ShareUS to ban high-GWP refrigerants
A rule proposal by the US Environmental Protection Agency (EPA) provides that all high-GWP HFCs, including R134a, R404A and R410A, will be banned in most new refrigeration equipment from January 1, 2025.
The American Innovation and Manufacturing (AIM) Act was enacted in December 2020 and authorises the EPA to phase down the production and consumption of HFC refrigerants, maximise their reclamation and minimise releases from equipment, while facilitating the transition to next-generation technologies through sector-based restrictions.
The AIM Act directs the EPA to phase down the production and consumption of HFCs by 85% by 2036, in line with the schedule in the Kigali Amendment to the Montreal Protocol, ratified by the United States on October 31, 2022. (see our previous post )
The rule proposed by EPA in December 2022 focuses on the transition to alternatives through sector-based restrictions via a ban on the use of high-GWP HFCs starting from 2025 in most new refrigeration, air conditioning and heat pump applications. This rule intends to prohibit the manufacture and import of products containing such HFCs by January 1, 2025, in most cases, and to prohibit the sale, distribution, and export of these products one year later.
The main restrictions proposed are the following:
| Application | Proposed GWP limit | Compliance date |
|---|---|---|
|
Residential and light commercial air conditioning and heat pump systems |
700 |
January 1, 2025 |
|
Residential and light commercial air conditioning – variable refrigerant flow systems |
700 |
January 1, 2026 |
|
Retail food refrigeration – stand-alone units, supermarket systems with refrigerant charge capacities of 200 pounds* or greater, remote condensing units with refrigerant charge capacities of 200 pounds or greater |
150 |
January 1, 2025 |
|
Retail food refrigeration – supermarket systems with refrigerant charge capacities less than 200 pounds* charge, remote condensing units with refrigerant charge capacities less than 200 pounds |
300 |
January 1, 2025 |
|
Cold storage warehouse systems with refrigerant charge capacities of 200 pounds* or greater |
150 |
January 1, 2025 |
|
Cold storage warehouse systems with refrigerant charge capacities less than 200 pounds* |
300 |
January 1, 2025 |
|
Residential refrigeration systems |
150 |
January 1, 2025 |
|
Motor vehicle air conditioning – light-duty passenger vehicles |
150 |
Model year 2025 |
These restrictions mean that all common higher GWP HFCs including R134a, R404A and R410A will be banned in most new refrigeration and air conditioning applications from 2025. However, the proposed GWP limit of 700 for residential and light commercial air conditioning from 2025 means that R32 will remain permitted as the EPA rates its GWP at 675.
By way of comparison, it can be noted that, within the framework of the revision of EU Regulation n°517/2014 (“F-gas” Regulation), the European Commission proposes to prohibit in the EU the use of HFCs with a GWP of 150 or more in new split system air conditioners and heat pumps with a nominal output of 12kW or less from 2027, thereby prohibiting the use of R32 (see our previous post).
The full list of restrictions proposed by EPA is available here.
EPA estimates that the proposed rule, if finalised as written, would result in cumulative emission reductions up to 903 million tonnes of CO₂-equivalent from 2025 to 2050, with net climate benefits of up to USD 56.3billion.
The draft rule was open for comment until the end of January 2023.
Download the Informatory Note on low-GWP refrigerants