EU F-Gas Regulation 2024/573 and Refrigeration Compressor Oils
Summary
Regulation (EU) 2024/573, in force since 11 March 2024, moves EU refrigeration from R-404A to CO2, propane and HFO blends (as of 2026-10-14). The oil follows the refrigerant: HFO blends keep polyol ester (POE) oil, while CO2 and propane compressors take the oil their maker specifies. Existing R-404A systems may use reclaimed or recycled gas until 1 January 2030.
Regulation (EU) 2024/573 was published in the Official Journal on 20 February 2024 and entered into force on 11 March 2024, repealing Regulation (EU) No 517/2014 (Castel, 2024).
R-448A has a GWP of 1387 and R-449A a GWP of 1397, against 3922 for R-404A, on the IPCC AR4 basis (BITZER Refrigerant Report 21, 2020).
BITZER makes a supplier guarantee of moisture content below 50 ppm a precondition for alternative oils in its HFC and HFO compressors, used at the system owner's own responsibility (BITZER KT-500, 2025).
When a mineral oil system is converted to R-448A, Honeywell's procedure prefers 95% synthetic oil after the oil change, checked with an oil refractometer (Honeywell, 2019).
This analysis covers stationary refrigeration under Regulation (EU) 2024/573 and the compressor oils that follow from its bans. It does not cover mobile refrigeration, air conditioning, heat pumps or rules outside the EU, and the oil guidance is compressor maker guidance, not law. It is not legal advice for a specific site.
What is changing under Regulation (EU) 2024/573, and when?
Regulation (EU) 2024/573 tightens EU refrigeration in three steps: a servicing limit from 2025, placing-on-market bans from 2025 to 2030, and a wider servicing limit from 2032. Status as of 2026-10-14: the Regulation was adopted on 7 February 2024, entered into force on the twentieth day after its publication (Regulation 2024/573, Article 38), which was 11 March 2024, and repeals Regulation (EU) No 517/2014 (Castel, 2024). The English text was corrected by a corrigendum of 24 March 2025 that, among other points, set the chiller limit in Annex IV point 7(d) at "a GWP of 750 or more" (Corrigendum to Regulation 2024/573, 2025). The timeline below lists the dates that change which refrigerant, and so which oil, an EU refrigeration plant can use.
Date | Provision | Effect on refrigeration oil |
|---|---|---|
11 March 2024 | Entry into force (Regulation 2024/573, Article 38) | Bans and servicing limits fixed in law |
1 January 2025 | Article 13(3); Annex IV points 3(c), 4 and 5(b) (Regulation 2024/573) | Virgin gas of GWP 2500 or more out of servicing; new self-contained units below GWP 150 |
1 January 2027 | Annex IV point 7 (Regulation 2024/573) | New chillers limited by capacity and GWP |
1 January 2030 | Article 13(3) exemption ends; Annex IV point 5(c) (Regulation 2024/573) | Reclaimed R-404A top-up ends; new non-chiller plant below GWP 150 |
1 January 2032 | Article 13(5); Annex IV point 7(c) (Regulation 2024/573) | Virgin gas of GWP 750 or more out of servicing, R-448A included; new chillers up to 12 kW F-gas free unless site safety requires otherwise |
The row that decides most oil stock plans is 1 January 2030: from that date, new refrigeration equipment other than chillers must use a refrigerant below GWP 150 unless safety requirements at the site require otherwise; the primary circuit of cascade multipack systems of 40 kW or more may still use F-gases below GWP 1500 (Regulation 2024/573, Annex IV points 5(c) and 6).
Which refrigeration bans in Regulation (EU) 2024/573 apply from 2025 to 2030?
The refrigeration bans in Regulation (EU) 2024/573 that apply from 2025 to 2030 are one servicing ban and four market bans. The servicing ban in Article 13(3) reads: "From 1 January 2025, the use of fluorinated greenhouse gases, with a global warming potential of 2 500 or more, for the maintenance or servicing of any refrigeration equipment shall be prohibited." (Regulation 2024/573, Article 13). Because the 2025 sentence covers any refrigeration equipment, the 40 tonnes of CO2 equivalent charge size named earlier in the paragraph no longer limits it; in our reading, small R-404A systems are covered (Regulation 2024/573, Article 13).
The servicing ban excludes military equipment and equipment designed to cool products below -50 °C (Regulation 2024/573, Article 13). Until 1 January 2030, it also excludes reclaimed gas in containers labelled under Article 12(7), and recycled gas recovered from such equipment and used only by the undertaking that recovered it or for which it was recovered (Regulation 2024/573, Article 13). It also does not apply to equipment for which an exemption has been authorised under Article 11(5) (Regulation 2024/573, Article 13).
Annex IV covers new equipment. Self-contained refrigeration equipment other than chillers with a GWP of 150 or more has been banned since 1 January 2025, except where safety requirements at the site require it (Regulation 2024/573, Annex IV). Other refrigeration equipment, except chillers, is banned at GWP 2500 or more from 1 January 2025, unless designed to cool products below -50 °C, and at GWP 150 or more from 1 January 2030, unless required by safety requirements at the site (Regulation 2024/573, Annex IV).
Which refrigeration products and oils are affected by the EU F-gas bans?
The refrigeration products affected by the EU F-gas bans are self-contained cabinets, centralised multipack systems, condensing units and other non-chiller plant, and chillers, each with its own GWP limit and date. The table below maps each Annex IV entry to the refrigerants that meet it and the oil families compressor makers list for them; the refrigerant column is our reading of the options, not a legal requirement.
Product (Annex IV point) | GWP limit and date | Refrigerants that meet it | Usual oil family |
|---|---|---|---|
Self-contained refrigeration, not chillers (point 4) | Below 150 from 1 January 2025, unless site safety requires otherwise (Regulation 2024/573) | Propane (R290), CO2 (R744) | Per hermetic compressor maker; with propane, mineral oil serves over a wide range and POE or PAO offer more favourable properties (BITZER Refrigerant Report 21, 2020) |
Commercial multipack systems of 40 kW or more (point 6) | Below 150 since 1 January 2022; below 1500 in a cascade primary circuit (Regulation 2024/573) | CO2, with an HFO blend allowed in the cascade primary circuit | CO2: POE, or PAG for high pressures (BITZER KT-500, 2025) |
Other refrigeration, not chillers (point 5(b)) | Below 2500 from 1 January 2025 (Regulation 2024/573) | R-448A (GWP 1387), R-449A (GWP 1397) (BITZER Refrigerant Report 21, 2020) | POE (BITZER KT-500, 2025) |
Other refrigeration, not chillers (point 5(c)) | Below 150 from 1 January 2030, unless site safety requires otherwise (Regulation 2024/573) | CO2, propane, R-454C or R-455A (GWP 148) (BITZER Refrigerant Report 21, 2020) | Per refrigerant: POE, PAG or PAO |
Chillers (points 7(b) and 7(d)) | Up to 12 kW: below 150 from 1 January 2027; above 12 kW: below 750 from 1 January 2027, unless site safety requires otherwise (Regulation 2024/573; Corrigendum, 2025) | Low-GWP HFO blends, propane | POE; polyvinyl ether (PVE) increasingly in factory-made chillers (BITZER Refrigerant Report 21, 2020) |
The row with the widest reach is point 5(c): from 1 January 2030, condensing units and remote plant that today run R-448A or R-449A on POE must, when newly placed on the market, move to refrigerants below GWP 150, except the primary circuit of cascade multipack systems covered by point 6 (Regulation 2024/573, Annex IV). The bans reach new equipment only; the Finnish Environment Institute states that they "do not affect products or equipment already in use" (Finnish Environment Institute, 2025). For oil suppliers, the likely effect is a shift in mix: POE for HFO blend retrofits through the late 2020s, then more CO2 grades of POE and PAG, and propane grades, as new plant moves below GWP 150. That last point is our inference from the Annex IV dates, not a forecast from a source.
Which compressor oils go with the low-GWP refrigerants that replace R-404A?
The compressor oils that go with the low-GWP refrigerants replacing R-404A are POE for HFO blends, special POE or polyalkylene glycol (PAG) for CO2, and maker-specific PAG, PAO or mineral oil for propane. BITZER states that "only oils specified by the compressor manufacturer may be used" and adds: "Because of the increased reactivity of HFOs with oil, this is especially true for systems with these refrigerants." (BITZER Refrigerant Report 21, 2020).
HFO blends such as R-448A and R-449A take the same POE family as R-404A. BITZER notes that these blends contain R1234yf and R1234ze(E), that part of them is highly soluble in oil and strongly reduces viscosity, and that their low chemical stability "requires particular care regarding cleanliness, dryness and evacuation" (BITZER KT-500, 2025).
CO2 needs oils formulated for it. BITZER charges POE as the standard oil for subcritical and transcritical CO2 compressors and PAG as the precondition for applications above 40 bar low side or 120 bar high side (BITZER KT-500, 2025). Highly soluble POE reduces viscosity strongly in CO2, while conventional oils are mostly not miscible and need costly oil return measures (BITZER Refrigerant Report 21, 2020).
Propane dissolves strongly in customary oils, so BITZER charges its R290 semi-hermetic compressors with a special high viscosity index oil: PAG as standard and PAO as an option (BITZER KT-500, 2025). The same maker's refrigerant report says mineral oils can serve over a wide range, with POE and PAO offering more favourable properties (BITZER Refrigerant Report 21, 2020).
Does the 2025 servicing ban force an oil change in existing R-404A systems?
The 2025 servicing ban does not by itself force an oil change in existing R-404A systems: it limits which refrigerant may be charged, and an R-404A system already runs on POE. Until 1 January 2030, such a system may be topped up with reclaimed or recycled R-404A under the Article 13(3) conditions, with no change to the oil (Regulation 2024/573, Article 13).
After a retrofit to R-448A, the oil usually stays. Honeywell's retrofit guide says: "R-404A systems typically already have POE oil and so an oil change is not required." (Honeywell, 2019). The same guide adds two conditions. A full oil change is warranted if the lubricant is contaminated or an acid test shows high acidity, and the viscosity grade and brand must be checked with the compressor maker for the compressor being retrofitted (Honeywell, 2019).
Systems that once ran R-22, R-402A or R-408A on mineral oil are different. For those, Honeywell says the existing lubricant is in most instances not suitable for R-448A, a change to a synthetic lubricant is required, and 95% synthetic oil is preferred after the change (Honeywell, 2019).
A limit follows from the Regulation itself. R-448A has a GWP of 1387 (BITZER Refrigerant Report 21, 2020), so from 1 January 2032 R-448A that is not reclaimed or recycled may no longer be used to service stationary refrigeration other than chillers (Regulation 2024/573, Article 13). In our reading, an R-448A retrofit on existing POE is therefore a bridge to 2032, not an end point.
What are the technical consequences of the EU F-gas transition for refrigeration oil condition?
The technical consequence of the EU F-gas transition for refrigeration oil condition is that moisture and acid limits tighten as plants move to HFO blends and CO2. POE, PAG and polyvinyl ether oils are strongly hygroscopic, and with CO2 or ester oils, water reacts to form acids that corrode metal and cannot be removed by evacuation (BITZER KT-500, 2025). The table below shows BITZER's warning values for used oil in its reciprocating compressors, based on the reference values of DIN 51503-2; other compressor makers set their own.
Oil and refrigerant | Max. water content (DIN 51777) | Total acid number (DIN ISO 6618) | Viscosity at 40 °C |
|---|---|---|---|
POE for HFC and HFO blends | 200 mg/kg (BITZER KT-500, 2025) | 0.2 mg KOH/g (BITZER KT-500, 2025) | Outside ±15% of new oil (BITZER KT-500, 2025) |
POE for CO2 | 150 mg/kg (BITZER KT-500, 2025) | 0.2 mg KOH/g (BITZER KT-500, 2025) | Outside ±15% of new oil (BITZER KT-500, 2025) |
PAG for CO2 and hydrocarbons | 800 mg/kg (BITZER KT-500, 2025) | 0.2 mg KOH/g (BITZER KT-500, 2025) | Outside ±15% of new oil (BITZER KT-500, 2025) |
PAO for hydrocarbons | 80 mg/kg (BITZER KT-500, 2025) | 0.2 mg KOH/g (BITZER KT-500, 2025) | Outside ±15% of new oil (BITZER KT-500, 2025) |
The key row for retrofits is the first: a POE sample from an R-404A or R-448A system with more than 200 mg/kg water or a total acid number above 0.2 mg KOH/g has reached BITZER's warning value (BITZER KT-500, 2025).
Used oil from flammable refrigerant systems is a fire hazard. BITZER warns that oil from R290, R1270 or R1234yf systems may still contain dissolved flammable gas at atmospheric pressure (BITZER KT-500, 2025). Drain it only under the oil's safety data sheet (SDS) and the waste oil rules of Directive 2008/98/EC, Article 21, as transposed nationally, with no open fire or ignition source nearby, into pressure resistant vessels filled with nitrogen and marked with the ISO 7010 W021 flammable sign (BITZER KT-500, 2025).
What should oil suppliers and service companies do before 2030 under the EU F-gas Regulation?
Before 2030, oil suppliers and service companies should stock the oils the new refrigerants need, test oil before every R-404A retrofit, and help plant owners plan for the 1 January 2030 and 1 January 2032 limits in Regulation (EU) 2024/573. The table below assigns the work. The dates come from the Regulation; the actions are our reading of what those dates require of the oil side, since the Regulation itself sets no rule for compressor oil.
Action | Who | By when |
|---|---|---|
Stock POE grades in the viscosity grades compressor makers list for R-448A and R-449A | Oil suppliers, wholesalers | Now, for retrofits and new plant |
Stock CO2 grades of POE and PAG, and the propane grades makers specify, in sealed containers | Oil suppliers, service companies | Before taking on CO2 or propane plant |
Test oil for acid number, water and, in former mineral oil systems, mineral share, and confirm grade with the compressor maker | Service companies | Before each R-404A retrofit |
Label reclaimed gas containers with the batch number and reclamation facility, and use recycled gas only within the recovering undertaking | Reclaimers, service companies | Each top-up until 1 January 2030 |
Plan replacement or retrofit of R-404A plant before reclaimed supply ends | Plant owners, service companies | Before 1 January 2030 |
Plan the 2032 servicing limit for R-448A and R-449A plant | Plant owners, service companies | Before 1 January 2032 |
The oil test row matters most for the oil side. The Regulation governs the gas, for example by requiring reclaimed gas containers to carry the batch number and the name and address of the reclamation facility in the Union (Regulation 2024/573, Article 12), but it sets no rule for the oil. An acid number or water result above the compressor maker's warning value, such as 0.2 mg KOH/g or 200 mg/kg for BITZER POE (BITZER KT-500, 2025), is the signal to change the oil during the retrofit rather than after a failure.
What is still open in the EU F-gas transition for refrigeration oils?
Three points are still open in the EU F-gas transition for refrigeration oils as of 2026-10-14: a review that may change Annex IV, possible exemptions, and long-term HFO stability. Article 35(5) requires the Commission to report on the effects of the Regulation by 1 January 2030 and, if appropriate, to propose amendments, which may include Annex IV (Regulation 2024/573, Article 35).
Exemptions can shift individual dates. The Commission may authorise placing-on-market exemptions of up to 4 years under Article 11(5), as it did for ice makers and frozen drinks dispensers using gases of GWP 150 or more from 1 January 2025 to 30 June 2026 (European Commission, 2026). Article 13(6) also allows exemptions of up to 4 years from the 2032 servicing limit for stationary refrigeration, and from the 2026 limit for air conditioning and heat pumps, where reclaimed and recycled gas is verifiably short (Regulation 2024/573, Article 13). The Commission's simplification proposal of 21 May 2025 concerns F-gas Portal registration, not refrigeration ban dates (European Commission, 2025).
BITZER notes concerns about the long-term stability of R1234yf in real refrigeration circuits, while extensive testing has shown the required stability in mobile air conditioning, and that some lubricants show increased reactivity that suitable formulation or stabilizers can suppress (BITZER Refrigerant Report 21, 2020). Lubinpla, an applied AI company, works cases like this from a company's own documents, such as SDS and oil analysis certificates, and returns one cited document for review, with each step approved by the user.