Renewing HVAC while the building is in use: what changes under the new F-gas Regulation

Many companies have air-conditioning systems running on R-410A that work, but that can no longer be extended with the same gas in the coming years. The F-gas Regulation (EU) 2024/573 has set dates for placing split equipment on the market according to its capacity and the global warming potential (GWP) of the refrigerant. Renewal is not urgent in every case, but it does need to be planned, and almost always with the building in use.

What dates the new Regulation sets

These are the placing-on-the-market bans for split air-conditioning and heat pump equipment affecting offices, shops and commercial buildings:

To put this in context: R-410A has a GWP of 2,088 and R-32 one of 675. A variable refrigerant flow system above 12 kW using R-410A cannot be placed on the market new from 2029, and one using R-32 from 2033.

Maintenance is changing too. Since 2026, air-conditioning and heat pump equipment can no longer be recharged with virgin gas with a GWP of 2,500 or more; reclaimed or recycled gas is permitted until the end of 2031. R-410A and R-32 fall below that threshold, but the phase-down of HFC quotas will mean less gas available at a higher price.

Renewing with the building in use

In an office building or an operating facility, the question is not only which equipment to install, but how to replace it without stopping operations. Before asking for quotes, it is worth having the following resolved:

• What can be reused. Check whether the existing refrigerant lines are suitable for the new refrigerant (diameters, wall thicknesses and condition of the insulation) or whether new lines need to be run.
• Where the routes go. Risers, suspended ceilings and runs across the roof. Good routing limits works in occupied areas to specific days.
• In what order. Floor by floor or zone by zone, with a temporary system if needed, so that each area is out of service for as short a time as possible.
• Where the outdoor units go. Load on the roof, noise towards neighbours, maintenance access and, with mildly flammable refrigerants (A2L), the clearances and ventilation required by the manufacturer and by safety regulations.

Taking the opportunity to sort out ventilation

Replacing the HVAC system is the moment to review outdoor air. The RITE (Spanish Regulation on Thermal Installations in Buildings, RD 1027/2007) sets minimum ventilation rates by use and requires energy recovery from exhaust air depending on the airflow and operating hours (IT 1.2.4.5.2). With properly sized heat recovery units, indoor air quality requirements are met without driving up consumption.

Heat pumps and decarbonisation

Many renewals move from direct expansion systems to air-to-water heat pumps, which keep the refrigerant out of occupied spaces and make it easier to use low-GWP gases. They also help meet the efficiency requirements of the CTE DB-HE (Spanish Building Code, energy efficiency section) and improve the building's energy rating.

How we approach it at ALTERTECNIA

We start with a survey of what is there: equipment, refrigerant, loads, lines and routes. With that, we define the new solution in BIM, coordinate it with the other building services and plan the works in phases so that the building keeps operating. We then handle the legalisation of the installation and carry out site supervision alongside the installation contractor.

If you have equipment running on R-410A or older refrigerants and want to know what affects you and when, tell us about your case.

Sources

• Regulation (EU) 2024/573 on fluorinated greenhouse gases, Annex IV. Technical summaries: Projet Celsius and F-Gas 2024 technical factsheet.
• Maintenance with gases of GWP ≥ 2,500: summary of F-Gas Regulation 2024/573.
• Reglamento de Instalaciones Térmicas en los Edificios (RITE), RD 1027/2007, IT 1.1.4.2 and IT 1.2.4.5.2.