Recently, the Environmental Protection Agency (EPA) released a proposed rulemaking detailing how it plans to ban the use of many HFCs in new air conditioners and commercial refrigeration equipment. The rulemaking is part of the AIM Act, which tasks EPA with phasing down the production and consumption of HFCs by 85% by 2036; maximizing refrigerant reclamation and reducing leaks; and restricting the use of regulated HFCs in sectors or subsectors where they are used. This rulemaking addresses the third area, specifically, transitioning to alternatives through sector-based restrictions.

In the proposed rule, all restrictions would occur in two stages: The manufacture or import of products would be prohibited by either 2025 or 2026, depending on the sector or subsector, followed a year later by a prohibition on the sale, distribution, offer for sale or distribution, export, and other activities pertaining to those products (see Tables 1 and 2). This proposed rulemaking addresses all petitions that EPA has granted thus far.

TABLE 1: Proposed GWP limit restrictions on HFCs by sector and subsector. (Courtesy of EPA)

TABLE 2: Proposed prohibited substance restrictions on HFCs by sector and subsector. (Courtesy of EPA)

While most thought that EPA would follow California’s lead and propose a 750 GWP limit in new air conditioners and heat pumps, the Agency’s rulemaking calls for a 700 GWP limit for most new comfort cooling equipment, including chillers, starting January 1, 2025. VRF systems would have until January 1, 2026 to comply with the restrictions. The rule also proposes a 150 or 300 GWP limit for most new commercial refrigeration equipment used in supermarkets and convenience stores, also starting in 2025.

To support compliance with the proposed prohibitions on the use of HFCs in specific sectors and subsectors, EPA is proposing labeling, reporting, and recordkeeping requirements for products imported or manufactured using an HFC. The Agency is proposing to use the same reporting platform used in prior AIM Act rules and the Greenhouse Gas Reporting Program (GHGRP).

EPA estimates that the proposed rule, if finalized as written, would result in significant greenhouse gas (GHG) emissions reductions benefits while providing savings to American consumers and industry through energy efficiency gains and lower cost alternatives. The proposal would result in cumulative GHG emissions reductions ranging from 134 to 903 MMTCO₂e through 2050. EPA estimates that the cumulative net benefits of this proposed action are between $13.1 billion to $56.3 billion from 2025 through 2050.

EPA will accept comments on this proposal for 45 days after publication in the Federal Register and will hold a virtual public hearing after publication in the Federal Register. For more information on the rule and how to comment, as well as information on the virtual public hearing, please visit www.epa.gov/climate-hfcs-reduction.