Refrigerators are already subject to EU ecodesign requirements under Commission Regulation (EU) 2019/2019, which remains in force under ESPR Article 74. The ESPR delegated act will add a Digital Product Passport requirement including refrigerant type, Global Warming Potential (GWP), recycled content, and carbon footprint. Refrigerators using HFC refrigerants face additional scrutiny under both ESPR and the EU F-Gas Regulation.
Truth Anchor: ESPR Article 74: existing ecodesign measures remain in force until replaced by ESPR delegated acts. Commission Regulation (EU) 2019/2019 remains mandatory. — EUR-Lex CELEX:32024R1781
Refrigerant GWP: The Critical ESPR Issue for Refrigerators
The refrigerant used in a refrigerator determines its climate impact beyond energy consumption. The DPP is expected to require disclosure of the refrigerant type and its Global Warming Potential (GWP). This is particularly important for refrigerators using HFC refrigerants, which are being phased down under the EU F-Gas Regulation (EU) 2024/573.
Refrigerant
Type
GWP (100-year)
EU F-Gas Status
ESPR Outlook
R600a (isobutane)
Natural hydrocarbon
3
Not regulated
Favoured — very low GWP
R290 (propane)
Natural hydrocarbon
3
Not regulated
Favoured — very low GWP
R134a
HFC
1,430
Phase-down under F-Gas Regulation
Disfavoured — high GWP
R404A
HFC blend
3,922
Phase-down under F-Gas Regulation
Disfavoured — very high GWP
R32
HFC
675
Phase-down under F-Gas Regulation
Transitional — lower GWP than R134a
Expected DPP Data Fields for Refrigerators
Data Field
Annex III Category
Status
Energy efficiency class (A–G)
Energy performance
Already required (EU energy label)
Annual energy consumption (kWh)
Energy performance
Already required (EU energy label)
Refrigerant type
Substances of concern
New under ESPR delegated act
Refrigerant GWP
Carbon footprint
New under ESPR delegated act
Refrigerant charge (kg)
Substances of concern
New under ESPR delegated act
Recycled steel content
Recycled content
New under ESPR delegated act
Recycled plastic content
Recycled content
New under ESPR delegated act
Lifecycle carbon footprint
Carbon footprint
New under ESPR delegated act
Repairability score
Repairability
New under ESPR delegated act
What Refrigerator Manufacturers Must Do Now
Verify compliance with existing Regulation (EU) 2019/2019: Confirm energy efficiency class, noise disclosure, and spare parts availability meet current requirements.
Audit refrigerant use: Document the refrigerant type, GWP, and charge for all refrigerator models. Plan transition to natural refrigerants (R600a, R290) for models still using HFCs.
Conduct lifecycle carbon footprint assessment: Calculate the carbon footprint including refrigerant GWP contribution over the product lifetime.
Audit recycled content: Determine recycled steel, aluminium, and plastic content. Note that recycled plastics in food contact applications face additional food safety requirements.
Prepare DPP infrastructure: Select a DPP registry service provider and prepare DPP data templates for all refrigerator models.
Refrigerators Under ESPR: The Most Energy-Intensive Household Appliance
Refrigerators are the most energy-intensive household appliance in continuous use — they run 24 hours a day, 365 days a year. The EU has been regulating refrigerator energy efficiency since 1994, and the current Ecodesign Regulation for refrigerators (Regulation (EU) 2019/2019) sets strict minimum energy efficiency requirements. The ESPR refrigerator delegated act will replace this regulation and add the Digital Product Passport requirement, with new data fields for recycled content, carbon footprint, and substances of concern.
Refrigerator DPP: Expected Data Fields
Data Category
Expected Data Fields
Status
Energy performance
Energy efficiency class (A-G), annual energy consumption (kWh)
Existing (EU 2019/2019)
Volume
Total volume (litres), fresh food volume, frozen food volume
The refrigerant used in a refrigerator has a significant impact on its climate footprint. High-GWP refrigerants (such as HFCs) contribute to climate change if they leak. The EU F-Gas Regulation (Regulation (EU) 2024/573) is phasing out high-GWP refrigerants. The ESPR refrigerator DPP will include the refrigerant type and GWP, making it easy for market surveillance authorities to identify products using prohibited refrigerants. Manufacturers using high-GWP refrigerants should plan to transition to low-GWP alternatives (such as R600a, R290, or R744) before the applicable ESPR delegated act enters into force.
Refrigerators Under Existing Ecodesign and Energy Labelling
Household refrigerators and freezers have been subject to EU Ecodesign requirements since 1996, making them one of the longest-regulated product categories in EU history. The current regulation (EU 2019/2019) and Energy Labelling regulation (EU 2019/2016) entered into force in March 2021 and introduced a rescaled Energy Label (A–G, replacing the old A+++ to G scale). The ESPR delegated act for refrigerators will extend these requirements to include Digital Product Passport obligations and will likely introduce enhanced repairability requirements — minimum spare parts availability periods, mandatory publication of repair manuals, and disassembly instructions for end-of-life processing.
Refrigerant Phase-Down and ESPR Refrigerator Compliance
Household refrigerators use refrigerants to transfer heat from the interior to the exterior. The most common refrigerant in modern household refrigerators is R-600a (isobutane), which has a Global Warming Potential (GWP) of 3 — extremely low compared to the HFCs it replaced. Some commercial refrigeration equipment still uses R-134a (GWP 1430) or R-404A (GWP 3922), which are being phased down under the EU F-Gas Regulation (EU 2024/573). The ESPR refrigerator DPP will require manufacturers to declare the refrigerant type, GWP value, and charge quantity in grams. For commercial refrigeration equipment, this data is essential for F-Gas compliance reporting.
Connected Refrigerators and Smart Grid Interaction
Modern premium refrigerators increasingly include WiFi connectivity and smart home integration. The EU's Smart Appliances initiative, developed under the Energy Efficiency Directive and the Electricity Market Regulation, aims to enable smart appliances to respond to grid signals — reducing energy consumption during peak demand periods and increasing consumption during periods of high renewable energy generation. The ESPR delegated act for refrigerators may include requirements for smart readiness — the ability to receive and respond to demand response signals. The Smart Readiness Indicator (SRI) methodology, developed under the Energy Performance of Buildings Directive, provides a framework for assessing smart readiness that could be incorporated into the refrigerator DPP.
Yes. Commission Regulation (EU) 2019/2019 sets minimum energy efficiency requirements for refrigerators. These requirements entered into force on 1 March 2021 and remain in force under ESPR Article 74.
The ESPR delegated act for refrigerators is expected in 2027-2029. From the compliance date, every refrigerator placed on the EU market must have a valid DPP accessible via a QR code.
Commission Regulation (EU) 2019/2019 requires refrigerators to meet minimum energy efficiency requirements. The minimum class on the new A-G scale is E. New models must achieve class D or above to qualify for the EU energy label.
Yes. Refrigerators using HFC refrigerants (R134a, R600a) must disclose the refrigerant type and Global Warming Potential (GWP) in the DPP. The EU F-Gas Regulation is phasing down HFCs. Refrigerators using natural refrigerants (R600a isobutane, R290 propane) have lower GWP and will be favoured under ESPR.
The minimum recycled content requirements for refrigerators have not yet been published. The delegated act is expected to require disclosure of recycled steel, aluminium, and plastic content. Recycled content in refrigerators is currently low due to food safety concerns about recycled plastics in food contact applications.
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
Refrigerators and freezers are subject to ecodesign requirements under EU Regulation 2019/2019 and energy labelling requirements under EU Regulation 2019/2016, both of which took effect on 1 March 2021. These regulations set minimum energy efficiency requirements (expressed as the Energy Efficiency Index, or EEI) and requirements for the availability of spare parts and repair information. The ESPR delegated act for refrigerators will build on these requirements and add DPP data disclosure, carbon footprint transparency, and refrigerant information requirements.
Refrigerators present a unique environmental challenge because they contain refrigerants — substances that can have a significant global warming potential (GWP) if released into the atmosphere. The most common refrigerants in modern household refrigerators are R-600a (isobutane, GWP = 3) and R-134a (GWP = 1,430). The ESPR DPP for refrigerators is expected to include information on the type and quantity of refrigerant used, the GWP of the refrigerant, and instructions for safe handling at end-of-life. This information is critical for waste electrical and electronic equipment (WEEE) treatment facilities, which must recover refrigerants before processing refrigerators.
Frequently Asked Questions
The ESPR delegated act for refrigerators is expected to be adopted in 2025–2026, superseding EU Regulation 2019/2019. Manufacturers should plan for compliance by 2027–2028. The existing regulation remains in force until the ESPR delegated act takes effect.
Yes. The DPP for refrigerators is expected to include the type and quantity of refrigerant, its global warming potential (GWP), and instructions for safe recovery at end-of-life. This information is required by WEEE treatment facilities and is also relevant to F-Gas Regulation compliance.
The F-Gas Regulation (EU 517/2014) restricts the use of high-GWP refrigerants in refrigeration equipment. ESPR does not replace the F-Gas Regulation but complements it by requiring disclosure of refrigerant information in the DPP. Manufacturers must comply with both regulations independently.
The current ecodesign regulation requires 10 years of spare parts availability. Key parts include: door seals, door hinges, thermostats, compressors, condenser fans, evaporator fans, and electronic control boards. The ESPR delegated act is expected to maintain or extend this requirement and require DPP disclosure of spare parts availability.
Yes. Wine coolers and beverage refrigerators fall within the scope of the ESPR delegated act for refrigerators if they are placed on the EU market. The requirements will apply to all household refrigerating appliances within the scope of the delegated act, regardless of the specific application.