In October 2023, the Environmental Protection Agency (EPA) finalized new regulations on hydrofluorocarbons (HFCs) as part of the American Innovation and Manufacturing (AIM) Act. This marks a significant shift from proposed guidelines to enforceable regulations that will profoundly impact the refrigeration and HVAC industry. However, there is some confusion about the implications of these new rules. Let’s clarify what these regulations mean for us moving forward.
The EPA’s Final Rule: What’s New?
The EPA’s final rule targets the use of HFCs based on their Global Warming Potential (GWP). The GWP measures how much heat a gas traps in the atmosphere over a specified period, relative to carbon dioxide (CO2). With CO2 assigned a GWP of 1, other gasses are rated based on their potential to contribute to global warming. It is a measure of the energy 1 ton of gas will emit over a given time period compared to one ton of Carbon Dioxide. The GWP values are calculated over 20, 100, or 500 years. The most common, and what the EPA uses, is the 100 year calculation. However, some states, such as New York, are looking at using a 20 year GWP calculation for their regulations.
Here’s a summary of the key regulations for various refrigeration systems. This table highlights the stringent GWP limits set by the EPA and their respective compliance dates.
Source: EPA Final Rule – Phasedown of Hydrofluorcarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing (AIM) Act
Understanding GWP and Its Impact
The focus on GWP is central to these regulations. The table below provides a snapshot of the GWP values for commonly used refrigerants:
Refrigerants like HFC-134a, R-404A, and R-507A, which are prevalent in cold storage and process refrigeration, will no longer be viable options under the new regulations. Instead, the industry will shift towards using CO2 (R-744) and ammonia (R-717) for larger applications. Meanwhile, newer, mildly flammable HFOs may become standard for smaller applications.
How will this be enforced?
Starting January 2026, manufacturers will be prohibited from selling equipment that does not meet the new GWP guidelines. The EPA will enforce this through several measures:
- Prohibiting the manufacture and import of products utilizing higher-GWP HFCs.
- Banning the sale, distribution, and export of non-compliant products three years after the initial prohibition.
- Restricting the installation of new refrigeration systems using higher-GWP HFCs.
These regulations underscore the need for our industry to adapt quickly, embracing new technologies and refrigerants that align with these environmental goals.
Moving Forward
ineAs these regulations come into effect, our focus will be on ensuring that our clients and partners are well-informed and prepared. Transitioning to CO2 and lower-GWP refrigerants will require careful planning and a clear understanding of the options available. Our team and our vendors are here to assist with this transition, offering the expertise needed to navigate these changes successfully.
REFERENCES
1 https://www.epa.gov/system/files/documents/2021-09/hfc-allocation-rule-nprm-fact-sheet-finalrule.pdf
2 https://www.epa.gov/climate-hfcs-reduction/technology-transitions-gwp-reference-table