Over the past several years, the dynamic regulatory landscape has exerted increasing influence upon those who select commercial refrigeration equipment. Uncertainty about which refrigerants would be available for use — and which legacy hydrofluorocarbon (HFC) refrigerants would be phased out (and when) — has dominated the conversation. Amid this uncertainty, operational safety, reliable system performance, total cost of ownership (TCO) and sustainability continue to remain key system selection considerations.
With the passing of the American Innovation and Manufacturing (AIM) Act in late 2020 — and the Environmental Protection Agency’s (EPA) recent Technology Transitions proposal — regulatory compliance is becoming a top priority. Not only did the AIM Act bring HFC regulations back into focus at a national level, but it also promised an end to the federal stalemate on the phasedown of HFC refrigerants. For those in the commercial refrigeration sector, the EPA’s renewed authority to regulate refrigerants will provide much needed regulatory uniformity throughout the U.S.
Understandably, after dealing with years of uncertainty, many organizations have developed varying degrees of refrigerant transition fatigue. Some are seeking a strategy that would remove iterative steps and get them to the end game of compliance. Others prefer to take a more incremental approach, i.e., focusing on a strategy that meets near-term compliance targets but is also capable of adapting to future standards. Regardless of which approach aligns with your operational objectives, it’s important to be aware of the regulatory implications, available refrigerant options and refrigeration technologies that enable them.
The California Air Resources Board (CARB) has led the way on the HFC phasedown by establishing ambitious proposals which went into effect in Jan. 2022:
- New facilities — Installation of new refrigeration systems containing more than 50 pounds of refrigerant are required to use refrigerants with less than 150 global warming potential (GWP).
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Existing facilities — Installation of new systems are subject to company-wide, fleet GWP reduction targets by 2030 compared to their 2019 baselines. CARB offers two paths for compliance in existing facilities:
- Weighted-average GWP (WAGWP) reduction <1,400 GWP by 2030, where WAGWP is the sum of the total refrigerant charge of every system greater than 50 pounds in every store in California
- Greenhouse gas emissions potential (GHGp) reduction by 55 percent, where GHGp is the sum of the total refrigerant charge of every system greater than 50 pounds in every store in California multiplied by the GWP values of the refrigerant types in use
In late 2022, the EPA proposed a Technology Transitions rule that would impose new GWP limits across HVACR sectors. Although a final rule on this proposal is expected in October, proposed compliance dates are set to begin in 2025, with GWP restrictions per sector, including commercial refrigeration:
- 150 GWP in large systems (≥200 lbs.) and self-contained units; 300 GWP in smaller-charge systems (<200 lbs.)
All regulatory developments are impacting system architectures that favor lower refrigerant charges, natural refrigerants (CO2 and R-290) and the emergence of lower-flammability A2L refrigerants. Copeland is developing the next generation of refrigeration technologies to support the safe and reliable use of lower-GWP refrigerants.
