In early October, Michael Regan, Administrator for the US Environmental Protection Agency signed the agency’s final rule, titled “Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under the American Innovation and Manufacturing Act of 2020.” The rule focuses primarily on the technology transition-related objectives of the AIM Act.
Using portions of the unofficial published rule[1], this article aims to provide an overview of this rule, the refrigerants affected, and implementation deadlines. We’ll also offer our take on what the rule means for industries in our orbit.
The most noteworthy element of this final rule relates to a significant addition to the EPA’s authority. As we’ve covered in previous articles, the American Innovation in Manufacturing (AIM) Act of 2020 granted EPA authority to regulate hydrofluorocarbon refrigerants. October’s final rule on HFC restrictions is in keeping with the AIM Act's goal of a 40% HFC reduction by 2024 and 80% by 2036. This latest rule outlines equipment and system-specific phasedown requirements for new products in several HVAC-R applications and adjacent industries.
In general, the relevant provisions contained in the AIM Act seek to lessen the manufacturing sector’s environmental impact through incentive-based and compulsory measures, the latter of which describes the final rule in question. According to the rule’s executive summary, its goals for addressing HFCs are threefold:
The EPA notes that the final rule, “Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under the American Innovation and Manufacturing Act of 2020” focuses on the third item above, specifically “facilitating the transition to next-generation technologies by restricting use of HFCs in the sectors or subsectors in which they are used.” Starting as soon as January 1, 2025, restrictions will take effect on the use of higher-GWP HFCs in new 1) aerosols, 2) foams, and 3) refrigeration, air conditioning, and heat pump equipment.[2]
Among the most notable effects this rule will have on the HVAC-R industry relates to refrigerants. Since the start of 2022, bulk production and/or import of HFCs has been regulated using an allowance system, the goal of which is to gradually reduce the manufacture and importing of HFCs over time, as shown below.
Source: United States Environmental Protection Agency (https://www.epa.gov/climate-hfcs-reduction/frequent-questions-phasedown-hydrofluorocarbons#technology-transitions-program)
Before the finalization of “Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under the American Innovation and Manufacturing Act of 2020,” HFC substances contained in manufacturing products were not subject to the allowance requirement. With the announce of the final rule, however, “the import of certain products containing and using HFCs will be prohibited starting January 1, 2025.”
The tables below detail the GWP limit/prohibited substances for HVAC-R systems and products and the timeline of the rule’s implementation moving forward.
|
Subsector |
System |
GWP Limit or Prohibited Substances |
Installation Compliance Date5 |
|
Stationary residential and light commercial air conditioning and heat pumps |
Residential and light commercial air conditioning and heat pump systems (e.g., mini-splits, unitary systems) |
700 |
January 1, 2025 |
|
Stationary air conditioning and heat pumps |
Variable refrigerant flow systems |
700 |
January 1, 2026 |
|
Chillers |
Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) |
Not covered |
Not covered |
|
Chillers |
Industrial process refrigeration with exiting fluid from -50 °C (-58 °F) to -30 °C (-22 °F) |
700 |
January 1, 2028 |
|
Chillers |
Industrial process refrigeration with exiting fluid above -30 °C (-22 °F) |
700 |
January 1, 2026 |
|
Chillers |
Comfort cooling |
700 |
January 1, 2025 |
|
Ice rinks |
Ice rinks |
700 |
January 1, 2025 |
|
Data centers, computer room air conditioning, and information technology equipment cooling |
Data centers, computer room air conditioning, and information technology equipment cooling |
700 |
January 1, 2027 |
|
Industrial process refrigeration (not using chillers) |
With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) |
150 |
January 1, 2026 |
|
Industrial process refrigeration (not using chillers) |
With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) |
300 |
January 1, 2026 |
|
Industrial process refrigeration (not using chillers) |
High temperature side of cascade systems and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) |
300 |
January 1, 2026 |
|
Industrial process refrigeration (not using chillers) |
Temperature of the refrigerant entering the evaporator from -50 °C (-58 °F) to -30 °C (-22 °F) |
700 |
January 1, 2028 |
|
Industrial process refrigeration (not using chillers) |
Temperature of the refrigerant entering the evaporator below -50 °C (-58 °F) |
Not covered |
Not covered |
|
Cold storage warehouses |
With 200 or more lb refrigerant charge, excluding high temperature side of cascade system |
150 |
January 1, 2026 |
|
Cold storage warehouses |
With less than 200 lb refrigerant charge |
300 |
January 1, 2026 |
|
Cold storage warehouses |
High temperature side of cascade system |
300 |
January 1, 2026 |
|
Retail food - supermarkets
|
With 200 or more lb refrigerant charge, excluding high temperature side of cascade system |
150 |
January 1, 2027 |
|
Retail food - supermarkets |
With less than 200 lb refrigerant charge |
300 |
January 1, 2027 |
|
Retail food - supermarkets |
High temperature side of cascade systems |
300 |
January 1, 2027 |
|
Retail food - remote condensing units |
With 200 or more lb refrigerant charge, excluding high temperature side of cascade system |
150 |
January 1, 2026 |
|
Retail food - remote condensing units |
With less than 200 lb refrigerant charge |
300 |
January 1, 2026 |
|
Retail food - remote condensing units |
High temperature side of cascade system |
300 |
January 1, 2026 |
|
Retail food - remote refrigerated food processing and dispensing equipment |
Retail food - remote refrigerated food processing and dispensing equipment |
R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 |
January 1, 2027 |
|
Remote automatic commercial ice machines |
Remote automatic commercial ice machines |
R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 |
January 1, 2027 |
|
Refrigerated transport |
|
Not covered |
Not covered |
|
Refrigerated transport |
Intermodal containers with exiting fluid temperature from a chiller equal to or above -50 °C (-58 °F) |
700 |
January 1, 2025 |
|
Refrigerated transport |
Road systems |
R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 |
January 1, 2025 |
|
Refrigerated transport |
Road systems |
|
January 1, 2025 |
|
Refrigerated transport |
Marine systems |
R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 |
January 1, 2025 |
Source: United States Environmental Protection Agency (https://www.epa.gov/climate-hfcs-reduction/technology-transitions-hfc-restrictions-sector#refrigeration-ac-heat-pumps)
|
Subsector |
Product |
Global Warming Potential Limit or Prohibited Substances |
Manufacture and Import Compliance Date1 |
|
Stationary residential and light commercial air conditioning and heat pumps (e.g., window units, portable room air conditioning) |
Stationary residential and light commercial air conditioning and heat pumps (e.g., window units, portable room air conditioning) |
700 |
January 1, 2025 |
|
Residential dehumidifiers |
Residential dehumidifiers |
700 |
January 1, 2025 |
|
Household refrigerators and freezers |
Household refrigerators and freezers |
150 |
January 1, 2025 |
|
Vending machines |
Vending machines |
150 |
January 1, 2025 |
|
Motor vehicle air conditioning |
Light-duty passenger vehicles |
150 |
Model Year 2025, and no earlier than [One year after date of publication in the Federal Register] |
|
Motor vehicle air conditioning |
Medium-duty passenger vehicles, heavy-duty pick-up trucks, complete heavy-duty vans |
150 |
Model Year 2028 |
|
Motor vehicle air conditioning |
Listed nonroad vehicles (agricultural tractors greater than 40 horsepower; self-propelled agricultural machinery; compact equipment; construction, forestry, and mining equipment; and commercial utility vehicles) |
150 |
January 1, 2028 |
|
Chillers (as a stand-alone product) |
Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) |
Not covered |
Not covered |
|
Chillers (as a stand-alone product) |
Industrial process refrigeration with exiting fluid greater than or equal to -50 °C (-58 °F) and less than -30 °C (-22 °F) |
700 |
January 1, 2028 |
|
Chillers (as a stand-alone product) |
Industrial process refrigeration with exiting fluid equal to or above -30 °C (-22 °F) |
700 |
January 1, 2026 |
|
Chillers (as a stand-alone product) |
Comfort cooling |
700 |
January 1, 2025 |
|
Chillers (as a stand-alone product) |
Ice rinks |
700 |
January 1, 2025 |
|
Data centers, computer room air conditioning, and information technology equipment cooling |
Data centers, computer room air conditioning, and information technology equipment cooling |
700 |
January 1, 2027 |
|
Industrial process refrigeration (not using chillers) |
With refrigerant entering the evaporator below -50 °C (-58 °F) |
Not covered |
Not covered |
|
Industrial process refrigeration (not using chillers) |
With refrigerant entering the evaporator equal to or above -50 °C (-58 °F) and less than -30 °C (-22 °F) |
700 |
January 1, 2028 |
|
Industrial process refrigeration (not using chillers) |
High temperature side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) |
300 |
January 1, 2026 |
|
Industrial process refrigeration (not using chillers) |
With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) |
300 |
January 1, 2026 |
|
Industrial process refrigeration (not using chillers) |
With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) |
150 |
January 1, 2026 |
|
Retail food - refrigeration stand-alone units |
Retail food - refrigeration stand-alone units |
150 |
January 1, 2025 |
|
Retail food - refrigerated food processing and dispensing equipment |
500 g of refrigerant or less and outside scope of UL 621, edition 7 |
150 |
January 1, 2027 |
|
Retail food - refrigerated food processing and dispensing equipment |
More than 500 g of refrigerant and outside scope of UL 621, edition 7 |
R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 |
January 1, 2027 |
|
Retail food - refrigerated food processing and dispensing equipment |
Ice cream makers within the scope of UL 621, edition 7 |
R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 |
January 1, 2028 |
|
Self-contained automatic commercial ice machines |
Batch type: harvest rate <=1,000 lb ice per 24 hours |
150 |
January 1, 2026 |
|
Self-contained automatic commercial ice machines |
Continuous type: harvest rate <=1,200 lb ice per 24 hours |
150 |
January 1, 2026 |
|
Self-contained automatic commercial ice machines |
Batch type: harvest rate above 1,000 lb ice per 24 hours |
R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-442A, R-507, R-507A, HFC-134a, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, G2018C, Freeze 12 |
January 1, 2027 |
|
Self-contained automatic commercial ice machines |
Continuous type: harvest rate above 1,200 lb ice per 24 hours |
R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-442A, R-507, R-507A, HFC-134a, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, G2018C, Freeze 12 |
January 1, 2027 |
|
Cold storage warehouses |
With 200 or more lb refrigerant charge, excluding high temperature side of cascade system |
150 |
January 1, 2026 |
|
Cold storage warehouses |
With less than 200 lb refrigerant charge |
300 |
January 1, 2026 |
|
Cold storage warehouses |
High temperature side of cascade system |
300 |
January 1, 2026 |
|
Refrigerated transport |
Intermodal containers with refrigerant temperature entering the evaporator below -50 °C (-58 °F) |
Not covered |
Not covered |
|
Refrigerated transport4 |
Intermodal containers with refrigerant temperature entering the evaporator equal to or above -50 °C (-58 °F) |
700 |
January 1, 2025 |
|
Refrigerated transport4 |
Road—self-contained products |
R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 |
January 1, 2025 |
|
Refrigerated transport4 |
Marine—self-contained products |
R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 |
January 1, 2025 |
Source: United States Environmental Protection Agency (https://www.epa.gov/climate-hfcs-reduction/technology-transitions-hfc-restrictions-sector#refrigeration-ac-heat-pumps)
EPA has a large resource library with a complete list of all affected refrigerants, allowance details, and additional specifics on the phasedown.
As this and subsequent regulation is finalized, there's lots left to learn about what it means for the HVAC-R industry. We're still learning, too, but we feel it's important that those affected by the phasedown give it the care and attention it deserves. Should I change refrigerants? Do I need to change refrigerants? When do I need to change refrigerants? A deep understanding of the answers to these questions is a great place to start when deciding what action to take as a result of EPA's rule.
Once that decision is made, you can start to examine the impact that making the switch will have on coil and unit performance. If there’s a significant difference, there’s still time for design adjustments, but that window is gradually closing. If you find yourself in the position described above, contact us. We can work with you to better understand the effects of refrigerant changes and can help you with any coil design adjustments that may be necessary so you can say “we’re ready” with confidence.
Don’t get left out in the cold when it comes to heat transfer information. To stay up to date on a variety of topics on the subject, subscribe to The Super Blog, our technical blog, Doctor's Orders, and follow us on LinkedIn, Twitter, and YouTube.
*These tables are for informational purposes only and should not be relied on for compliance purposes. Please refer to 40 CFR Part 82, Subpart B for full details.
1. Sale, distribution, and export of these products is prohibited three years after the manufacture and import compliance date.
2. See regulatory text for specific types of aerosol products subject to the later compliance date. Excludes metered dose inhalers using HFC-134a or HFC-227ea or defense sprays using HFC-134a as a propellant.
3. Includes blown foam, products incorporating blown foam, and pre-blended polyol products. Excludes composite structural preformed polyurethane foam for trailer use and for marine use.
4. New products only; does not apply to equipment that is operational during transport.
5. EPA is restricting the installation of new field-assembled systems. Components used to repair existing systems are not subject to these restrictions.
[1] A pre-published, unofficial version of the rule was used in writing this article (86 FR 55116). The pre-published version has been submitted for publication the Federal Register, and the official version will be published at a later date.
[2] United States Environmental Protection Agency. (2023, October 13). Frequent questions on the phasedown of hydrofluorocarbons. Frequent Questions on the Phasedown of Hydrofluorocarbons. https://www.epa.gov/climate-hfcs-reduction/frequent-questions-phasedown-hydrofluorocarbons
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