Fluorinated gases in indoor heat pumps: what changes for manufacturers and importers in 2026

Key data

Manufacturers and importers of indoor monoblock heat pumps have the green light to continue introducing equipment with fluorinated greenhouse gases into the European market. The Commission Implementing Regulation (EU) 2026/2486, published on 11 November 2026 and in force from the previous day, grants a specific exemption to Regulation (EU) 2024/573, which generally restricts the placing on the market of F-gases in air conditioning and heating equipment.

The key lies in the technical justification: the exemption only applies when no viable alternatives with low global warming potential (low GWP) refrigerants exist for certain equipment designs. It is not a universal exemption for the entire range of indoor heat pumps, but for specific types that meet strictly defined technical conditions.

What does this regulation establish?

Regulation (EU) 2024/573 is the general European framework that regulates and progressively restricts the use of fluorinated greenhouse gases (F-gases) in different types of equipment, with the aim of reducing emissions of gases with high global warming potential (GWP). Its application directly affects the HVAC sector, which has historically depended on fluorinated refrigerants such as R-410A or R-32.

The new Implementing Regulation 2026/2486 introduces an exemption from that general restriction for a specific case:

• Equipment of the type monoblock indoor heat pump
• For which no viable technical alternatives exist with low GWP refrigerants
• Under strictly defined technical conditions by the regulation itself

The regulatory logic is clear: the EU does not want to slow down the deployment of heat pumps—a key technology for decarbonizing the building stock—due to lack of mature technical solutions. But the exemption is temporary and conditional: the sector is expected to migrate towards alternative refrigerants as technology advances.

Economic and operational impact

For companies in the sector, this exemption has an immediate and positive operational impact: it avoids the interruption of product lines that otherwise could not be marketed in the EU due to non-compliance with the general F-gas restriction.

Without the exemption, manufacturers and importers with indoor monoblock heat pump models that still do not have versions with low GWP refrigerants would have had to withdraw those products from the European market or accelerate a costly technological conversion at full speed. The specific implications are:

• Sales continuity for technically justified models, without the need for immediate product reformulation.
• Additional time for R&D in the transition towards alternative refrigerants (propane R-290, R-454B, R-466A or other low GWP options).
• Technical documentation obligation: companies must be able to prove that their equipment meets the specific requirements that justify the exemption. Without that accreditation, the product cannot rely on it.
• Medium-term regulatory risk: the exemption is not indefinite. Companies that do not invest in technological transition will be exposed when the exemption expires or when validated technical alternatives appear.

Who does it affect?

• Manufacturers of indoor monoblock heat pumps based in or selling in the EU that use F-gases in their equipment.
• Importers that place on the European market this type of equipment from third countries.
• Distributors that market these products in the European supply chain.
• Installers and HVAC sector companies that advise customers on which equipment can be legally installed.
• Procurement and product compliance departments of companies that acquire this equipment for their facilities.

Practical example

A European manufacturer of indoor monoblock heat pumps markets a model that uses R-410A (an F-gas with high GWP). With the entry into force of Regulation (EU) 2024/573, that model would have been excluded from the European market as it could not be marketed with that refrigerant.

However, if that manufacturer can technically demonstrate that no viable alternative currently exists with low GWP refrigerant for that specific equipment design—for example, due to safety restrictions in indoor installations that prevent the use of flammable propane (R-290)—, it can rely on the exemption in Regulation 2026/2486 and continue to market the model in the EU while that technical situation persists.

The operational key is the technical documentation that proves the absence of viable alternative. Without that file, the product cannot rely on the exemption even if it could technically meet the requirements.

What should companies do now?

1. Identify which models in your catalog use F-gases in monoblock indoor configurations and could be affected by the general restriction of Regulation (EU) 2024/573.
2. Verify if those models meet the specific technical requirements that justify the exemption according to Regulation 2026/2486. Not all equipment with F-gases is automatically covered.
3. Prepare and keep updated the technical documentation that proves the absence of viable alternatives with low GWP refrigerants for the models relying on the exemption.
4. Plan the technological roadmap towards alternative refrigerants, given that the exemption is temporary and the European regulatory framework will continue to tighten.
5. Inform the distribution network and installers about which models can be marketed under the exemption and which cannot, to avoid non-compliance in the supply chain.
6. Consult with specialized advisors in F-gas regulations if you have doubts about whether your specific products meet the technical conditions defined in the regulation.

Official source

Consult the complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602486