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1. Understanding the Regulatory Timeline
The regulation distinguishes clearly between existing systems and new products—a distinction often misunderstood in the industry.
Existing Systems
Existing heat pump installations may continue to be operated, repaired, and maintained according to current standards. The regulation does not mandate decommissioning of existing R32, R410A, R407C, or R134a systems. However, installers should note that higher-GWP refrigerants will likely become scarcer and more expensive due to the ongoing phase-down.
New Products: Critical Deadlines
Deadline Requirement
January 1, 2027 No marketing of monoblock heat pumps (up to 50 kW) with GWP > 150; No marketing of split heat pumps (up to 12 kW) with GWP > 150
January 1, 2029 Split heat pumps up to 12 kW: all F-gases banned (except safety exceptions)
January 1, 2030 GWP > 150 banned across all heat pump categories
Key implication: From 2027, R32 (GWP 675) will be effectively phased out for most residential heat pump applications, making R290 (GWP ~3) the dominant solution.
The Safety Exception
An explicit exception exists under Annex IV: if safety requirements at the installation site prevent the use of low-GWP refrigerants (A3 flammability class), higher GWP values up to 750 remain permissible. This is particularly relevant for indoor installations of brine and groundwater heat pumps where R290's flammability presents implementation challenges.
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2. Why R290? Thermodynamic and Regulatory Advantages
R290 offers compelling advantages that make it the refrigerant of choice for future-proof installations:
Regulatory Benefits
· GWP of approximately 3—well below the <150 threshold
· Not subject to F-gas phase-down quotas—no quota risk, no refrigerant price spikes
· PFAS-free—aligned with emerging environmental regulations
Performance Advantages
· Excellent thermodynamic properties—delivers high efficiencies, particularly with large surface evaporators
· High flow temperatures—can achieve up to 70°C, suitable for existing radiator systems
· High real-world SCOP—hydronic systems using R290 achieve excellent seasonal efficiency
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3. Safety Considerations for A3 Refrigerants
R290 is classified as A3—highly flammable. This requires fundamental changes to installation practices. Safety is no longer a "good practice" recommendation but a design-critical requirement.
Pre-Installation Safety Checklist
Before commencing work on any R290 unit, installers must verify:
· Work permit obtained if required by site protocols
· All personnel trained for flammable refrigerant work and wearing appropriate PPE
· Work zone cordoned off with CAUTION signs installed
· All ignition sources removed—power tools, computers, mobile phones, and any spark-producing equipment must be cleared from the work area
· Static discharge prevention—grounding equipment, anti-static clothing, ESD safety shoes
· ATEX-certified tools (explosion-proof) available
· R290-calibrated gas leak detector—tested, calibrated, and with appropriate alarm thresholds
· Sufficient ventilation—portable explosion-proof ventilation units
· Fire extinguisher—ABC dry powder or CO₂, minimum 2 kg, readily accessible
Personal Protective Equipment
Installers must wear:
· Protective clothing against heat exposure and cold from liquified gas
· Anti-static work shoes (ESD safety shoes)
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4. Installation Clearance Requirements
The European ATEX directive and national practical guidelines (e.g., Dutch NPR 7910-1) traditionally require a 1-meter safety zone around outdoor units, with no building openings (windows, doors, ventilation) or ignition sources permitted within this zone.
Emerging Solutions for Clearance Challenges
Manufacturer innovations are addressing these constraints:
· Vaillant's Flexible Space Functionality (available Q2 2026): Allows closer placement to windows, doors, and basement openings. The SafeGuard functionality enables completely free placement with no additional ventilation systems or safety zones.
· Indoor R290 heat pumps: Products like the Inova by Pipelife (3.2kW capacity, 75°C flow temperature) are designed for fully indoor installation within apartments, with no outdoor unit required. Connects via ducting up to 10m from external walls without performance reduction.
· Hydronic separation: Systems like OCHSNER's AIR EAGLE keep the entire R290 refrigerant circuit sealed in the outdoor unit, with only water-carrying lines entering the building—eliminating risk of R290 entering habitable spaces.
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5. Certification and Training Requirements
F-Gas Certification Is No Longer Sufficient
R290 is not a fluorinated gas, meaning traditional F-Gas certification alone does not cover its handling. Installers require additional qualifications covering A3 flammable refrigerants.
Daikin's Stand By Me – Certified Partner Program
As of February 2025, Daikin has established a Europe-wide certification program for R290 heat pump installers:
Three training levels (L1, L2, L3) :
· Level 1 (General Installer): Essential skills for installation and commissioning of Daikin Altherma 4 R-290 heat pumps—F-gas certification not required
· Level 2 and 3 (SBM Certified Partner): Full lifecycle certification—installation, commissioning, repair, and maintenance—requires F-gas license completion
Training network: 116 training centres across Europe, with over 3,400 HVAC-R partners in Central Europe alone.
Recertification
Existing certifications will likely have expiry dates, requiring periodic recertification. Industry projects like SKILLSAFE EU are harmonising new safety training standards across member states.
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6. Leak Detection and System Checks
The new regulation introduces specific leak check requirements:
Key Changes
· Mandatory leak check within 1 month after repair, but must be performed after a minimum of 24 hours operating time (previously could be done same day)
· Leak detection systems required for equipment containing 5t CO₂ equivalent of HFCs or 1kg of HFOs
· Operators and manufacturers are now obligated to perform leak checks (previously only operators)
For R290 Systems
· Use electronic leak detectors specifically calibrated for R290/propane
· Personal gas monitoring systems should be placed at floor level near the unit
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7. Practical Installation Considerations
System Types and Typical Applications
Monoblock Systems:
· Entire refrigerant circuit contained in outdoor unit
· Only water pipes enter the building—no refrigerant indoors
· Preferred for hydronic heating applications
Split Systems:
· Refrigerant lines run between indoor and outdoor units
· More challenging for R290 due to potential leak paths into occupied spaces
· Limited to 12kW until 2029, then banned for F-gases
Site Assessment Protocol
1. Heating load determination—verify radiators are suitably dimensioned; heat pumps should be designed for maximum 55°C flow temperature where possible
2. Installation location assessment—check clearances to openings and ignition sources
3. Risk assessment—document site-specific safety measures
4. End-user notification—inform property owners about safety responsibilities
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8. Market Developments
Product Innovations
· Pipelife Inova: 3.2kW fully indoor R290 heat pump for apartments, 75°C flow temperature, 800×800mm footprint
· Systemair Geniox HP DFN: R290 air handling unit with integrated heat pump, plug-and-play installation, for commercial buildings
· Daikin Altherma 4 R-290: Full product range with dedicated installer certification program
Market Trends
· Manufacturers increasingly offering R290 solutions for both residential and commercial applications
· Direct-from-manufacturer trade models emerging (e.g., Karnot UK) with higher installer margins
· R290 systems enabling reversible operation for both heating and cooling
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9. Summary Checklist for Installers
□ Obtain A2/A3 certification for flammable refrigerants
□ Verify regulatory deadlines for your market and system types
□ Follow manufacturer clearance specifications carefully
□ Use ATEX-certified tools and R290-calibrated leak detectors
□ Conduct site risk assessment and document all findings
□ Install fixed leak detection where required
□ Inform end-users of safety obligations and maintenance requirements
□ Perform leak checks after 24 hours runtime following repairs
□ Maintain detailed logs of charge amounts and service history
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References
1. Engineers Ireland. "Inova: A heat pump designed for the way Irish apartments are built." (2026)
2. OCHSNER Wärmepumpen. "The OCHSNER Refrigerant Dual Strategy."
3. VSK. "Installation of Vaillant propane heat pumps much more flexible due to new security system." (2025)
4. Daikin Central Europe. "Stand By Me – Certified Partner program." (2025)
5. RefIndustry. "Systemair introduces R290 air handling unit for EU F-gas rules." (2026)
6. Dimplex. "Project Planning Handbook." (2024)
7. ES M100L ST Installation Manual. "R290 Refrigerant Safety." (2026)
8. Daikin Romania. "Programul Stand By Me Certified Partner." (2025)
9. Karnot Energy Solutions. "R290 Heat Pumps for MCS." (2026)
10. AREA. "Guide to F-gas Regulation 2024." (2024)
11. Daikin Altherma 4 Installer's Reference Manual. "Safety Checklist Before Work On R290 Units." (2025)