The HVACR industry is undergoing another refrigerant transition, as HFCs such as R-410A and R-404A are being phased down in favor of new, lower-GWP refrigerants, such as R-32 and R-454B. Unlike the last transition, which shifted from the use of one nonflammable (A1) refrigerant to another, many of these new refrigerants are mildly flammable (A2L), so additional care will need to be taken in order to safely use them.

This year will also be pivotal for the refrigerant transition, as a 40% reduction in HFC production occurs starting January 1, 2024. Below, industry experts offer advice about what contractors need to know about the transition, as well as how to prepare for it.

EXPERT OPINIONS

Alex Ayers, director of government affairs at HARDI

The AIM Act that was passed in 2020 phases down the production and consumption of HFCs, including all the major refrigerants that we use today in air conditioning and refrigeration. That means that 2023 is really an important year for us to prepare for this transition, as 2024 is our first major reduction in production of HFCs. With that reduction in HFC refrigerants, we're going to need to prepare for this next generation of refrigerants that will come into play. And that means A2Ls or mildly flammable refrigerants will start being used in air conditioning equipment very soon.

For contractors and distributors, this means making sure that you are trained on A2L refrigerants, whether that is from a third party or from your equipment manufacturer. Distributors also need to prepare to receive bulk shipments of A2L cylinders, along with precharged equipment. It's really important for everyone to spend 2023 preparing, whether that is going through training or getting your updated occupancy permits for your warehouses, making sure that you understand what's going to be required of you as this transition goes on.

That's going to be partially accelerated by the changing state of building codes, where more and more states are adopting A2Ls earlier than what was maybe expected a couple of years ago. This ensures that we have enough places to install A2Ls for that first major step down.

We also need to make sure that we have enough reclaim and recovery. It's very important to recover as much of the older HFCs like R-410A as possible, so that way we have an adequate supply of reclaim moving into the future years and making sure that no one is forced to replace any equipment early due to a lack of supply.

Phil Johnston, general manager of the environmental business development center at Daikin Applied Americas

When talking about refrigerants, I have three recommendations for contractors and other industry professionals heading into 2023. First, get up to speed on exactly what is shifting and when. The U.S. Environmental Protection Agency (EPA) granted certain petitions that suggested alignment with the state of California transition date of January 1, 2024; however, EPA recently proposed not aligning with California and setting a January 1, 2025 national deadline to transition chillers for domestic installations. That is when refrigerants with a GWP at or above 700, such as R-134a and R-410A, can no longer be used in chillers for comfort cooling. Direct HVAC systems like rooftops, ground-source heat pumps, mini splits, and VRV transition at later dates.

Second, get familiar with the replacement options. The replacements for R-410A are group A2L refrigerants, but not all A2Ls are alike. It's important to look at the performance characteristics of each refrigerant; for example, what's the refrigerant charge, the thermal capacity, or the efficiency? Beyond GWP, these variables have a significant impact on total lifecycle climate performance and total lifecycle operating costs. With this information, you can help guide your customers to the ideal option for their application.

Third, seek out training. Organizations such as the ESCO Group, ACCA, and RSES offer training on the new refrigerants. These groups and the education programs they provide are a fantastic resource. You're also going to see a wave of new products with low-GWP refrigerants from manufacturers throughout this coming year and most will have corresponding training. It will also be valuable to get engaged with your local sales offices — your partners — for detailed information and support.

Jason Obrzut, director of industry standards and relations at the ESCO Group

The HVACR industry is currently going through an HFC phasedown. The industry is transitioning to refrigerants classified as low-GWP refrigerants. Many of these refrigerants are designated as slightly or highly flammable. Industry standards and codes have been updated to allow this transition to occur in a variety of applications. One of the things to note as we head into 2023 is that the adoption of these updated codes and standards is happening at the state level, and some states are ahead of others. In other words, low-GWP refrigerants will be rolled out in some states before they're allowed in others. Check with your local code authority to see how far along your state is in the transition.

One final note: Just because the refrigerant is flammable doesn't mean the refrigeration cycle changes. However, updated standards and guidelines have been released for the transport, storage, and safe handling of these refrigerants. Seek out training on these refrigerants. Continuing education is an investment in yourself and your future.

Chris Forth, vice president of regulatory, codes, and environmental affairs, ducted systems, at Johnson Controls

The EPA recently had an announcement regarding the AIM Act, which pertains to the phasedown of HFCs. Specifically, the technology transition proposals, which industry submitted more than a year ago. While we were expecting this announcement, there are a couple of notable surprises you should be aware of.

You might ask what are technology transitions, and what did those have to do with the transition to low-GWP refrigerants and the phaseout of 410A? Technology transitions are prohibitions on certain HVAC sectors such as air conditioning, VRF, or chillers to stop production of those products, which use refrigerants above a certain GWP threshold. Technology transitions are used by EPA to aid in the overall phase down of HFCs covered by the scope of the AIM Act. In this case, EPA is proposing that the air conditioning and heat pumps sector stop production of new equipment beginning January 1, 2025. I emphasize that this is for new equipment.

While the January 1, 2025 date isn't a surprise, and we're glad this date hasn't been moved, the surprise is the GWP level of 700. The industry had petitioned AHRI to request a maximum limit of 750, not 700. The 750 GWP also aligns with California and other states, so we’re not sure why EPA went with the 700. While the 700 doesn't negatively impact JCI's low-GWP choice of R-454B, which has a GWP of around 466, or even that of R-32, which has a GWP of around 675, it could impact other refrigerant solutions that exceed 700. Of course, the lower the number, the better, and the lower number could help the EPA achieve its ultimate reduction targets.

The bigger news, however, is that EPA is also proposing a one-year prohibition on the sell through of equipment — in this case, R-410A. In other words, EPA is saying whatever new production that is left over after one year would basically be dead inventory. The question this one-year prohibition raises is, will this result in any stranded inventory? EPA is providing a couple of different opportunities for comments, including a webinar and formal comments that can be submitted. The date for the webinar and the formal comments will be 15 days and 45 days respectively after a formal notice has been published in the Federal Register. That date hasn't happened yet, but this is something trade organizations should be aware of and individuals may want to comment directly.

Jennifer Butsch, director of regulatory affairs at Emerson

At the federal level for 2023, we expect to gain clarity. The EPA is currently working to finalize three important rules impacting refrigerants used in HVACR applications resulting from the AIM Act:

1. In 2024, the HFC supply is scheduled to drop another 30% per the Kigali Amendment. The EPA is finalizing the next allocation rule (HFC allowances for producers and importers) for years 2024 to 2028, and we expect this to be finalized later in 2023.
2. On the demand side, the EPA will be placing limits on the GWP of new equipment through the recently proposed technology transition rule. We expect the final version of the rule in October 2023.
3. Subsection (h) of the AIM Act directs the EPA to announce regulations for the purpose of maximizing reclamation and minimizing releases of certain HFCs — a proposal is likely to be released in summer 2023. This rule will likely be expanded to broadly address demand for higher-GWP refrigerants in existing equipment through requirements around leak repair, recordkeeping and reporting requirements, and service practices during installation. This rule could also include specifics related to refrigerant reclamation.

We also expect to see further activity out of the EPA through the Significant New Alternatives Program (SNAP) program. We hope to see the EPA finalize SNAP 25 for chillers and dehumidifiers, as well as release a proposed rule (perhaps SNAP 26) enabling additional refrigerant substitutes for commercial refrigeration end uses.

Building code updates remain key to a successful transition to lower-GWP refrigerants, many of which have a degree of flammability. Many states have not begun updating codes to allow for use of A2Ls in air conditioning and refrigeration. There will continue to be a huge push here to get as many of these states updated as possible by the end of 2023.

The patchwork of state level activity is likely to continue, but we are hopeful that progress at federal level reduces some activity at state level. The state level activity we are currently monitoring includes:

• California, New York, and Washington State are all working through additional HFC rulemakings associated with recently passed legislation; and
• Continued PFAS (per- and polyfluoroalkyl substances) activity at the state level (PFAS are a group of chemicals that do not break down in the environment and can cause health risks in people and animals). In 2021, Maine passed legislation regulating the use of PFAS. While the ban on certain substances listed in the legislation does not go into effect until 2030, the first phase of the legislation goes into effect on January 1, 2023, requiring manufacturers to label certain goods and components that are considered PFAS under Maine’s definition of PFAS. The current definition includes most synthetic refrigerants, so it is important for manufacturers to familiarize themselves with this law and ensure compliance with approaching labeling requirements. In addition to other states initiating their own laws related to PFAS, we expect to see continued effort to try to align their work with EPA approaches to PFAS.