The service call
The annual service contract had been in place for seven years. The same company. The same technician, usually. A half-day visit in February — check the compressor, inspect the seals, top up the refrigerant if needed, sign the certificate. The laboratory had never had a problem with the chamber. The service had always been unremarkable.
February 2025 was no different, on the surface. The technician arrived at eight in the morning. He checked in at reception, collected his badge, and was shown to the chamber room by the facilities coordinator. He had his toolbox. He had his cylinder.
The coordinator left him to it. She had other things to do. The technician had been there before. He knew where everything was.
What the technician had
The cylinder in his van was R-404A. Virgin refrigerant, from stock his company had purchased the previous year. He had used it on dozens of service calls. He had two more cylinders in the van.
R-404A had been the correct refrigerant for this chamber since it was installed, twelve years earlier. The chamber's documentation specified R-404A. The compressor was designed for R-404A. Every service certificate in the laboratory's files listed R-404A as the refrigerant used.
What the technician did not know — or had not registered, or had not acted on — was that since 1 January 2025, the use of virgin R-404A for servicing refrigeration equipment was prohibited across the European Union. Regulation (EU) 2024/573, Article 13(3). The regulation had been published in the Official Journal in February 2024. It had been in force since March 2024. The ban on virgin R-404A for servicing had been effective for thirty-one days when the technician arrived at the laboratory.
He topped up the refrigerant, completed the service record, and left by midday.
What happened next
For several months, nothing happened. The chamber ran normally. The laboratory ran normally. The service certificate was filed. The annual compliance documentation was updated.
The laboratory had a customer in the automotive sector. That customer had recently updated its supplier quality requirements. The update included a clause requiring suppliers to confirm compliance with applicable environmental regulations, including F-Gas. The laboratory received the updated requirements in May and began working through its compliance documentation.
The environmental compliance review was assigned to a member of the quality team. She was thorough. She pulled the service records for all chamber equipment, cross-referenced the refrigerants listed against the current regulatory status, and arrived at the February service certificate.
R-404A. Virgin. GWP 3,922. Serviced 4 February 2025.
She looked up Article 13(3) of Regulation (EU) 2024/573.
When it came to light
The quality team member brought the finding to the laboratory manager. The laboratory manager called the service company.
The conversation was uncomfortable. The service company confirmed that virgin R-404A had been used. They had not been aware that the regulation had changed. Their technicians had not been briefed on the January 2025 service ban. They had stock of virgin R-404A and had continued to use it on service calls through February, March, and into April — when a different customer had raised the same issue and they had finally updated their procedures.
The service company offered to return and replace the refrigerant with reclaimed R-404A at no charge. The offer was accepted. The replacement was completed within two weeks.
But the regulatory violation had occurred. The question now was what to do about it.
The laboratory's legal team advised that the violation was the service company's primary responsibility — they had sourced and used the prohibited refrigerant. The laboratory had a secondary exposure as the operator of the equipment, having failed to verify that the service was conducted with compliant materials. Both parties had obligations under the F-Gas Regulation. Neither had met them in February.
The laboratory notified its customers proactively. Most acknowledged the notification and accepted the explanation. The automotive customer placed the laboratory on a corrective action plan. The corrective action plan required the laboratory to demonstrate updated procurement controls and refrigerant compliance verification procedures within ninety days.
Root cause
The investigation identified two causes, both of which were necessary and neither of which was sufficient alone.
The service company failed to update its procedures before the regulation came into force. Regulation (EU) 2024/573 was published in February 2024 and entered into force in March 2024. The service ban on virgin R-404A was effective from 1 January 2025 — ten months after the regulation entered into force. A service company specialising in refrigeration equipment had ten months to update its procedures, brief its technicians, and adjust its refrigerant stock. This one did not.
The laboratory's service contract did not specify refrigerant compliance requirements. The contract specified the scope of work, the service frequency, and the price. It did not specify that refrigerants used must comply with applicable F-Gas regulation at the time of service. It did not require the service company to confirm the regulatory status of any refrigerant used. The laboratory had relied on the service company's expertise without verifying it.
A service contract for refrigeration equipment in an EU jurisdiction should include a clause requiring the service provider to confirm, in writing, that any refrigerant used complies with applicable F-Gas regulations at the time of service — including that any HFC refrigerant with a GWP ≥ 2,500 used after 1 January 2025 is reclaimed gas certified to EN 13311-2. One sentence in the contract would have made the question explicit. Without it, the question was never asked.
What the regulation says
EU Regulation 2024/573, Article 13(3): from 1 January 2025, the use of fluorinated greenhouse gases with a global warming potential of 2,500 or above for the maintenance or servicing of refrigeration equipment is prohibited.
The key distinctions for operators of climatic and environmental test chambers:
Virgin vs. reclaimed. Virgin R-404A — new gas, never previously used — has been prohibited for servicing since 1 January 2025. Reclaimed R-404A — recovered from existing equipment, processed at a certified facility to EN 13311-2 standards, and re-certified — remains permitted for servicing existing installations until 31 December 2029. The cylinder label must state that the gas is reclaimed. If it does not, it is virgin gas and its use for servicing is a violation.
Servicing vs. operation. The ban applies to the use of R-404A for servicing and maintenance — topping up, replacing leaked gas, or recharging after repairs. It does not require existing equipment using R-404A to be immediately retrofitted. Equipment that operates on its existing R-404A charge, without needing servicing with new refrigerant, continues to operate lawfully. The regulation targets the gas used in the service act, not the gas already in the system.
Operator responsibility. The operator of refrigeration equipment has obligations under the F-Gas Regulation, including ensuring that servicing is conducted by certified personnel using compliant materials. Delegating service to a third party does not transfer the operator's regulatory obligations. If a contractor uses prohibited refrigerant, the operator may share liability.
What changed after
The laboratory updated its service contracts for all refrigeration equipment. The updated contracts included a clause requiring the service provider to confirm, at each service visit, the regulatory status of any refrigerant used and to provide certification documentation for any reclaimed gas.
The laboratory also added a pre-service verification step to its facilities management procedure. Before any service visit involving refrigeration equipment, the facilities coordinator was required to ask the service company to confirm the refrigerant they planned to use and its compliance status. The question was added to the service authorisation form as a mandatory field.
The service company, for its part, briefed all its technicians on the F-Gas Regulation changes, cleared its virgin R-404A stock, and replaced it with certified reclaimed stock. The briefing had taken one hour. The regulatory transition it addressed had been in the public domain for ten months before the incident.
Check your service contract. If it does not specify refrigerant compliance, update it before the next service visit.
Chamber procurement guide →Frequently asked questions
Can a thermal shock chamber be used instead of a cycling chamber for JESD22-A104?
No. JESD22-A104 NOTE 2 explicitly states that air-to-air or liquid-to-liquid thermal shock chambers shall not be substituted for thermal cycling chambers. The ramp rate of the DUT matters for the failure mechanisms A104 targets — too-fast a rate produces unrealistic damage during interconnect testing that does not represent field conditions.
What is the difference between JESD22-A101 and JESD22-A110 (HAST), and are they interchangeable?
Both target moisture ingress failure mechanisms. A101 runs at 85°C/85% RH for 1,000 hours; A110 (HAST) accelerates this with temperature (typically 130°C) and pressure (~2.3 atm), reducing the duration to 96 hours. They are not directly interchangeable for all device types — some qualification frameworks accept HAST as a substitute for 85/85, but this requires documented justification and is not automatic.
Does JESD22-A104 require DUT temperature measurement or just chamber air temperature?
The standard requires that the specimen reach the nominal temperature during each soak period — not just the chamber air. For small packages the difference is negligible. For larger assemblies, boards, or power modules, a thermocouple on the DUT is the only way to demonstrate compliance with this requirement. JEP 140 and JEP 153 provide the measurement methodology.
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