No "new gas" is imposed in 2026. What exists is a calendar of placing-on-the-market bans, set by Regulation (EU) 2024/573, which bites equipment by equipment rather than refrigerant by refrigerant. The two dates that decide your purchasing: 1 January 2027 for air-to-water split systems up to 12 kW with a GWP of 150 or more, and 1 January 2029 for air-to-air splits of the same size. R32, at a GWP of 675, falls under both. R290, at 3, passes everywhere.
Understanding heat pump refrigerants: definitions and key points
What does the refrigerant do in a heat pump's cycle?
In a heat pump, the refrigerant circulates in a closed loop. It picks up heat by evaporating at low temperature, then releases it by condensing on the heating side. This change of state, driven by pressure (compressor, expansion valve), "carries" heat from outside to inside. One point to keep in mind. The circuit must stay leak-tight. A leak lowers performance, and triggers recovery and traceability obligations.
The main refrigerant families: HFC, HFO, natural (CO₂, propane)
There are three main families. HFCs (e.g. R410A, R32) are widespread, but their high GWP weighs on the choice. HFOs show a much lower climate impact, with safety rules to follow depending on the product. Finally, natural refrigerants are gaining ground. CO₂ (R744) operates at very high pressure. Propane (R290) offers excellent efficiency, but it is flammable, so the charge is limited and siting needs care. To connect these ideas to real results on site, also see how a heat pump's actual performance is measured.
2026 regulation: what changes for heat pump refrigerants
The F-Gas framework and phased bans: what you need to check
In 2026, the European F-Gas regulation tightens further. The key point for your heat pump projects is the drop in HFC quotas, which makes some refrigerants scarcer and more expensive. Before signing, check the planned refrigerant, its GWP level, and the upcoming ban schedule for new equipment with a high GWP. Those characteristics sit on the product data sheet, or directly in a catalogue built from verified manufacturer data.
GWP thresholds and labelling: reading and comparing a technical data sheet
On a technical data sheet, look for the GWP (R410A ≈ 2,088, R32 ≈ 675, R290 ≈ 3), the charge in kg and the CO2 equivalent. At equal performance, a lower GWP limits the risk of extra cost and regulatory blockage, and a refrigerant at or below a GWP of 150 also lowers the minimum SEER and SCOP required under ecodesign. Also compare refrigerant availability and maintenance conditions.
Capability certificate, traceability and leak detection: on-site obligations
On site, the company must hold a capability certificate. Every intervention involves recovery, traceability of quantities, and record-keeping. The leak-detection requirement depends on the threshold in tonnes of CO2 equivalent. Plan for these points at the quote stage, this is often what keeps the job clean through to commissioning. To scope the full set of requirements and avoid gaps during inspections, also see the compliance rules to know for RGE tradespeople.
Obligation
Leak checks: is this job covered?
The obligation is not triggered by the kilograms of refrigerant but by tonnes of CO₂ equivalent: the charge times the fluid’s global warming potential. Hence different answers for the same charge depending on the fluid.
3.0 kg
Equivalent charge
2.0 t CO₂e
GWP 675
Leak check
Not required
Trigger threshold
5 t CO₂e
that is 7.4 kg of this fluid
Below the threshold: no periodic check
This is the usual case for a residential R32 multi-split. What still applies: the company’s certification, the tightness test and evacuation at commissioning, the intervention record and the logbook.
Regulation (EU) 2024/573, article 5. Periodic checks are one thing; the company’s certification, the tightness test at commissioning and the record keeping apply whatever the charge.
An Argile tool
The ban calendar, equipment by equipment
Annex IV of the regulation lists bans on placing on the market, not on use: equipment already installed keeps running and can still be serviced. What stops is your ability to buy a new one. Here are the lines that concern residential cooling and heat pumps.
| Equipment | Banned GWP threshold | From |
|---|---|---|
| Split systems holding less than 3 kg of Annex I gases | GWP ≥ 750 | 1 January 2025 |
| Air-to-water splits, rated capacity ≤ 12 kW | GWP ≥ 150 | 1 January 2027 |
| Monobloc and self-contained units, ≤ 12 kW | GWP ≥ 150, or 750 where site safety requires it | 1 January 2027 |
| Monobloc and self-contained units, > 12 kW and ≤ 50 kW | GWP ≥ 150, or 750 where site safety requires it | 1 January 2027 |
| Air-to-air splits, rated capacity ≤ 12 kW | GWP ≥ 150 | 1 January 2029 |
| Split systems, rated capacity > 12 kW | GWP ≥ 750 | 1 January 2029 |
| Other self-contained equipment | GWP ≥ 150 | 1 January 2030 |
| Monobloc and self-contained units, ≤ 12 kW | any fluorinated gas, no threshold | 1 January 2032 |
| Split systems, rated capacity > 12 kW | GWP ≥ 150 | 1 January 2033 |
| Split systems, rated capacity ≤ 12 kW | any fluorinated gas, no threshold | 1 January 2035 |
Two readings that matter on site. First, air-to-water goes two years before air-to-air in the domestic range: if you mostly fit 8 to 12 kW air-to-water heat pumps, your R32 deadline is 2027, not 2029. Second, the last row is the one people miss: from 2035 a split below 12 kW may contain no fluorinated gas at all, whatever its GWP. HFOs are not a destination, they are a stage.
Why your refrigerant prices rise with nothing being banned
The mechanism that weighs most on your costs is not in the table. Since 1 January 2025, being allocated a placing-on-the-market quota requires paying 3 euros per tonne of CO2 equivalent of HFC produced or imported. For a refrigerant at a GWP of 675 that works out at roughly 2 euros per kilo; for R410A at 2,088, roughly 6 euros per kilo, before the scarcity effect of the quota itself. Cylinder prices and service recharges follow, and that belongs in your maintenance contracts rather than in your margin.
Leak checks, meanwhile, have been extended to HFOs, which were previously outside their scope. Their frequency depends on the charge, expressed in tonnes of CO2 equivalent for HFCs and in kilograms for HFOs: move a fleet to HFO without revisiting the service schedule and you end up non-compliant on machines you assumed were out of scope. On sizing the machines you will fit instead, see calculating cooling capacity.
Environment: choosing a lower-impact refrigerant without compromising performance
GWP, direct and indirect emissions: a simple way to think about it
GWP measures a refrigerant's climate impact in the event of a leak. To reason quickly, add up two items. Direct emissions, linked to leaks and top-ups. Indirect emissions, linked to the electricity the heat pump consumes over 15 to 20 years. A low-GWP refrigerant helps, but a properly sized and well-tuned unit often makes the bigger difference.
Impact of refrigerant choice on efficiency, temperatures and durability
R290 (propane) and CO2 have a very low GWP, but require a suitably adapted design. R290 often allows good water temperatures and good efficiency, at the cost of safety constraints (flammability) and installation requirements. R32 remains common, with a higher GWP, and solid performance. In every case, check the operating range, defrost cycles, and component quality.
Transport, end of life, recovery: limiting the footprint on site
On site, the goal is simple. Zero leaks. Clean fittings, careful vacuum pull-down, leak checks, and traceability. Also plan for end of life. Refrigerant recovery, storage in an approved cylinder, and handover to an authorised operator. Fewer losses means less impact, and fewer callbacks.
Practical comparison of the 2026 options for your heat pump projects
R32: use cases, limits and availability to watch
R32 remains common on air-to-air heat pumps and some air-to-water units. Good balance of cost and performance, with a lower GWP than older blends. Limits. A mildly flammable A2L refrigerant, with commissioning requirements. In 2026, HFC quotas and the F-Gas phase-down schedule may tighten supply. Plan your orders ahead.
R290 (propane): strengths, safety constraints and installation
R290 is attractive for its very low climate footprint and its efficiency, especially in outdoor monobloc units. The trade-off. An A3 flammable refrigerant. On site, check clearances, ventilation, the absence of ignition sources, EN 378 compliance, and plan for a clear intervention procedure.
CO₂ (R744) and other solutions: when to propose them to the right client
CO₂ targets uses where high temperature matters, such as DHW and certain networks. Higher pressures and a more limited product range. To propose to clients ready to invest and maintain the system. Alternatives. HFOs or lower-GWP blends depending on the manufacturer, useful when R290 is not an option. To scope the choice according to emitter needs, also see the impact of low- vs high-temperature heat pumps on emitters.
A method for tradespeople: securing your quotes and installations in 2026
By heat pump type: air-to-air, air-to-water, water-to-water, hybrid
Start by scoping the use case. An air-to-air heat pump targets room-by-room comfort, without heating water. Air-to-water is the most common in renovation with radiators or underfloor heating. Water-to-water needs a resource (groundwater, boreholes) and an upfront study. Hybrid makes sense when the existing backup system is reliable and the client wants to smooth out winter peaks. Aim for accurate sizing, not "as big as possible".
By building and need: renovation, new build, low/high temperature
Before the quote, check insulation, emitters, hydraulics and controls. At low temperature, a heat pump gains efficiency. At high temperature, clearly state the limits, the possible adaptations and the cost of the emitters. In 2026, keep the incentives reflex in mind. RGE, CEE, MaPrimeRénov'. A reliable audit or DPE avoids surprises.
By your organisation: training, tooling, stock and after-sales service
Secure the execution. Manufacturer training, QualiPAC if you're targeting incentives, and refrigerant-handling skills. Prepare your tooling (vacuum gauge, scale, leak detection) and a small stock of critical parts. Scope the after-sales service. Commissioning, adjustments, and annual maintenance explained from the quote stage.
