Selecting “SF6-free” medium-voltage switchgear is not a gas substitution exercise: it changes dielectric design, interruption technology, pressure system, environmental obligations, service procedures, footprint and end-of-life evidence. In the EU, the decisive legal event is generally putting equipment into operation, and the dates, GWP thresholds and procurement derogations must be treated as project requirements.
This article reflects Regulation (EU) 2024/573 and its official corrigendum available at 19 August 2026. It covers MV switchgear through 52 kV, but law, competent-authority guidance and project facts must be checked at the decision date. It is engineering guidance, not legal advice.
Executive conclusions
- SF6 combines strong dielectric/arc-quenching performance with chemical stability, but Regulation 2024/573 assigns it a 100-year GWP of 24,300.
- For EU primary and secondary MV distribution switchgear up to and including 24 kV, Article 13(9)(a) prohibits putting equipment using fluorinated greenhouse gases as insulating/breaking medium into operation from 1 January 2026, subject to specified derogations.
- For MV above 24 kV up to and including 52 kV, the corresponding date is 1 January 2030.
- The official 2025 corrigendum changes the HV band in Article 13(9)(c) to more than 52 kV; it does not change the MV limits above.
- “Ordered,” “placed on the market,” “delivered,” “installed” and “put into operation” are not interchangeable legal events.
- Article 13 provides procurement-based and other derogations, but they require evidence; documentation supporting specified derogations must be retained for at least five years.
- Do not call a fluoronitrile or fluoroketone mixture “F-gas-free” merely because it is SF6-free. Check every constituent against the Regulation and calculate mixture GWP as required.
- Vacuum interruption plus air/dry-air/technical-air insulation can avoid fluorinated insulating/breaking media, but suitability still depends on ratings, dimensions, temperature, altitude, lifecycle and test evidence.
- Alternative gas designs need gas-specific safety, handling, by-product, recovery and end-of-life instructions; IEC 62271-4:2022 explicitly includes alternatives to SF6.
- Procurement should evaluate lifetime leakage/recovery, gas availability and training—not only nameplate GWP.
1. Why SF6 was used
- high dielectric strength enables compact clearances and sealed construction;
- good heat transfer and arc-interruption properties in suitable designs;
- stable performance across long service life when gas quality and sealing are maintained;
- reduced sensitivity of internal insulation to ambient contamination;
- mature monitoring, recovery, analysis and service ecosystem.
These advantages do not make SF6 environmentally neutral. Annex I of Regulation (EU) 2024/573 lists a 100-year GWP of 24,300 for SF6. One kilogram released is therefore accounted as 24.3 tonnes CO2-equivalent under that value. The practical control objective is to prevent emissions across manufacture, filling, service, fault response and decommissioning.
2. EU prohibition dates for electrical switchgear
| Equipment under Article 13(9) | Prohibition on putting into operation | Baseline medium requirement |
|---|---|---|
| MV primary/secondary distribution, ≤24 kV | From 1 January 2026 | No fluorinated greenhouse gas in insulating/breaking medium, unless a derogation applies |
| MV primary/secondary distribution, >24 kV to ≤52 kV | From 1 January 2030 | No fluorinated greenhouse gas in insulating/breaking medium, unless a derogation applies |
| HV, >52 kV to ≤145 kV and ≤50 kA | From 1 January 2028 | GWP below 1, unless a derogation applies |
| HV, >145 kV or >50 kA | From 1 January 2032 | GWP below 1, unless a derogation applies |
The >52 kV boundary above incorporates the Official Journal corrigendum dated 24 March 2025. For a 52 kV-rated assembly intended for MV distribution, do not assume the HV wording overrides Article 13(9)(b); obtain legal/authority interpretation for unusual classification cases.
3. The legal event: putting into operation
The prohibition wording is “putting into operation.” Procurement programs must therefore control the planned commissioning/use date, not just purchase or manufacture. The Regulation separately says moving switchgear already operating in the Union to another location within the Union is not putting it into operation for Article 13 purposes. Article 13(14) excludes equipment where the operator can evidence that the order was placed before 11 March 2024.
- record rated voltage and primary/secondary-distribution purpose;
- identify gas/mixture and its role in insulation and/or interruption;
- record order, placing-on-market, delivery, installation and commissioning dates separately;
- obtain the operator/legal entity and Member State competent-authority requirements;
- include extension panels and compatibility with the installed board;
- freeze the compliance pathway before tender award, not at energization.
4. Procurement-based derogation ladder
Article 13(11), as corrected, allows switchgear relying on fluorinated greenhouse gases with GWP below 1,000 when a procurement procedure considering the technical specifics produces insufficient qualifying alternatives:
- for the first two years after the MV dates, no bids or only bids from one manufacturer offer switchgear not using fluorinated greenhouse gases;
- after that two-year period, no bid is received from a manufacturer offering such F-gas-free switchgear;
- the analogous HV test is based on bids for medium with GWP below 1.
Article 13(12) then permits GWP 1,000 or more if the qualifying procurement procedure receives no bid for medium below GWP 1,000. This is an evidence hierarchy, not a blanket commercial exemption. Technical specifications must describe the real application without artificial requirements designed to exclude alternatives.
5. Other Article 13 provisions
- Existing relocation: taking operating equipment out of service and putting it into operation elsewhere within the Union is excluded by paragraph 10.
- Ecodesign lifecycle case: paragraph 13 provides a route only where established under ecodesign requirements adopted under Directive 2009/125/EC; a private lifecycle claim is not automatically this derogation.
- Pre-Regulation order: paragraph 14 covers evidenced orders placed before 11 March 2024.
- Extension compatibility: paragraph 15 addresses devices extending existing switchgear where lower-GWP devices are incompatible and would require replacement of the entire existing switchgear.
- Records: paragraph 16 requires evidence for listed derogations to be kept at least five years and supplied to authorities/Commission on request.
- Notification: the Regulation and Member State implementation can require notification when specified procurement derogations are used; check the competent authority.
6. Classify the alternative accurately
| Design family | Typical interruption | Insulation approach | Regulatory wording to verify |
|---|---|---|---|
| Air-insulated switchgear | Vacuum breaker/contactor | Ambient air plus solid supports | No F-gas medium, subject to all components |
| Sealed dry/technical-air GIS | Vacuum | Pressurized purified air/N2/O2 mixture | Usually presented as F-gas-free; verify actual composition |
| Fluoronitrile mixture | Often vacuum or gas-specific | Fluoronitrile + CO2/O2/N2 blend | SF6-free but contains a listed fluorinated substance; mixture GWP matters |
| Fluoroketone mixture | Technology-specific | Fluoroketone blend | Do not infer legal status from trade name; check Annex/listing and definition |
| Solid-insulated/sealed solid | Vacuum | Epoxy/silicone/thermoplastic plus air interface | No insulating gas may be needed, but material/end-of-life impacts remain |
| SF6 or SF6 mixture | SF6/vacuum depending design | SF6-based | High-GWP F-gas; full Regulation obligations |
Require the chemical name, CAS number where applicable, mass fraction, charge mass and calculated mixture GWP. “Eco,” “clean,” “natural origin,” “low carbon” and “SF6-free” are not sufficient compliance attributes.
7. Engineering comparison: air/dry air
- Advantages: no fluorinated insulating/breaking medium; familiar vacuum interruption; simplified climate accounting; reduced regulatory gas burden.
- Tradeoffs: higher pressure, larger dimensions or field optimization may be required; internal arc pressure and thermal design remain; purity/moisture and leak performance still matter.
- Verify: rated insulation at minimum functional pressure, temperature and altitude; partial-discharge behavior; pressure vessel/enclosure rules; gas replenishment specification; IAC and leakage evidence.
8. Engineering comparison: fluorinated low-GWP mixtures
- Advantages: compact dielectric performance can ease replacement or higher-voltage applications; substantially lower mixture GWP than SF6 may be possible.
- Tradeoffs: still potentially regulated as an F-gas; gas ratio, condensation/boiling behavior and low-temperature limits are mixture-specific; supply/recovery ecosystem may be proprietary.
- Verify: each constituent and current legal status, mixture-GWP calculation, minimum temperature, toxicity/exposure data, decomposition products, gas-analysis method, compatible service cart, recovery/reuse/disposal route and long-term availability.
Regulation 2024/573 Annex I lists heptafluoroisobutyronitrile (fluoronitrile) with a GWP100 of 2,750. A diluted mixture can have a much lower mixture GWP, but that does not make the fluorinated constituent disappear or automatically satisfy the MV “no fluorinated greenhouse gases” baseline.
9. Engineering comparison: solid insulation
- Advantages: eliminates gas handling for encapsulated primary insulation; compact and resistant to ambient contamination.
- Tradeoffs: voids/interfaces and partial discharge are critical; condition assessment and repair can be difficult; material volume, recyclability and separation at end of life require scrutiny.
- Verify: PD/type-test evidence, thermal ageing, surface tracking at exposed interfaces, mechanical/thermal cycling, fire/smoke requirements, replaceability and documented material recovery.
10. Gas is only one part of switchgear performance
- rated voltage, insulation levels and frequency;
- continuous current and temperature rise at service conditions;
- short-time withstand and peak withstand current;
- breaker/load-break switch making, breaking, TRV and electrical endurance;
- earthing-switch making class;
- LSC, partition class, accessibility and IAC under IEC 62271-200;
- pressure/density monitoring, alarms and lockout behavior;
- minimum operating temperature and altitude correction;
- leakage rate, expected service life and sealed-pressure-system evidence;
- maintenance, spares, gas availability and end-of-life plan.
Do not accept “same IEC ratings” without confirming the offered configuration was represented in the relevant type tests. Gas substitution can change internal electric field, pressure rise, thermal transfer and by-products.
11. IEC gas-handling framework
- IEC 62271-4:2022 provides minimum handling procedures for gases used for insulation/switching during installation, commissioning, normal/abnormal operation, repair, overhaul and end of life.
- The 2022 edition adds alternatives to SF6 and uses gas-specific annexes; manufacturer instructions can impose additional requirements.
- IEC 60376:2018 specifies technical-grade SF6 and N2/CF4 complementary gases for electrical equipment.
- IEC 60480:2019 specifies criteria for reuse of recovered/reclaimed SF6 and SF6 mixtures and addresses by-products/health evaluation.
- IEC 62271-1 and the relevant product standard govern common/service/rating/test requirements; IEC 62271-200 applies to the MV assembly.
12. Handling and occupational-safety plan
- gas identity, safety data sheet and cylinder/mixture traceability;
- technician certification/training required by EU/national rules;
- ventilation and oxygen-displacement assessment for rooms/pits;
- gas-specific exposure and decomposition-product controls after an arc/fault;
- PPE, respiratory and contamination controls based on hazard assessment;
- dedicated, compatible evacuation/filling/recovery equipment and fittings;
- moisture, purity, ratio and pressure measurement with calibrated instruments;
- closed-loop recovery and weighing before/after intervention;
- segregated labelled cylinders and prevention of cross-contamination;
- spill/leak/abnormal-pressure response and competent disposal route.
Never use an SF6 service cart for an alternative mixture without explicit equipment/manufacturer compatibility and decontamination rules. Incorrect gas ratio can invalidate insulation capability and compliance.
13. Leak checking, monitoring and records
Article 5 establishes leak-check duties and specific switchgear exclusions. Electrical switchgear is exempt from leak checks if it has a manufacturer-specified tested leakage rate below 0.1% per year and is labelled accordingly, or has pressure/density monitoring with an automatic in-service alert, or contains less than 6 kg of Annex I F-gases. These are conditions in law, not reasons to ignore alarms or emissions.
- asset ID, compartment, gas/mixture and original charge;
- pressure/density corrected for temperature and alarm thresholds;
- quantity added, recovered, recycled/reclaimed and lost;
- leak location, repair, verification and responsible certified undertaking/person;
- cylinder mass and gas-quality analysis;
- automatic-alert functional tests and alarm response;
- CO2-equivalent reporting basis and Regulation version;
- end-of-life recovery certificate and waste/reuse destination.
14. Existing SF6 fleet
The new-equipment dates do not mean an installed SF6 board must automatically be removed. Operate the existing fleet with leak prevention, monitoring, competent handling, inventory, recovery and planned replacement. Article 13(7) prohibits use of SF6 for maintenance or servicing of electrical switchgear from 1 January 2035 unless it is reclaimed or recycled, subject to technical-unavailability/emergency-repair evidence and the stated military exclusion.
- rank leakers by annual mass and CO2-equivalent emissions;
- repair rather than routinely top up without cause;
- secure reclaimed/recycled gas strategy before 2035;
- identify obsolete seals, density monitors and service tooling;
- plan extension compatibility under Article 13(15);
- recover gas during decommissioning—never vent intentionally;
- retain fleet gas bank and cylinder ownership/quality records.
15. Tender specification checklist
- intended country, commissioning date, voltage band and distribution function;
- compliance declaration against Regulation 2024/573 and corrigenda;
- gas constituent, mass, ratio, GWP source/calculation and F-gas status;
- exact IEC 62271 editions and type-test configuration mapping;
- minimum functional/lockout pressure and minimum temperature;
- guaranteed leakage rate, monitoring/alarm and sensor test method;
- internal arc, pressure relief and room interface;
- installation/filling/commissioning scope and certified personnel;
- gas sampling, purity/moisture/ratio acceptance criteria;
- service equipment, fittings, cylinders, training and spares;
- faulted-gas/by-product emergency procedure;
- recovery, reclaim/reuse/disposal and producer take-back;
- procurement-derogation evidence if the baseline is not met;
- lifetime environmental data separated from legal compliance.
16. Evaluation matrix
| Dimension | Evidence, not claim |
|---|---|
| Legal | Constituents, GWP, voltage/application/date, Article 13 route, authority record |
| Electrical | Ratings, test reports, minimum pressure/temperature, offered configuration |
| Safety | SDS, by-products, ventilation, pressure relief, IAC, emergency procedure |
| Reliability | Leak guarantee, monitoring, field population, service response, diagnostics |
| Maintainability | Tools, trained staff, gas supply, parts, sampling/recovery procedures |
| Environment | Charge × GWP, guaranteed leakage, recovery rate, material/energy lifecycle assumptions |
| End of life | Recovery ownership, reusable/reclaimable gas, material separation, take-back |
| Commercial | Footprint/civil impact, auxiliaries, service contracts, regulatory risk and residual value |
17. Common mistakes
- assuming “SF6-free” means “F-gas-free”;
- using equipment delivery instead of putting-into-operation date;
- ignoring the ≤24 kV and >24–≤52 kV date split;
- using pre-corrigendum HV “from 52 kV” wording;
- claiming a procurement derogation without a defensible procedure and bids;
- accepting a trade-name GWP without composition/calculation;
- comparing gas GWP but ignoring charge mass, leakage and recovery;
- reusing service carts/cylinders across incompatible gases;
- assuming sealed equipment needs no alarm response or recordkeeping;
- forgetting the 2035 reclaimed/recycled SF6 service rule;
- treating a private lifecycle study as the Article 13(13) ecodesign route;
- buying a compliant gas technology with unverified IEC ratings/configuration.
Primary references
- Regulation (EU) 2024/573—official text.
- Official corrigendum of 24 March 2025.
- IEC 62271-4:2022—Handling procedures for insulating/switching gases.
- IEC 60376:2018—Technical-grade SF6 and complementary gases.
- IEC 60480:2019—Reuse of SF6 and mixtures.
- IEC 62271-200:2021—MV metal-enclosed switchgear and Amendment 1:2024.
Regulatory note: Confirm consolidated EU text, Member State implementation/notification, competent-authority interpretation and manufacturer instructions at procurement and commissioning. Dates and applicability can turn on facts not captured in a general article.