In short and in plain language
A heat pump needs a refrigerant. Stricter rules for new units are coming soon.
From 2027 many small new heat pumps may only use refrigerants that do little harm to the climate. For air conditioners with an indoor and an outdoor part this applies from 2029.
Old systems may keep running. The rules only apply to new units.
From 2028 a new heat pump only gets a grant if it uses a natural refrigerant. Propane is one example.
Check your page about heat pumps. Name the refrigerant and add a date. We help you with this.
Open the heat pump page of a plumbing and heating firm today and you will find units, refrigerants and funding notes from the time the page was written. At the turn of the year the basis for part of that changes: new monoblock heat pumps and air-to-water split systems up to 12 kW rated capacity may no longer contain fluorinated greenhouse gases with a global warming potential (GWP) of 150 or more when they are placed on the market from 1 January 2027 (UBA, TEXTE 74/2026). Air-to-air split units follow in 2029 (UBA, TEXTE 74/2026). And from 1 January 2028 the federal funding programme for efficient buildings only supports heat pumps with natural refrigerants as individual measures (BEG EM). None of these rules shuts down a system that is already running. But any page that shows an R-32 unit as a current offer, mentions a funding bonus the applicable guideline no longer contains, or has no answer to the question about an existing system will turn into wrong information over the coming months. This article sorts the deadlines by unit type, shows which details belong on a heat pump page, and explains how an FAQ can inform customers factually without creating pressure.
Key takeaways
- From 1 January 2027 new monoblock heat pumps and air-to-water split systems up to 12 kW may not contain F-gases with a GWP of 150 or more; for air-to-air split units this applies from 2029 (Annex IV, Regulation (EU) 2024/573).
- The deadlines ban placing new units on the market, not running existing systems. If the indoor or outdoor unit of a split system is replaced, the European Commission regards the result as a new system (UBA).
- From 1 January 2028 the federal programme for efficient buildings only funds heat pumps with natural refrigerants such as R290 propane or R744 carbon dioxide as individual measures (BEG EM).
- For units with a GWP of 150 or more, the refrigerant, charge in kilograms and CO2 equivalent and the GWP also belong in advertising descriptions, so on the product page (Art. 12(16), Regulation (EU) 2024/573).
- The FAQ answers the question about the existing system factually and with a date stamp. What applies to every new unit from 2027 should not appear as a special feature of your own offer (Annex No. 10a UWG).
- In simple split air conditioners, R-32 was used in 100 per cent of new installations in the 2024 reporting year (UBA, TEXTE 74/2026). Air-to-air split units up to 12 kW with a GWP of 150 or more may not be newly placed on the market from 1 January 2029.
The deadlines by unit type
The legal basis is Regulation (EU) 2024/573 on fluorinated greenhouse gases, known as the F-gas Regulation. Its Article 11 prohibits placing the products and equipment listed in Annex IV on the market from the date given there (Art. 11(1), Regulation (EU) 2024/573). For heat pumps and air conditioners, points 8 and 9 of that annex are decisive: point 8 covers self-contained units, meaning monoblock systems, and point 9 covers split systems with separate indoor and outdoor units. The yardstick is the global warming potential of the refrigerant, the GWP, measured relative to carbon dioxide. The table below shows the dates that matter for the service page of a plumbing and heating firm.
| New units (Annex IV, Regulation (EU) 2024/573) | Rated capacity | Banned from | Affects units with |
|---|---|---|---|
| Monoblock heat pump, self-contained | up to 12 kW | 1 January 2027 | F-gases with GWP 150 or more (point 8(b)) |
| Monoblock heat pump, self-contained | up to 12 kW | 1 January 2032 | any F-gas (point 8(c)) |
| Monoblock heat pump, self-contained | over 12 up to 50 kW | 1 January 2027 | F-gases with GWP 150 or more (point 8(d)) |
| Air-to-water split system | up to 12 kW | 1 January 2027 | F-gases with GWP 150 or more (point 9(b)) |
| Air-to-air split system | up to 12 kW | 1 January 2029 | F-gases with GWP 150 or more (point 9(c)) |
| Split system of any type | up to 12 kW | 1 January 2035 | any F-gas (point 9(d)) |
| Split system | over 12 kW | 1 January 2029 | F-gases with GWP 750 or more (point 9(e)) |
| Split system | over 12 kW | 1 January 2033 | F-gases with GWP 150 or more (point 9(f)) |
Each of these rows has an exception: the ban does not apply where the refrigerant is required to meet safety requirements at the site. For self-contained units up to 12 kW the maximum GWP is then 750 (Annex IV point 8(b), Regulation (EU) 2024/573). Requirements an operator sets for itself do not count; the safety requirements must derive from Union law, national law or non-binding rules such as standards (UBA). On a service page the exception is therefore not a sales argument but an individual case that is checked on site.
The 12 kW limit also needs explaining, because the regulation does not define rated capacity. The German Environment Agency takes it to mean the cooling, refrigerating or heating capacity stated by the manufacturer under the standard rating conditions typical for the intended use; for heat pumps this is the rated heat output under the relevant ecodesign regulation (UBA). Anyone naming unit classes on the page should therefore add the rated heat output from the data sheet, not a rounded floor area the unit is supposed to cover.
What the GWP limit means for common refrigerants
The limit of 150 separates the refrigerants found in many units in recent years from those that remain in small monoblock and air-to-water units from 2027. R-32 (difluoromethane, HFC-32) has a GWP of 675 (Annex I, Regulation (EU) 2024/573). The older blend R-410A has 2088 (UBA). Propane, known as refrigerant R-290, has a GWP of 0.02 (Annex VI, Regulation (EU) 2024/573), and carbon dioxide as R-744 a GWP of 1 (European Commission). There are also blends just below the limit, such as R-454C with a GWP of 146 (European Commission). Units like these may still be placed on the market after 1 January 2027, but they contain an F-gas. For monoblock units up to 12 kW that ends on 1 January 2032, for split systems up to 12 kW on 1 January 2035 (Annex IV points 8(c) and 9(d), Regulation (EU) 2024/573). A page that describes an R-454C unit as "future-proof" promises more than the regulation supports.
A working aid, not legal advice
What the deadlines mean for existing systems
Customers ask one question first: what happens to the system that is already running? The answer lies in the definition. Placing on the market includes the first supply or making available to third parties within the Union, whether for payment or free of charge (Art. 3 point 6, Regulation (EU) 2024/573). A heat pump installed a few years ago was placed on the market long ago. The deadlines in Annex IV prohibit placing new units on the market; they do not govern the operation of an installed system. In its recitals the regulation also expressly states the aim that equipment already installed can be repaired and maintained throughout its entire lifespan (recital 18, Regulation (EU) 2024/573).
For repair and servicing, the regulation expressly allows placing on the market parts needed for existing equipment (Art. 11(1), Regulation (EU) 2024/573). The permission only applies as long as the repair or servicing does not result in any of the following:
- a higher capacity of the unit,
- a larger quantity of fluorinated greenhouse gases in the unit, or
- a switch to a refrigerant with a higher global warming potential.
The German Environment Agency draws a line where repair turns into replacement. An outdoor or indoor unit is not a spare part, and if the indoor or outdoor unit of a split system is replaced, the European Commission regards the whole as a new system (UBA). For the website this means: the sentence "your system may keep running" is correct. The sentence "we simply swap the faulty outdoor unit" needs checking case by case once the deadlines have passed.
Topping up follows a separate rule. Since 1 January 2026 it has been prohibited to use fluorinated greenhouse gases with a GWP of 2,500 or more for the maintenance or servicing of air conditioners and heat pumps (Art. 13(4), Regulation (EU) 2024/573). Reclaimed and recycled gases remain permitted for this until 1 January 2032 (Art. 13(4), Regulation (EU) 2024/573). Heat pumps with R-410A are not affected by this ban, because the GWP of this blend is lower at 2088 (UBA). The same applies to R-32 with a GWP of 675 (Annex I, Regulation (EU) 2024/573).
That leaves units already sitting in a stockroom or at the wholesaler. Anything lawfully placed on the market before the deadline may still be supplied afterwards. One year after the relevant date in Annex IV, however, this is only permitted if it is proven that the unit was lawfully placed on the market before that date (Art. 11(1), Regulation (EU) 2024/573). For an air-to-water split heat pump with R-32 that was lawfully placed on the market before 1 January 2027, this means it can be supplied from stock in 2027, and from 2028 only with that proof. A note such as "remaining stock, installation still possible" therefore only belongs on the page if the firm can provide the proof.
Funding: only natural refrigerants from 2028
The second deadline comes from funding. Since 21 July 2026 a new funding guideline has applied to individual measures under the federal programme for efficient buildings (BEG EM). Under the heading refrigerants, its technical minimum requirements recommend heat pumps with natural refrigerants, and from 1 January 2028 only heat pumps with natural refrigerants are funded (BEG EM). As examples of natural refrigerants the guideline lists R290 propane, R600a isobutane, R1270 propene, R717 ammonia, R718 water and R744 carbon dioxide.
For the KfW loan for climate-friendly new builds in the low-price segment (KfW programmes 296 and 498) a rule of this kind applies a year earlier: from 1 January 2027 only heat pumps with a natural refrigerant may be installed in efficiency houses under that guideline (KfW). Anyone advising builders therefore meets the refrigerant question not at commissioning but at the financing stage.
A website that still mentions the efficiency bonus is already out of date. The KfW information sheet on heating funding in its December 2024 version provided an additional bonus of 5 per cent of the eligible total costs for efficient heat pumps (KfW, information sheet 458, version 12/2024), among other cases where a natural refrigerant is used (KfW, information sheet 458, version 12/2024). The information sheet valid since 24 September 2026 makes up the grant only from basic funding, the climate speed bonus and the income bonus (KfW).
For the website this has two consequences. First, the argument shifts: a monoblock heat pump up to 12 kW with R-32 may no longer be newly placed on the market from 2027, and under the guideline a heat pump without a natural refrigerant will no longer be funded from 1 January 2028. Second, funding figures date faster than unit descriptions. The climate speed bonus currently amounts to 16 per cent of the eligible total costs (KfW). It falls for the first time on 1 February 2027 and by 4 percentage points every six months after that (KfW), and it is no longer granted for applications from 1 August 2028 (KfW). The funding rate for heat pumps itself changes as well: under the guideline it falls from 30 per cent (BEG EM) to 15 per cent from the first quarter of 2027 (BEG EM), and a bonus of 15 percentage points is then added if the heat pump originates in the Union (BEG EM). A funding rate without a date is therefore out of date with every reduction. It is better for the funding section to carry the date, the source and a note that the funding body decides on approval and amount.
Where the heat pump page is out of date
In new builds the heat pump has long been the usual heating system: 73.6 per cent of residential buildings completed in Germany in 2025 are heated mainly by a heat pump (Destatis), and for 83.0 per cent of residential buildings approved in 2025 it is planned as the main heating system (Destatis). The market still fluctuates: the number of new installations fell from 438,500 in 2023 to 234,500 in 2024 (UBA, TEXTE 74/2026). For a plumbing and heating firm, the heat pump page is therefore a central page for enquiries, and almost every firm has one: 94 per cent of trade businesses use their own website (Bitkom 2025). Outdated details rarely sit in the main text alone.
Unit lists and product cards
Models with R-32 or R-410A that appear as the current offer. After the deadline they belong in a section for existing systems and service, not in the recommendation.
Refrigerant details
Phrases such as "modern refrigerant" without a designation. They are replaced by the designation and GWP, and for F-gases also by the charge and CO2 equivalent.
Funding section
Bonuses the current guideline no longer mentions and funding rates without a date. The section gets a date stamp, a source and the 2028 deadline for natural refrigerants.
FAQ
Questions about noise and running costs are there, the question about the existing system is missing. It belongs there with a date stamp, as does the question about replacing the outdoor unit.
Air conditioners and air-to-air
Split air conditioners with R-32 as a summer offer. The 2029 deadline applies to air-to-air split units up to 12 kW, and until then they need the F-gas details on the page.
Downloads and profile
Data sheets as PDFs, quote templates and posts in the business profile often carry the same old details. They belong in the same review as the page.
A simple table is enough for the review: every page, every download, every post in the profile, alongside the units and refrigerants mentioned, the funding claims and the date of the last change. Whatever stands out is not deleted but rewritten. A page that is found in searches for a unit type keeps its address and gets today's status. How to split the offer into separate pages per service instead of explaining everything on one combined page is covered in the article Service pages instead of one combined page. And how a plumbing and heating website keeps emergency call-outs, bathrooms and heat pumps apart is explained in Websites for plumbing and heating.
What belongs on the service page for each unit type
Customers rarely ask about the GWP. They ask whether the unit is eligible for funding, whether spare parts will still be available later and whether it suits the house. The service page answers these questions most reliably with fixed details for each unit type that can be checked:
- Design: monoblock or split, air-to-water or air-to-air, installed indoors or outdoors.
- Rated heat output: the value in kW from the data sheet, because the deadlines depend on the 12 kW limit.
- Refrigerant: the designation, such as R290 or R-32, and the GWP; for propane a note that it is a natural refrigerant.
- For F-gases: a note that the unit contains fluorinated greenhouse gases, plus the charge in kilograms and in CO2 equivalent.
- Funding: whether the unit meets the requirements of the current guideline, with a date stamp and a reference to the funding body.
- Servicing: which checks the firm offers, at what interval and who carries them out.
The fourth point is not optional for units with F-gases. The label must state that the unit contains fluorinated greenhouse gases, the designation of the gas, the quantity by weight and in CO2 equivalent and the global warming potential (Art. 12(3), Regulation (EU) 2024/573). For units with a GWP of 150 or more, this information must also be given in descriptions used for advertising (Art. 12(16), Regulation (EU) 2024/573). A product card on the website advertising a split air conditioner with R-32 is usually such a description. A worked example for that line: a unit with 1.2 kilograms of R-32 contains 0.81 tonnes of CO2 equivalent, because a tonne of CO2 equivalent is the mass in tonnes multiplied by the GWP (Art. 3 point 3, Regulation (EU) 2024/573), here 0.0012 times 675. The charge is shown on the rating plate and in the manufacturer's data sheet.
Competition law helps with the wording. Generic environmental claims such as "eco-friendly" or "climate-friendly" are not permitted towards consumers if the firm cannot demonstrate recognised excellent environmental performance (Annex No. 4a UWG); more on this in the article Eco claims on tradesperson websites. A specific statement such as "refrigerant R290 (propane), GWP 0.02" (Annex VI, Regulation (EU) 2024/573) can be checked instead. And what applies to every new unit in a category from 2027 must not appear as a special feature of your own offer: the German Unfair Competition Act prohibits presenting legal requirements that apply to all products in a category on the Union market as a distinctive feature of the offer (Annex No. 10a UWG). The sentence "our monoblock heat pumps comply with the new F-gas Regulation" is therefore more of a risk than an argument. What holds up is what the firm actually does differently: advice on where to place the unit, experience with propane units, the servicing offer.
Sample text for the refrigerant section
The FAQ: factual rather than alarmed
The deadlines bring questions, and the heat pump page is where they are answered before they reach the phone. The tone plays its part. An FAQ that says "buy now while you still can" reads as sales pressure, and a deadline that sounds like a threat creates mistrust instead of enquiries. Each answer works better with one sentence on the legal position, one on what it means for the customer and the date stamp. How to rework such sentences when the law changes is shown in the article on the new heating law. Four questions that belong on a heat pump page, with answers of the length an FAQ can carry:
- May my system keep running? Yes. The deadlines of the F-gas Regulation prohibit placing new units on the market; they do not govern the operation of an installed system, and repair and maintenance are meant to remain possible throughout its lifespan (recital 18, Regulation (EU) 2024/573). Since 2026, a top-up ban has applied to refrigerants with a GWP of 2,500 or more (Art. 13(4), Regulation (EU) 2024/573).
- Do I have to replace my R-32 heat pump? No. The deadlines do not create any duty to replace it, and the top-up ban does not apply to R-32 with a GWP of 675 (Annex I, Regulation (EU) 2024/573).
- What happens if the outdoor unit fails? Repairs with spare parts are permitted as long as capacity, charge and global warming potential do not increase. If the outdoor or indoor unit of a split system is replaced, this counts as a new system (UBA).
- Can I still get funding for an R-32 unit? Under the current guideline, only heat pumps with natural refrigerants are funded from 1 January 2028 (BEG EM). What applies until then we check with you against the funding body's current documents.
The answers stay short and refer to a conversation for the details. An FAQ is not legal advice and should not promise to be; a sentence such as "we will see whether your system is affected at the service visit" takes the question where it belongs. Firms that offer maintenance contracts link the FAQ to the maintenance page, as described in the article Maintenance contracts on the service page. That way the question about the old system becomes a reason for an appointment rather than a scare.
Air conditioners and air-to-air heat pumps: 2029 in view
Firms that offer split air conditioners alongside heating heat pumps, units that heat as air-to-air heat pumps in winter, face a clear starting point. R-32 was first introduced in simple split units in 2015, and its use has since expanded to 100 per cent of all new installations in the 2024 reporting year (UBA, TEXTE 74/2026). The refrigerant stock of portable small units and simple split units in Germany was three times as high in 2024 as in 2004 (UBA, TEXTE 74/2026). From 1 January 2029, air-to-air split systems up to 12 kW with a GWP of 150 or more may no longer be placed on the market (European Commission).
That does not mean there is nothing to do until then. An air conditioning offer that shows R-32 units today already needs the F-gas details from Article 12, and it needs a review date before the deadline. There are alternatives in the split segment too: single-split heat pumps with propane up to about 6 kW rated capacity are already being shown at trade fairs (UBA, TEXTE 74/2026). Whether and when a firm offers such units is its decision; the page should simply not give the impression that today's range will remain available unchanged for years.
For sales to private customers there is also a rule that should be visible on the website. Equipment that is not hermetically sealed and is charged with fluorinated greenhouse gases may only be sold to end users if evidence is provided that the installation will be carried out by an undertaking certified under Article 10 (Art. 11(7), Regulation (EU) 2024/573). A split air conditioner therefore appears on the page as an offer including installation, not as goods without fitting. Certification under Article 10 covers relevant alternatives to fluorinated greenhouse gases, including natural refrigerants where applicable (Art. 10(1), Regulation (EU) 2024/573); firms that install propane units can name their fitters' qualification on the page.
The revision in six steps
- Record what exists: every page, PDF, quote template and post in the business profile that mentions units, refrigerants or funding.
- Check the unit list: for each model, enter design, rated heat output, refrigerant and GWP from the data sheet and assign the deadline from Annex IV.
- Write texts per unit type: monoblock, air-to-water split and air-to-air split separately, with specific details instead of generic environmental claims.
- Add F-gas details: for units with a GWP of 150 or more, add charge, CO2 equivalent and global warming potential to the product description.
- Rewrite the FAQ and funding section: existing system, repair, replacing the outdoor unit and funding, each with a date stamp and source.
- Set review dates: first quarter of 2027 (funding rate for heat pumps), 1 February 2027 (climate speed bonus), 1 January 2028 (funding only with natural refrigerants), 1 January 2029 (air-to-air split), 1 January 2032 and 1 January 2035 (all F-gases in small monoblock and split units).
The first two steps lie with the firm, because only the firm knows which units it actually installs and which it is dropping from its range. Texts, FAQ and technical implementation are handled by the agency. The structure follows the principle that also applies to a trade website relaunch: addresses stay, content is renewed, and every page that search engines find keeps its place. The review dates belong in the firm's calendar and, if a maintenance plan is agreed, in the agency's calendar as well.
What the revision costs
Revising the heat pump page is possible as part of website maintenance. It starts at 49 euros per month net, can be cancelled monthly and has no minimum term; small text and image changes are included, and the effort for a larger review depends on the number of pages and downloads. If the page is so old that a revision is no longer worthwhile, we replace it with a relaunch at a fixed price from 2,900 euros net; old addresses are redirected, and the scope, such as separate pages per unit type, is agreed before the quote. Firms without a website of their own start at a fixed price from 1,490 euros net. Hosting in Germany costs from 15 euros per month net, also cancellable monthly. All prices, as of September 2026, are on the pricing page. How a plumbing and heating website is structured overall is shown on the page Web design for plumbing and heating.
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