EPA Introduces Rules For HFC Refrigerant Management and Technology Transitions

Today, let’s dive into the recent buzz around the U.S. Environmental Protection Agency (EPA) dropping some eco-friendly bombshells on the HVACR industry. Brace yourselves for two major rules under the American Innovation and Manufacturing (AIM) Act, designed to kick hydrofluorocarbons (HFCs) to the curb and make our air a little fresher.

Rule #1 is Technology Transitions and rule #2 is HFC Refrigerant Management.

After reading this article you’ll have a better handle on:

  • The two new major rules announced by the EPA
  • How to stay compliant and up to date

Technology Transitions Rule: Out with the Old, In with the New

The EPA rolled out the finalized Technology Transitions Rule, that went into effect December 26, 2023. This rule has its sights on slashing the global warming potential (GWP) of refrigerants used in air conditioning and refrigeration gear

The biggest impact so far: The ability to install R-410a systems is coming to an end on January 1, 2025. Installation is banned after that date.

With the phaseout of R-410a, there are several good options for air conditioning systems including R32, R452B, and R454B. With all the latest legislation, the lower GWP (Global Warming Potential), the better.  

ACCA and the HVAC community are trying to establish a sell-through period or date for both residential and light commercial use of R-410a. 

Now, compliance dates are scattered like confetti, ranging from 2025 to 2028, depending on the application. Just remember, this rule covers both the birth (manufacture) and the baptism (installation) of HFC equipment. 

Here are two dates to circle on your HVAC calendar:

  • January 1, 2025: Installation of stationary residential and light commercial air conditioning and heat pumps must use refrigerants with less than 700 GWP 
  • January 1, 2026: Installation of stationary air conditioning and heat pumps must use refrigerants with less than 700 GWP 

Note: The greater the GWP value, the greater the heat-trapping effect of a specific gas on Earth in comparison to carbon dioxide. GWP values for ozone-depleting substances can vary from 5 to as high as 14,400.

System Repair vs. Component Replacement

In the rule, the EPA differentiates between “products” and “systems.” A product is like a ready-to-roll item, while a system needs a little TLC from installers to finalize the refrigerant circuit. 

Here’s a breakdown of refrigeration vs HVAC systems under the new rule when it comes to replacements and new installations.

Refrigeration Equipment: According to the rule, restrictions apply to refrigeration equipment when “75 percent of the refrigeration system’s evaporators (by number) and 100 percent of its compressor racks, condensers, and connected evaporator loads are replaced; such replacement constitutes a new installation.”

Air Conditioning Systems: Restrictions vary based on system size. For systems featuring one condenser and one  evaporator, restrictions come into play when “replacing the exterior condenser, condensing unit, or remote condensing unit.” 

If a system has more than one condenser and/or multiple evaporators, there are more restrictions: “when 75 percent of the indoor evaporator units (by number) and 100 percent of the air source or water source condensing units are replaced over a three-year period.”

So while it’s a little confusing, you will need to follow this information to determine new restrictions on repair and replacement. 

HFC Refrigerant Management Rule: Playing Detective with Leaks

The EPA also dropped the HFC Refrigerant Management Rule, which is still in the proposal stage, meaning that the provisions are subject to change. 

The HFC rule is like a Sherlock Holmes for HVAC systems, sniffing out leaks, demanding repairs, and promoting good behavior.

Leak repair requirements are a bit complicated, so take note. If your system has a refrigerant charge of 15 lbs. or more with a GWP of 53 or greater, you’ve got 30 days to fix those leaks (or 120 if you need an industrial shutdown). 

And yes, there are leak rate thresholds: 

  • 20% for commercial refrigeration 
  • 30% for industrial process refrigeration 
  • 10% for comfort cooling appliances

Automatic Leak Detection Systems (ALDs) are mandatory for certain new and used appliances. Those with 1,500 pounds or more of HFC (or HFC substitutes with a GWP over 53). 

No ALDs are needed for comfort cooling appliances – they’re chill. This is because of lower leak rates.

Reclaim: Recycling for Refrigerants

The EPA is all about being eco-friendly, proposing rules for reclaiming refrigerants before selling or transferring them. No more tossing them out like last night’s takeout! 

Reclaimed refrigerants need a stamp of purity, and there’s a cap on the amount of virgin HFC allowed in the mix – no more than 15%.

Starting January 1, 2028, the EPA wants us to use reclaimed HFCs for the initial charge in specific equipment, including:

  • Residential and light commercial AC and heat pumps
  • Cold storage warehouses
  • Industrial process refrigeration
  • Stand-alone retail food refrigeration 
  • Supermarket systems 
  • Refrigerated transport
  • Automatic commercial ice makers 

Also starting January 1, 2028,  the EPA proposal states that reclaimed HFC refrigerant be used to service OR repair certain equipment, including:

  • Stand-alone retail food refrigeration 
  • Supermarket systems 
  • Refrigerated transport
  • Automatic commercial ice makers 

Cylinder Management and Tracking

The Refrigerant Management rule addresses cylinder management and tracking. 

If you’re purchasing, receiving or handling cylinders with regulated substances, you’re required to register with the EPA’s tracking system. And disposable cylinders? Return them to reclaimers – heels and all. 

Compliance is supposed to be rolling in phases, so buckle up between 2025 and 2027. As a disclaimer, a similar provision was struck down when ACCA entered into a lawsuit against the EPA, so nothing is set in stone.

The court struck down provisions of the Environmental Protection Agency’s (EPA) allocation rule. This rule would have banned the use of non-refillable cylinders and require QR code tracking of refrigerant cylinders

You’re Ready For The New Rules

That about sums up the two new EPA rules concerning HFC refrigerant management. Make sure to stay updated – we’ll keep you informed. Check back for more articles on the latest laws and regulations


Related: EPA Proposes 40% Cut in HFC Phasedown in 2024


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