Legal Fact-Check, Regulatory Gray Areas, and the Propane-Based Future of a Success Story
European climate policy is driving the phased rollout of fluorinated greenhouse gases (F-gases) to drastically reduce global greenhouse gas emissions. The legal basis for this is Regulation (EU) 2024/573 of the European Parliament and of the Council of February 7, 2024, on fluorinated greenhouse gases, which replaced the previous Regulation (EU) No 517/2014.
A central criterion for the approval of refrigeration and air conditioning systems is the Global Warming Potential (GWP). The safety refrigerant R32 (difluoromethane) used in the Midea PortaSplit has a GWP value of 675. Under the tightened limits of the new F-gas Regulation, the remaining timeline for this refrigerant to be used in new equipment is highly restricted.
1. The Legal Foundations in Detail
A closer look at the legislative text reveals that the deadlines are strictly tied to the system architecture of the devices.
Excerpt from Annex IV (Placing on the market prohibitions referred to in Article 11(1)) of Regulation (EU) 2024/573:
Point 5: “Self-contained air-conditioning equipment and heat pumps […] containing fluorinated greenhouse gases with a GWP of 150 or more […] Prohibition date: 1 January 2027.”
Point 7: “Air-to-air split systems […] containing fluorinated greenhouse gases with a GWP of 150 or more […] Prohibition date: 1 January 2029.”
(Source: Official Journal of the European Union, L series, Regulation (EU) 2024/573, Annex IV)
2. The Regulatory Special Status of the Midea PortaSplit: 2027 or 2029?
In practice, classifying the Midea PortaSplit raises complex legal questions. The legislator draws a strict distinction between “self-contained” systems (monoblocs) and “split systems.”
The PortaSplit occupies a technological hybrid position here: it consists of an indoor and an outdoor unit (classic split architecture), but is hermetically sealed at the factory and cannot be mechanically separated. This means that the refrigerant circuit remains permanently closed, and no intervention by a certified refrigeration technician is required during installation.
- Scenario A (Air-to-air split system): If the PortaSplit is evaluated purely on its two-part design, the R32 ban will not apply until January 1, 2029 (Annex IV, Point 7).
- Scenario B (Self-contained system): If it is classified as a portable, self-contained unit due to its factory-sealed, non-separable lines, the cutoff date shifts forward to January 1, 2027 (Annex IV, Point 5).
In Switzerland, the rules are tightened further via the national Chemical Risk Reduction Ordinance (ChemRRV). Here, a strict import ban applies to importers and distributors for such systems starting January 1, 2027, followed by a final retail sales ban from June 30, 2027.
3. What Does the Ban Mean for Buyers and Owners of the PortaSplit?
For consumers who already own a Midea PortaSplit or purchase one before the respective deadlines, there is absolutely no reason to worry. Regulation (EU) 2024/573 exclusively regulates the “placing on the market”—meaning the initial import and first sale within the European market.
- Unlimited Grandfathering Protection: Devices that have already been installed or are already in the retail pipeline enjoy full grandfathering protection. They can continue to be operated, resold privately, and used indefinitely.
- Maintenance and Repair: According to Article 13 of the Regulation, the use of refrigerants for the maintenance and repair of existing air conditioning systems in this capacity class remains fully permissible. However, since the PortaSplit does not feature standard Schrader service valves from the factory, any repair in the event of refrigerant loss (error code EL 0C) remains primarily a technical and economic hurdle rather than a regulatory one.
4. The Crux of the Successor: The Propane Challenge (R290)
Propane (R290) is considered a future-proof, environmentally friendly alternative to synthetic F-gases. With an extremely low GWP value of 0.02, it is immune to future restrictions under the F-gas Regulation. However, converting the PortaSplit to R290 presents Midea with a massive engineering hurdle rooted in the device’s unique architecture.
The Safety Risk: A Highly Explosive Gas at the Window
While the current refrigerant R32 is classified under safety class A2L (mildly flammable), propane belongs to class A3 (highly flammable and explosive).
In the Midea PortaSplit, the heavy rotary compressor is located in the indoor unit. This means that the liquid and gaseous refrigerant is continuously pumped through the 2-meter hose bundle that leads outside through open windows or balcony doors. This poses a constant risk of mechanical damage—such as getting pinched in the window frame by accident, pets chewing it, or a window slamming shut. If propane leaks indoors as a result of such damage, a flammable atmosphere can rapidly form in the room.
What an R290 Successor to the PortaSplit Would Have to Look Like
To bring an R290-based successor to market in compliance with harmonized safety standards (DIN EN 378 and IEC 60335-2-40), Midea would have to completely reinvent the device:
- Strict Charge Limit: The mass of propane refrigerant in the system would need to be drastically minimized to prevent reaching explosive limits in the room in the event of a leak.
- Encapsulated Electronics in the Indoor Unit: Since the compressor—and thus the main refrigerant lines—are located indoors, all switching relays, circuit boards, and the control system in the indoor unit must be designed as spark-free components (solid-state relays).
- Sensor Monitoring: An R290 successor would absolutely require permanent, highly sensitive leak sensors. If they trip, the system must be immediately de-energized, and emergency forced ventilation via the fan impellers must be initiated.
5. Conclusion: Should You Still Buy the R32 Version Now?
The upcoming ban on refrigerants with a GWP $\ge 150$ seals the medium-term end of the current Midea PortaSplit with R32 charging in the European market.
For end users, this means that anyone thinking about getting the PortaSplit can still do so without any hesitation, thanks to comprehensive legal grandfathering protection. Waiting for a propane successor model might even turn out to be a disadvantage: due to the mandatory explosion protection and encapsulation measures required for R290, future generations of mobile split air conditioners will become technologically far more complex, heavier, bulkier, and likely noticeably more expensive to purchase.