How Regulation (EU) 2024/573 changes wine cellar cooling: the GWP 150 threshold, self-contained equipment, and what to ask refrigeration suppliers.
For most of the last decade a wine cellar specification could describe the cooling duty, the temperature range and the noise target, and leave the refrigerant to the equipment supplier. That is no longer a safe assumption for projects in the European Union. Regulation (EU) 2024/573, which replaced the previous F-gas Regulation, sets equipment-level restrictions that depend on the refrigerant global warming potential, and those restrictions apply to the equipment rather than to the installer.
The practical consequence is that the refrigerant becomes a specification decision. If the cooling unit selected for a cellar falls inside a prohibition, the issue is not how it is installed or maintained but whether it may be placed on the market at all. For a project buyer, that is a question to settle before the equipment is ordered, not after it arrives on site.
This briefing summarises the parts of the Regulation that matter for wine cellar and wine room cooling, using the published text on EUR-Lex. It is written for architects, project managers and buyers, not as legal advice. Project-specific compliance should be confirmed with the equipment supplier and, where needed, with a qualified consultant in the destination member state.
Regulation (EU) 2024/573 of the European Parliament and of the Council of 7 February 2024 is the current EU framework for fluorinated greenhouse gases. It amends Directive (EU) 2019/1937 and repeals Regulation (EU) No 517/2014. It was published in the Official Journal on 20 February 2024 as OJ L, 2024/573, and it entered into force on the twentieth day following publication.
The Regulation works through several mechanisms at once: a phase-down of hydrofluorocarbon supply, restrictions on placing certain products and equipment on the market, requirements for leak checks and record keeping, and certification requirements for the undertakings that handle the equipment. For a wine cellar project, the mechanism that matters most directly is the equipment restriction in Annex IV.
Because the restrictions are written against dates and GWP thresholds rather than against product categories by name, the same cellar design can be compliant or non-compliant depending on which cooling unit is selected. That is why the refrigerant has to appear in the equipment schedule alongside the capacity and the sound pressure level.
Annex IV of the Regulation lists products and equipment that may not be placed on the market above a stated GWP. Item (4) of that Annex covers any self-contained refrigeration equipment, except chillers, that contains fluorinated greenhouse gases with a GWP of 150 or more, and the date of prohibition is 1 January 2025. The item includes an exception where fluorinated greenhouse gases with a lower GWP would not meet safety requirements at the site of operation.
That provision is the one most likely to affect a wine room. A through-wall or under-counter wine cooling unit is typically a complete factory-made assembly in its own casing, with no refrigerant-containing parts connected on site, which is the shape of equipment the Regulation describes as self-contained. Where such a unit is charged with a refrigerant above the threshold, it falls within the scope of the prohibition.
The threshold is a GWP value, not a refrigerant family name. Annex I of the Regulation lists the GWP values used for the substances in scope; HFC-134a, for example, is listed at 1,430, while propane (R-290) is listed at 0.02. A supplier proposing a unit for an EU project should be able to state the refrigerant, its GWP as listed in the Regulation, and whether the unit is self-contained or split.
Chillers sit under item (7) of Annex IV rather than item (4), and their dates are later. For chillers containing, or whose functioning relies upon, fluorinated greenhouse gases with a GWP of 150 or more, the prohibition for units up to and including a rated capacity of 12 kW applies from 1 January 2027. For chillers above 12 kW, the Annex lists a GWP of 750 from the same date.
This matters when a project uses a central chiller serving several rooms or a whole hospitality building rather than a self-contained unit per cellar. The compliance question then depends on the rated capacity and the refrigerant, and the answer can differ between a small chiller and a large one on the same site.
It also means that a design team should not treat the two equipment types as interchangeable for compliance purposes. A self-contained unit and a chiller serving the same cellar have different dates and different thresholds, so the equipment selection changes the compliance path.
The Regulation defines terms precisely, and the definitions decide whether a given unit is in scope. Self-contained equipment is defined as a complete factory-made system in a suitable frame or casing, fabricated and transported complete or in two or more sections, which can contain isolation valves and in which no gas-containing parts are connected on site.
Hermetically sealed equipment is a separate definition. It describes equipment where all parts containing fluorinated greenhouse gas are made tight during the manufacturing process at the manufacturer's premises by welding, brazing or a similar permanent connection, with joints in the sealed system having a tested leakage rate below a stated value under a stated pressure. Capped valves or capped service ports are allowed within that definition.
The two definitions answer different questions. Self-contained describes how the system is assembled and delivered; hermetically sealed describes how the circuit is closed. A unit can be self-contained without being hermetically sealed, and the leak-check and record-keeping obligations that follow can differ accordingly. For specification purposes, both should be recorded for the selected unit.
The Regulation also places obligations on the undertakings that handle the equipment, not only on the equipment itself. It provides that non-hermetically sealed equipment charged with fluorinated greenhouse gases may only be sold to an end user where evidence is provided that the installation is to be carried out by a certified undertaking, and it requires sellers of such equipment to keep records of the equipment sold and of the certified undertakings that will carry out the installation.
For a project in the EU, that means the installation route has to be planned with the equipment purchase. A cellar cooling unit that arrives charged, with a circuit that is not hermetically sealed, needs an installer who holds the relevant certification, and the paperwork trail has to exist before the equipment is handed over. This is a project coordination item, not a detail to resolve on the day of commissioning.
Where the equipment is hermetically sealed and labelled as such, the leak-check regime described in the Regulation is different, subject to the quantity of refrigerant and the location of installation. The supplier should be able to state the charge, the sealing method and the labelling, because those three facts determine which obligations apply after handover.
The following questions turn the Regulation into a specification checklist. What refrigerant is used, and what GWP is listed for it in Annex I? Is the unit self-contained as defined in Article 2, or is it a split system? Is the circuit hermetically sealed at the factory, and is the unit labelled accordingly? What is the refrigerant charge? If the unit is not hermetically sealed, which certified undertaking will install it, and what documentation will be supplied?
Ask for the answers in writing as part of the equipment submittal, and keep them with the project file. A quotation that lists a model number and a cooling capacity but not the refrigerant is not yet a compliant submittal for an EU project, because the compliance question cannot be answered from it.
It is also worth asking whether the supplier offers an alternative refrigerant configuration for the same unit. Where a supplier has both a higher-GWP and a lower-GWP option, the project can choose the configuration that fits the regulatory timetable without changing the physical design of the cellar.
The Regulation sets market restrictions and handling obligations. It does not decide the correct cooling duty for a cellar, the right temperature range for a collection, the acceptable noise level in a dining room or the humidity strategy for the room. Those remain engineering decisions that belong in the project brief and should be resolved on their own merits.
It also does not remove the need for a properly designed envelope. A lower-GWP refrigerant does not compensate for an uninsulated wall, a leaking cellar door or a condenser that cannot reject heat. The refrigerant question sits alongside the envelope and the equipment sizing, not instead of them.
Finally, the Regulation is EU law. Projects in Great Britain, Northern Ireland, the United States, the Middle East and Asia fall under their own regimes, which may set different thresholds and different dates. A specification written for one market should not be assumed to be compliant in another without checking the local requirement.
Primary source: Regulation (EU) 2024/573 of the European Parliament and of the Council of 7 February 2024 on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014, OJ L, 2024/573, 20.2.2024. Retrieved from EUR-Lex on 20 October 2026 at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R0573. Annex IV (products and equipment subject to placing-on-market restrictions) and Annex I (GWP values) were read directly from that text for this briefing.
Reference values quoted in this article: HFC-134a listed in Annex I at a GWP of 1,430; propane (R-290) listed in Annex I at a GWP of 0.02. Article 2 definitions of self-contained and hermetically sealed equipment, and the Annex IV dates of 1 January 2025 and 1 January 2027, are taken from the same published text. No secondary commentary has been used for the regulatory statements in this article.
Does this apply to a wine cellar in a private villa? The placing-on-market restrictions apply to equipment placed on the EU market regardless of whether the cellar is residential or commercial. The handling obligations depend on the equipment and on who installs and maintains it.
Is a split wine cooling system covered by the self-contained restriction? The self-contained restriction in Annex IV item (4) is written for self-contained equipment. A split system is assessed under the provisions that apply to the equipment type and refrigerant, so the supplier should confirm which item applies.
What if the low-GWP alternative cannot meet a safety requirement? Annex IV item (4) contains an exception where fluorinated greenhouse gases with a lower GWP would not meet safety requirements at the site of operation. That exception has to be assessed for the specific site, not assumed.
Do I need to change an existing cellar? The Regulation restricts placing equipment on the market. The obligations for equipment already in service relate to leak checks, record keeping and certified handling, which are separate from the market restriction.
For EU wine cellar projects, the refrigerant is now part of the specification. The self-contained restriction in Annex IV item (4) has applied since 1 January 2025, chillers follow a later timetable under item (7), and the definitions of self-contained and hermetically sealed decide how a given unit is treated. None of that can be answered from a model number alone.
The practical response is straightforward: add the refrigerant and its GWP to the equipment schedule, ask the supplier to state the equipment type and the sealing method in writing, and confirm the installation certification route before the equipment is ordered. ROYAL METAL fabricates the stainless steel cellar and cabinet envelope at its Foshan factory and works with project teams on the equipment coordination that the cellar requires; the regulatory determination for a specific EU project should be confirmed with the equipment supplier and a qualified local consultant.
Item (4) covers any self-contained refrigeration equipment, except chillers, containing fluorinated greenhouse gases with a GWP of 150 or more, with a prohibition date of 1 January 2025 and an exception for site safety requirements.
No. Chillers are covered by item (7), with a prohibition from 1 January 2027 for units up to and including 12 kW at a GWP of 150 or more, and a GWP of 750 for chillers above 12 kW from the same date.
Annex I lists the values applied to the substances in scope. HFC-134a is listed at 1,430 and propane (R-290) at 0.02. Ask the supplier to quote the value as listed in the Regulation.
It is EU law. Great Britain, Northern Ireland, the United States, the Middle East and Asia have their own regimes with their own thresholds and dates, so a specification written for the EU should not be assumed compliant elsewhere.
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