Enforcement and Inspection

Prepare for High-GWP Refrigerant Restrictions

The EPA will likely restrict the use of some common hydrofluorocarbon (HFC) refrigerants, including R134a, R410A, and R407C, in refrigeration and air conditioning equipment, as well as some foam production operations.

The EPA has granted, or partially granted, 11 petitions submitted by industry and environmental groups in response to the recently passed American Innovation and Manufacturing (AIM) Act, restricting the use of HFCs. Of those 11 petitions, seven are specifically related to the air conditioning and refrigeration industry, according to Cooling Post.

“In general, the petitions request a 150 [global warming potential (GWP)] limit threshold for most refrigeration including supermarkets and ice rinks, and a 750 GWP limit for air conditioning,” reports Cooling Post. “The petitions largely support the [Significant New Alternatives Policy (SNAP)] Rules 20 and 21, which were originally proposed by the EPA in 2014 but overturned in the US Court of Appeals in 2017. These proposals, which sought to prohibit the use of certain higher GWP refrigerants in specific applications, were later adopted by California and a number of other US states.”

The SNAP programs implement Section 612 of the 1990 amended Clean Air Act (CAA) and are designed to identify and evaluate substitutes for end uses that historically used ozone-depleting substances. GWP is among the criteria considered when evaluating a proposed substitute.

“This proposal would effectively ban R410A, due to its GWP of 2,088, leaving the flammable A2L refrigerants R32, with its GWP of 677, and R454B [GWP 466] as the main currently available commercial options, with flammable A3 propane in smaller systems,” adds Cooling Post.   

The European Commission is also considering a 750 GWP maximum under the European F-gas regulation, Cooling Post continues.

The EPA has two years to finalize rulemaking on the petitions it has granted. In addition, there are other petitions still under consideration by the Agency. These rules will follow up the final HFC phasedown rule, completed in September 2021, which established a program to cap and reduce the U.S. production and use of HFCs by 85% by 2036.