 2030. Your unit may keep running, but it has an end date.

Is it better to convert my refrigeration or replace it?

It depends on the age of the unit. Converting to a replacement gas such as R-449A, R-448A or R-513A puts the installation under the ban threshold immediately and usually costs a fraction of a new machine, but it stays an F-gas with leak checks, a logbook and a supply that the European quotas make tighter year after year. Replacing with propane or CO2 takes the unit out of the regulation for good and is the logical choice when the machine is due for replacement anyway.

Does the threshold apply per unit or to my whole kitchen together?

Per installation, so per separate refrigeration circuit. A cold room, a freezer room, a chilled counter and an ice machine are four units with four separate calculations; you do not pool their charges. That works both ways: four small units that each stay under the threshold bring no obligation at all between them, and one large installation can bring three on its own.