A client will arrive with a headline about the end of split systems and ask whether they will have to dismantle their heat pump. The F-gas Regulation says nothing of the sort. It does say something that changes what you can offer in the 2027 season - and that is better raised with them now than in December 2026, when a particular model runs out.
This article collects the dates from Annex IV, separates what the prohibition actually covers from what the press added, and shows the trap the 12 kW boundary creates when sizing. Every date and threshold comes from Regulation (EU) 2024/573 as published in the Official Journal. Legal position as at 10 August 2026.
What exactly is prohibited - three provisions, not one
The shorthand "banned from 2027" hides the fact that three different provisions are in play, each biting on a different party.
Placing on the market (Article 11(1)). Annex IV lists the dates from which given equipment may not be placed on the market. The regulation defines that as customs release for free circulation in the Union, or supplying or making available to another person in the Union for the first time, for payment or free of charge. So it bites on the manufacturer and the importer, not on the installation at a client's house.
Putting into operation and use (Article 13(19)). This is the part summaries usually skip. The putting into operation and use of equipment listed in Annex IV points 8(b)-(e) and 9(b)-(f) is prohibited after the prohibition date - unless the operator can provide evidence that safety requirements at the location do not allow equipment with a lower GWP to be installed, or that the equipment was placed on the market before the prohibition date. The operator keeps that evidence for at least five years and produces it on request (Article 13(20)).
Subsequent supply (Article 11(1), final subparagraph). One year after each Annex IV date, further supplying or making available of equipment lawfully placed on the market before that date is permitted only where evidence exists that it was lawfully placed on the market before the deadline.
Taken together these three give a picture different from "the ban does not cover use", but calmer than the headlines suggest:
- Units already installed keep working. No provision requires replacing or removing a working heat pump because of its refrigerant. The Article 13(19) prohibition passes them by expressly, because they were placed on the market before the date.
- Stock can be sold through, but from 2028 with paperwork. A unit placed on the market before 1 January 2027 may be sold and installed later too. From 1 January 2028 such a supply needs evidence that it reached the market before the deadline.
- The evidence is now part of the job. It is the operator - usually the owner of the installation - who has to keep it for five years, and they will get it from you. The purchase invoice with its date, plus the model and refrigerant recorded in the file, settle it; assembled two years later, they settle nothing.
- Servicing continues. Article 11(1) expressly permits placing on the market the parts required to repair and service existing Annex IV equipment, provided the repair does not increase the system's capacity or its F-gas charge and does not raise the refrigerant's GWP. The separate prohibition in Article 13(4) covers servicing with refrigerants of GWP 2500 or more and applies from 1 January 2026 - R410A (roughly 2088) and R32 (675) are below that threshold.
The practical conclusion: on 1 January 2027 nothing disappears from installations. It disappears from the manufacturer's price list, and then gradually from distributors' warehouses.
Dates for split systems
Annex IV treats split equipment (point 9) separately from self-contained equipment including monoblocs (point 8). The thresholds and dates differ between the two groups, and that is the source of most of the confusion. The first row below has applied since 2025; the second is the one the press is writing about.
| Provision | Equipment | Rated capacity | GWP threshold | Prohibited from |
|---|---|---|---|---|
| point 9(a) | Single split containing less than 3 kg of Annex I F-gases | - | 750 or more | 1 January 2025 |
| point 9(b) | Split air-to-water | 12 kW or less | 150 or more | 1 January 2027 |
| point 9(c) | Split air-to-air | 12 kW or less | 150 or more | 1 January 2029 |
| point 9(e) | Split | above 12 kW | 750 or more | 1 January 2029 |
| point 9(f) | Split | above 12 kW | 150 or more | 1 January 2033 |
| point 9(d) | Split | 12 kW or less | any F-gas | 1 January 2035 |
The second row is the one that changes the single-family heat pump market. The regulation defines a split system as one made up of several units connected by refrigerant lines, requiring the refrigerant-circuit components to be connected at the place of use. Fixed double duct equipment is accounted for as a split, under point 9 - the same date, not a milder category.
Dates for monobloc and self-contained equipment
Point 8 covers everything that is not a split - from a portable room air conditioner to a monobloc.
| Provision | Equipment | Maximum rated capacity | GWP threshold | Prohibited from |
|---|---|---|---|---|
| point 8(a) | Plug-in room air conditioner, moveable between rooms | - | 150 or more (HFCs only) | 1 January 2020 |
| point 8(b) | Plug-in room air conditioner, monobloc air-conditioning equipment, other self-contained equipment and self-contained heat pumps | up to and including 12 kW | 150 or more | 1 January 2027 |
| point 8(d) | Monobloc and other self-contained air-conditioning equipment and heat pumps | above 12 kW up to and including 50 kW | 150 or more | 1 January 2027 |
| point 8(e) | Other self-contained equipment, not covered by (b) or (d) | - | 150 or more | 1 January 2030 |
| point 8(c) | As in (b) | up to and including 12 kW | any F-gas | 1 January 2032 |
Rows two and three are worth putting side by side: for self-contained equipment the 12 kW boundary does not move the date by a single day. The incentive to reach for a larger machine, described below, applies to splits only.
Chillers are a separate category
Point 8 excludes chillers in its very title, and they have their own point 7 in Annex IV, with their own dates: a 150 threshold up to and including 12 kW from 1 January 2027, any F-gas up to 12 kW from 1 January 2032, and a 750 threshold above 12 kW already from 1 January 2027.
The boundary follows from the definition. The regulation defines a chiller as a system whose primary function is cooling a heat-transfer fluid. A monobloc air-to-water unit bought to heat a building has no primary cooling function, so it is accounted for under point 8, not point 7. For reversible equipment and on commercial jobs this classification is worth checking separately, because above 12 kW point 7 sets a 750 threshold applying from 2027 rather than the 2030 date in (e).
"Monobloc" does not mean "safe"
This is the second misconception, and a more common one than the first. Split is presented as the architecture the rules eliminate and monobloc as the one that survives. The tables show otherwise: a monobloc with a rated capacity up to and including 12 kW, on an F-gas with a GWP of 150 or more, leaves the market on 1 January 2027, the same day as a split air-to-water unit of the same capacity.
What decides whether equipment falls under the provision is the refrigerant, not the architecture. A monobloc stays in the catalogue when it runs on a refrigerant outside the scope of these prohibitions or below the threshold - not because it is a monobloc.
One caveat is worth knowing before citing this point in documentation. All language versions of the regulation are equally authentic, and point 8(b) is drafted differently across them. The English version ties "plug-in" to room air-conditioning equipment alone. In the Polish version "typu plug-in" sits at the end of the enumeration, where it can be read as applying to self-contained heat pumps as well; on that reading a hydraulically connected air-to-water monobloc would fall under (e) instead, giving 1 January 2030.
The scheme of the annex favours 2027: point (d) covers monoblocs above 12 kW up to and including 50 kW from 1 January 2027 and imposes no "plug-in" condition at all. The narrower reading would give a 10 kW monobloc a 2030 deadline alongside a 15 kW monobloc with a 2027 one. For planning a range, 1 January 2027 is the safer assumption.
Propane (R290) is not an F-gas, because it is not a fluorinated compound. Equipment on R290 is therefore not "below the threshold" - it is outside the scope of these prohibitions altogether. Hence the direction manufacturers' ranges are taking, though a flammable refrigerant brings its own design consequences: requirements on unit siting, safety zones and charge size.
Check intermediate refrigerants separately, and compute rather than trusting sales material. Blends are not in Annex I - the annex lists individual substances, and a blend's GWP is the mass-weighted average of its components' GWPs. R454B is 68.9 per cent R32 and 31.1 per cent R1234yf, so with the value of 675 for R32 the result is roughly 466. The same arithmetic puts R410A at roughly 2088. In a category with a 750 threshold either value is enough; in a category with a 150 threshold neither is. Moving from R32 to an intermediate refrigerant therefore does not rescue a split air-to-water unit up to 12 kW.
The 12 kW boundary and the trap it creates
Placing two rows of the split table side by side gives a result worth seeing together:
The same split, the same refrigerant, two dates
Split, rated capacity 12 kW or less
2025
single split under 3 kg, GWP ≥ 750
2027
air-to-water, GWP ≥ 150
2029
air-to-air, GWP ≥ 150
2035
any F-gas
Split, rated capacity above 12 kW
2029
GWP ≥ 750
2033
GWP ≥ 150
Six years apart - and the only thing separating those two cases is which side of the 12 kW boundary the unit's rated capacity falls on.
It is hard to imagine a stronger hint to reach for a larger machine. It is not worth taking, and the reason should be said plainly. Choosing a unit above 12 kW for a building with a design heat load of 6-8 kW is textbook oversizing: the machine's lower modulation limit sits high relative to the building's demand, so for most of the heating season the pump can only cycle. The client pays for that every month, for the life of the installation, and pays for far longer than the regulatory window that was supposed to justify the choice.
There is a purely formal reason too. The regulation does not define rated capacity - the term is absent from the definitions in Article 3. What assigns equipment to a category is the capacity declared for that equipment, not a number chosen by the designer. The 12 kW boundary in Annex IV is a legal boundary, drawn for product categories. It is not a design quantity and says nothing about how much heat a particular building loses. The only basis for sizing remains the design heat load calculated for that specific building envelope in that specific climate zone.
The safety exemption, and the difference between points 8 and 9
If you ever rely on the safety exemption - and with flammable refrigerants in a plant room that is a real scenario - the two equipment groups have it drafted differently.
- In point 8 the regulation states a fallback value explicitly: where safety requirements at the site do not allow the use of an F-gas with a GWP below 150, the GWP limit is 750. Watch (c), where the trigger differs: there it is about safety requirements not allowing the use of alternatives to F-gases.
- In point 9, covering splits, the provision refers only to an exclusion "if required to meet safety requirements at the site of operation", without stating the 750 fallback.
Two rows in the tables carry no such reservation at all: point 8(a) and point 9(a). When relying on the exemption in a specific project, go to the text of the relevant sub-point rather than a summary of it - all the more so because the same safety exemption returns in Article 13(19) as one of the two grounds for putting equipment into operation.
What this means for sizing
- The up-to-and-including-12 kW class is where the catalogues will change most. It is also the class most correctly sized single-family heat pumps fall into. When a manufacturer withdraws the model you have been proposing, picking a replacement takes fifteen minutes if you have the building's load calculated - and starts from zero if you do not.
- Sizing "with a margin" stops being merely a cost to the client and becomes a sales argument. If someone in the chain proposes a split above 12 kW citing the F-gas dates, the only defence is a number: the building's design heat load, and the unit's output read off its characteristic at design conditions.
- Record the refrigerant in the sizing documentation. Model, refrigerant and its GWP will govern parts availability and what you tell the client a year from now - and today they rarely reach the file.
- Treat the purchase invoice as a technical document. From 2028 it is the evidence that a unit from stock was placed on the market before the deadline, and the operator has to keep it for five years.
What to tell the client
- "I read that I will have to replace my heat pump." The ban covers the sale of new equipment, not your installation. The provision that does mention use expressly excludes equipment placed on the market before the prohibition date.
- "Then why do I need the paperwork?" So the date can be evidenced if anyone asks. Keep the invoice and the equipment record for five years.
- "Let us buy sooner, prices will rise." There is no rush before January 2027, and a unit from stock may be installed later too. Sizing needs a calculation, not a date.
- "My neighbour has a monobloc, that is safer." The refrigerant decides the date, not whether the unit is a monobloc. Monoblocs on an F-gas of GWP 150 or more share the same date.
- "Let us take a bigger one, since bigger ones are allowed for longer." A bigger machine in this building will cycle for most of the season and raise the bill. In any case that difference in dates applies only to splits.
How we handle it in HeatAlgo
The heat load module calculates the design heat load room by room to EN 12831-1:2017, with EN ISO 6946 for building elements and EN ISO 13370 for ground contact. That is the number to have to hand when a conversation turns to the unit's capacity class.
The preliminary heat pump sizing module reads those calculations live, so sizing happens for the same design temperature the building was calculated for. The result is a capacity class that follows from the building - a starting point for choosing a specific unit, including when model availability shifts for regulatory reasons.
If you would rather commission the calculations than do them yourself, we also offer individual heat load calculations. More guides are in the help centre.
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