EU F-Gas Switchgear Procurement in 2026: Rated Voltage and Evidence Scope

1. Start with the rated equipment and operation date

For EU procurement in 2026, ask whether the equipment is primary or secondary distribution switchgear rated up to and including 24 kV and when it will be put into operation. Article 13(9) of Regulation (EU) 2024/573 establishes the relevant starting date of 1 January 2026, subject to its derogations. The Commission FAQ v3 uses rated voltage, not merely nominal network voltage.

A 20 kV network description is therefore insufficient: the selected gear's rating is required. The rule is not a blanket ban on every installed SF6 device. Procurement, commissioning and asset maintenance must be classified separately. The evidence reviewed here was retrieved on 6 October 2026; this is a purchasing guide, not a declaration that any particular project is compliant.

2. Inspect the actual insulating and breaking medium

“SF6-free” does not necessarily mean “F-gas-free”. Request chemical identities and mixture composition for every insulating and breaking compartment, plus the manufacturer's declared GWP basis and applicable documentation. A vacuum interrupter can still be housed in equipment using a fluorinated insulating gas. Product branding cannot settle the scope.

An original RFQ should specify the required functional duty: rated voltage and current, short-circuit performance, interfaces, dimensions, environmental conditions and protection/control needs. Keep necessary technical requirements distinct from preferences for one familiar product. Overly narrow specifications can obscure whether an alternative actually meets the project's use, and weaken the procurement evidence.

3. Illustrative procurement decision

Consider a hypothetical industrial site on a 20 kV network procuring gear rated 24 kV for operation in 2026. Two distributor offers both use equipment from the same compliant manufacturer. They are not automatically two eligible manufacturers. During the relevant first two-year period, Article 13(11) treats bids from only one manufacturer differently from broad competition and can support its GWP below 1000 route when the stated procurement conditions are met.

That does not immediately permit SF6. Article 13(12) requires the separate absence of a bid for the GWP below 1000 technology in a procurement considering the specific technical requirements. Record tender scope, bids, manufacturer identities and technical evaluation. The example illustrates a question to resolve, not a finding of entitlement or an invented authority approval.

4. Keep the legal categories separate

The threshold is not a reason to arbitrarily overrate equipment to avoid review. Engineering selection must remain defensible. A repair part is not an unexamined new installation; an extension needs its own evidence concerning compatibility. An installed asset may remain subject to containment, recovery and servicing obligations even when a new-equipment prohibition is inapplicable.

5. Document the correct derogation

The regulation also addresses relocation of operating equipment within the EU and orders placed before 11 March 2024. These are specific fact patterns, not reusable supplier slogans. The procurement route distinguishes the first two-year one-manufacturer situation from the later no-bid situation and then distinguishes absence of compliant alternatives from absence of GWP below 1000 alternatives.

For the relevant derogations, Article 13(16) requires evidence retained for at least 5 years; Article 13(17) requires notification for the listed procurement, prior-order and extension cases. Assign the operator's responsibility explicitly. A supplier letter can be an input, but the operator needs the complete basis and its authority-notification record. Repair conditions prohibit the specified increase in GWP through gas-type change or in gas amount.

6. Freeze a reviewable purchase record

Create a decision record with rated equipment, location, intended operation date, gas identity, functional requirements, tender evaluation and chosen legal route. Link drawings and bid revisions so a substituted product triggers renewed review. The Commission implementation listing checked on 6 October 2026 identifies adopted measures separately from the simplification proposal; do not treat a proposal as an amendment. The FAQ states the ecodesign-based route lacks the necessary methodology.

Connect the AIS/GIS selection review and RMU interface guide to real electrical and spatial requirements. Preserve this technical record alongside legal evidence. The regulation has legal force; the Commission FAQ supports interpretation and does not replace it.

7. Scope FAQs

Is SF6 banned everywhere in 2026? No. Equipment class, rating, action and applicable derogations matter.

Does an SF6-free label resolve the purchase? No. Another F-gas may be present; obtain actual medium identity.

Do two resellers establish two manufacturers? Not when both bids offer the same manufacturer's equipment; assess the documented tender outcome.

8. References

• Regulation (EU) 2024/573, Article 13
• European Commission switchgear FAQ v3, 19 November 2025
• European Commission F-gas implementation listing