R-404A, 14 kg, and a Wholesaler Who Still Lists It
A small cold store runs a single-pack freezer on R-404A with a nameplate charge of 14 kg. The evaporator has a pinhole leak, the unit has been topped up three times in two years, and the operator wants you to 'do the same again' before the busy season. The site has no leak detection system fitted and the last documented check was nine months ago. The operator has been quoted by another contractor for a retrofit to R-449A and asks you whether it is worth it, or whether you can just keep topping up with R-404A that a wholesaler still lists as available.
1. The operator asks you to top up the 14 kg charge with virgin R-404A. May you?
Read the worked answer
No. Charge in CO2 equivalent = 14 kg × 3922 (GWP of R-404A) = 54,908 kg CO2e = 54.9 t CO2e.
Since 1 January 2020 the F-Gas Regulation prohibits the use of F-gases with a GWP of 2500 or more to service or maintain refrigeration equipment with a charge of 40 t CO2e or more. R-404A is 3922 and this system is 54.9 t, so the ban applies squarely.
That means:
- No virgin (newly produced) R-404A may be charged into this system.
- Reclaimed or recycled R-404A remains permitted under the exemption that runs to 1 January 2030.
- Or the system is retrofitted to a lower-GWP refrigerant.
The wholesaler listing it is irrelevant - availability is not permission. Separately, the leak must be located and repaired; repeatedly topping up a known leak is not a servicing strategy.
2. Compare staying on reclaimed R-404A with retrofitting to R-449A. Show the CO2e and leak-check consequences.
Read the worked answer
Staying on R-404A (reclaimed):
- 14 kg × 3922 = 54.9 t CO2e → 50–500 t band → leak check every 6 months (12 months only with a leak detection system).
- The 2500+ GWP servicing restriction continues to apply, and the reclaimed-supply exemption expires at the end of 2030.
Retrofit to R-449A (GWP 1397):
- 14 kg × 1397 = 19.6 t CO2e → drops into the 5–50 t band → leak check every 12 months (24 with a leak detection system).
- The servicing ban no longer applies because the GWP is below 2500.
- Annual CO2e held in the system falls by roughly 64 %, which also cuts the HFC quota burden and cost per kilogram.
Practical retrofit points: R-449A is A1 with a glide of about 5 K, so it must be charged as liquid; expect small capacity/efficiency changes and TXV or EEV adjustment; the POE oil is compatible; and the label and records must be updated to the new refrigerant, charge and tCO2e. Third option: R-452A (GWP 2140) gives 30.0 t CO2e - same 12-month band but about 53 % more CO2e than R-449A, so it is the weaker choice here.
3. If the operator chooses the reclaimed R-404A route, what must accompany that refrigerant and what does it mean for records?
Read the worked answer
Reclaimed refrigerant is not a commodity you accept on trust. It must come from a certified reclamation facility and be accompanied by a declaration/certificate of reclamation stating the refrigerant identity, the batch, the quantity and that it meets the required specification (typically an AHRI 700-type analysis).
For your records that means:
- Log the quantity charged, the date, and that the gas was reclaimed, not virgin - this is what demonstrates compliance with the servicing exemption.
- Keep the supplier's declaration with the job file; the operator should also hold a copy.
- Retain for at least 5 years alongside the leak-check and recovery records.
If a supplier cannot produce a reclamation certificate, treat the gas as unknown and do not charge it - an undocumented cylinder is exactly how contaminated or mislabelled refrigerant ends up in a system.