Executive summary (what changed in 2024–2026)

• Supply policy: Australia’s HFC import-quota phase-down (2018→2036) keeps pressure on high-GWP refrigerants. Low-GWP options like R290 and CO₂ are the practical path for new plug-in cabinets.
• Safety standards: AS/NZS 60335-2-89:2020 (IEC Ed.3 adoption) enables higher hydrocarbon charges in compliant commercial self-contained cabinets—no longer “150 g only”.
• Energy rules: Refrigerated cabinets are regulated under the GEMS framework; supplying in-scope models that aren’t registered/compliant is unlawful and attracts penalties.
• Operator upside: Many R290 designs cut kWh/day vs legacy R404A/R134a, trimming bills and back-of-house heat. Simple payback often lands in low single digits when replacing the worst old gear.

Why now: HFC phase-down & cabinet energy rules

Australia has run an HFC import-quota system since 2018; quotas reduce in steps to 2036. In parallel, refrigerated display/service cabinets are covered by Minimum Energy Performance Standards (MEPS) and registration under the Energy Rating (GEMS) program. The combination explains why new merchandisers are overwhelmingly R290 or R744 (CO₂).

What R290 is (and isn’t)

R290 = propane (C₃H₈), a hydrocarbon “natural refrigerant”. In Australian references it’s classed A3 (higher flammability, low toxicity) under AS/NZS ISO 817. Federal refrigerant/GWP lists use IPCC AR4 for regulatory baselines—hydrocarbons are shown as “GWP < 5”. Newer science in IPCC AR6 places R290’s GWP₁₀₀ near 0.02 (still “near-zero”).

Good to know: These are factory-charged sealed systems with small charges. You don’t swap cylinders on site; only competent technicians service sealed circuits.

GWP at a glance (mini-table you can show a landlord)

AR4 numbers are shown for regulatory consistency; R290’s AR6 figure is noted in the caption.

How much R290 is allowed? Charge limits explained

From “150 g myth” to higher charges (with conditions)

Commercial self-contained cabinets assessed to AS/NZS 60335-2-89:2020 (IEC Ed.3) can legally hold more than 150 g of A3 refrigerant when the appliance meets specific design and test criteria (enclosure, airflow, ignition-source control, marking, instructions, etc.). You’ll see compliant models with charges up to ~494 g of R290 per circuit. Always confirm on the data plate and in the instruction manual.

Compliance you must tick: GEMS registration & penalties

Refrigerated cabinets are a regulated product under the GEMS Act 2012. In-scope models must be registered and meet Minimum Energy Performance Standards (MEPS) in the current Determination. Supplying non-registered or non-compliant models is unlawful; the GEMS Regulator can suspend/cancel registrations, issue infringement notices and civil penalties, seek injunctions, and publicly name suppliers.

How to self-check a model quickly

1. Ask your supplier for the GEMS registration number and a link to the product fiche/test summary.
2. Confirm the refrigerant and charge on the nameplate match the fiche.
3. Verify electrical approval and hydrocarbon warnings/markings.

Note on “green energy only”: There is no blanket law forcing venues to purchase “green-energy” equipment. The enforceable pieces here are (1) the national HFC phase-down and (2) GEMS MEPS/registration for products like refrigerated cabinets.

Who can work on it: federal vs state licensing

• Commonwealth (ARCtick) licence: refrigerant-handling licences apply to fluorocarbons (CFC/HCFC/HFC). Natural refrigerants such as hydrocarbons are outside that licence—but you must still comply with WHS and competent-person requirements.
• States/territories: some jurisdictions require explicit authorisation for hydrocarbon gas work (example: QLD requires a Gas Work Licence (hydrocarbon refrigerants)). Always check your regulator.

Efficiency & heat load: what operators actually see

Hydrocarbon plug-ins run favourable thermodynamics (high heat-transfer coefficients, lower condensing pressures) and let manufacturers re-optimise compressors, capillary lengths and heat-exchangers. Real-world merchandiser case studies have shown double-digit kWh/day reductions against older R404A/R134a designs (e.g., 12.3 → 9.6 kWh/day on a glass-door merchandiser; later iterations near ~7.5 kWh/day). Your results depend on door discipline, ambient, duty and model.

Back-of-envelope ROI & energy maths

Method: Annual saving ≈ (kWh/day_old − kWh/day_new) × tariff × 365. Simple payback ≈ price difference ÷ annual saving.

Use your tested kWh/day (fiche) and actual tariff. If your site pays $0.25–$0.40/kWh, adjust accordingly. These are illustrative but reproducible.

Myth vs Fact (extended)

• Myth: “R290 is banned.”
  Fact: Permitted when used in equipment designed/tested for hydrocarbons and installed per the standard.
• Myth: “Hydrocarbons always need the same federal licence as HFCs.”
  Fact: ARCTick licences are for fluorocarbons; hydrocarbons sit outside, but state WHS/gas rules still apply.
• Myth: “150 g is the maximum charge.”
  Fact: Under AS/NZS 60335-2-89:2020, compliant commercial self-contained appliances can use higher charges—commonly up to about 494 g—subject to extra design/tests.
• Myth: “Any low-GWP gas is fine to retrofit.”
  Fact: Never substitute refrigerants without a certified path from the manufacturer; unsafe retrofits risk compliance and insurance.
• Myth: “Incentives mean any display fridge will be discounted.”
  Fact: State schemes change often; eligibility is narrow and administered by accredited providers.

Risk register & responsibilities

Buyer’s checklist & procurement spec

Minimums to put in your PO/tender

• Refrigerant: R290; charge per circuit (g) declared on data plate
• Compliance: AS/NZS 60335-2-89:2020; hydrocarbon warnings/markings present
• Energy: model registered under current Refrigerated Cabinets Determination (GEMS); provide fiche/test reference
• Warranty & service: hydrocarbon-competent technicians available; spare-parts lead times
• Documentation: installation clearances, night blinds/door-closer instructions, cleaning schedule

Installation & commissioning playbook

1. Pre-site: confirm footprint, electrical supply, airflow path, and no ignition sources in prohibited zones.
2. Position & level: observe rear/side clearances; ensure casters/feet are locked and levelled.
3. Power-on checks: verify controller settings, door heaters/night mode, and alarms.
4. Temperature validation: product simulators or calibrated probes; record time to pull-down.
5. Handover: train staff on door discipline, blinds, daily wipe/weekly coil-brush; document contact for hydrocarbon-competent service.

Operations, service & end-of-life

Good habits that protect your energy savings

• Keep coils and air paths clean; schedule monthly visual checks.
• Don’t defeat door closers or night blinds.
• Log defrost/temperature alarms; investigate early.

End-of-life

Use a contractor competent in hydrocarbons to recover refrigerant and decommission per environmental and WHS rules. Follow appliance instructions for disposal of hydrocarbon-charged systems.

Incentives snapshot (NSW/VIC)

State energy-savings schemes have, at times, offered incentives for high-efficiency refrigerated cabinets. Programs and eligibility change frequently; some activities (e.g., certain four-sided displays) have been tightened or paused. Check current rules and work with an accredited provider:

• NSW Energy Savings Scheme (ESS) — discounts via Accredited Certificate Providers, not cash grants.
• VIC Victorian Energy Upgrades (VEU) — activity lists and product eligibility are regularly updated.

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