UK & Italy Band Together to Stop R-32 Retrofits

Most everyone knows that over the past few years the European Union has been experiencing a large shortage as well as price hikes on HFC refrigerants such as R-134a, R-404A, and R-410A. While the shortages on R-134a can be traced back to the MAC Directive that took place on 2017, the shortage on R-404A and R-410A comes from the European Union’s F-Gas Regulation that went into effect January 1st, of 2015. This F-Gas regulation aimed at phasing down HFC refrigerants across the EU. It accomplished this by limiting the total amount of HFCs in the marketplace and by also banning these refrigerants from use in new applications.

While the intent of this law was clear the overall transition away from HFCs has been very rough for the EU. Not everyone was ready and not everyone had planned fro these phase downs. The old, ‘I’ll worry about it tomorrow,’ syndrome. These phase downs, as intended, have caused widespread shortages of 404A and 410A throughout the European Union. In fact last summer some countries saw a seven-hundred percent increase in price on 404A. Think about that for a moment folks. If you were buying a jug of 404A at ninety-dollars at the beginning of the season you would end up paying six-hundred and thirty dollars later on that season. Imagine trying to quote that to a customer. Imagine trying to absorb that extra cost. This was not sustainable. Solutions had to be found.

The intended solution here was to use more environmentally friendly refrigerants such as hydrocarbons, HFOs, or more friendly HFC refrigerants. Some of the machines running today can be retrofitted to accept some of these new alternative refrigerants, but not all of them can. Some contractors who are desperate for an alternative when dealing with a 410A unit that needs recharged have turned to using R-32 as a cheaper solution. Here’s the thing folks, these contractors are not retrofitting anything on these existing units. No, they are vacuuming out the remaining old 410A and replacing it all with R-32. They are putting this R-32 as a drop in replacement for 410A.

R-32 & The Retrofits

R-32 is an HFC refrigerant made from Difluromethane. It is being marketed as an alternative to R-410A and R-404A due to their high Global Warming Potential. For those of you who do not know R-32 makes up fifty percent of the R-410A blend that we use so much today. (The other component is R-125.) R-32’s GWP is set at only six-hundred and seventy-five and it has no Ozone depletion risk. When compared to R-410A’s two-thousand and ninety there is a remarkable improvement. The downside of R-32 is that it is classified as lower flammability where as R-410A is not flammable at all. While R-32 systems can and are being used across the world it is very important to note that an existing R-410A system cannot be retrofitted over to accept R-32 refrigerant. As I mentioned previously, there is a large difference between a retrofit and a drop in replacement. With a retrofit the system is brought up to necessary conditions to handle the new refrigerant. With a drop in replacement nothing is done except exchanging the refrigerant.

The contractors out there who are looking for a cheaper solution have been dropping in R-32 in place of R-410A. R-32 has not been approved for a direct retrofit on an R-410A system. Retrofitting a system to another refrigerant that hasn’t been approved is ignoring all of the specifications and components that are on that machine.  Remember that a R-410A unit is designed specifically to take the higher pressures of the 410A refrigerant. Using an unapproved refrigerant in place of 410A can have unintended consequences.

One of these side effects that has already been documented is premature compressor failure. This happens as the R-32 refrigerant operates at a higher discharge than R-410A. In some instances compressors have failed after only a few months of running with R-32. Then before you know it you are back in front of that customer with another expensive bill for them to pay. The other side effect of doing this drop in replacement, and a much more dangerous one, is flammability. R-410A is rated as an ‘1’ in the flammability measurement. This means that there is not a risk for ignition with R-410A. However, the R-32 refrigerant is rated as a ‘2’ on the flammability scale. The ‘2’ means that it has a ‘lower flammability’ rating. So, while it is not rated as a ‘3’ like Propane it is still rated as a flammable refrigerant. The R-410A system does NOT have the proper safety requirements to handle a flammable refrigerant.

The last one of these possible side effects to mention is that if the installer or technician doesn’t label the retrofitted unit as an R-32 unit and there is a leak later on down the road the future technician is going to assume that 410A is in the system. This is as big deal. Because of this assumption the tech isn’t going to take the proper precautions when dealing with a flammable refrigerant. There have been instances where a retrofit had occurred but it was not labeled correctly. This incorrectly labeled unit could directly lead to the deaths of future technicians. In one example two technicians lost their lives four years ago in Australia when attempting to repair a unit that had been retrofitted over to R-290. (Propane.) The Propane ignited due to it not being handled properly. One of these techs were smoking during the repair, which should never be done, but I can only hope that if this unit was labeled properly that this accident could have been avoided. A link to my article on this can be found by clicking here.

This event I mentioned above and the possibility of future events are why countries like the United Kingdom and Italy are now cracking down on unapproved retrofits.

United Kingdom & Italy

The United Kingdom’s Federation of Environmental Trade Associations (FETA) has come out against retrofitting R-410A units over to R-32. They stated a lot of the reasons and logic that I mentioned above. It is not safe. On top of FETA coming out against these retrofits REFCOM has also warned against them. REFCOM is one of the United Kingdom’s leading refrigerant certificate providers. While they do not have the 608/609 sections we have here they have their own certifications that techs have to go through and REFCOM is one of the leading providers. These two prominent names have come out against this dangerous practice and I can only imagine that there will be more to follow from the United Kingdom.

Over in Italy the Italian refrigeration association known as Assofrigoristi has announced that they will pursue fines and even jail time to installers that retrofit existing R-410A applications over to R-32. The jail terms could last up to three months and the proposed fine could be up to 5,200 Euros. (About $6,500 dollars.) All of that is not even counting what could happen if an accident comes from a retrofitted unit that your company changed over. Talk about liability.  Italy is not playing around with this folks.

If this trend continues into the summer season over the European Union then I could definitely see more countries voicing their opinions on the matter and maybe even enacting their own laws similar to what Italy has done.


At best these actions can permanently damage your customers air conditioner as well as void their manufacturer’s warranty. At worst, you could be responsible for injuries or deaths to future technicians who attempt to repair the retrofitted unit. Everyone understands that there is shortage of HFC refrigerants in the European Union but is it worth saving your customer a bit of money? Stick through the hard times of this phase out and know that it is not forever. With each passing year more and more machines will be using the alternative refrigerants. Hopefully, over time the demand of HFCs across the EU will begin to shrink and these crazy prices will begin to drop again.