SNAP Rule 26 Clears A2Ls for Takeoff

Companies can now start manufacturing lower-GWP commercial refrigeration equipment

A2L UNITS: Under SNAP Rule 26, companies can now start manufacturing lower-GWP commercial refrigeration equipment. (Courtesy of Chemours)

In May, the U.S. Environmental Protection Agency’s (EPA’s) Significant New Alternatives Policy (SNAP) program made HVACR headlines when Rule 26 became final. Approved to take effect on July 14, 2024, SNAP Rule 26 clears the runway for A2L for refrigerant manufacturers to commercialize high-performing, significantly lower-GWP A2Ls -- specifically, R-454A, R-454B, and R-454C -- and for OEMs to manufacture new systems using these refrigerants for commercial and industrial refrigeration applications.

Technology Transition

SNAP Rule 26 is an integral part of the larger industry transition to new-generation refrigerant solutions. The SNAP program was established in 1994 under Section 612 of the Clean Air Act, which requires the EPA to identify and evaluate substitutes for end uses that historically have utilized ozone-depleting substances. To achieve this, the EPA evaluates a substance’s overall risk to human health and the environment, looking at criteria such as ODP, GWP, flammability, and toxicity; occupational and consumer health and safety; and environmental risks, such as impact on ecosystems and local air quality. In addition to listing acceptable substitutes, Section 612 requires the EPA to prohibit use of substances in applications where alternatives pose less overall risk to human health and the environment.

In terms of where the industry is today, Rule 26 and other recent rules along the SNAP timeline provide critical support as the AIM Act works to achieve a total 85% HFC phasedown -- from historic baseline levels -- by 2036. As supply of HFCs decreases, SNAP approvals provide guidance for substitute solutions that meet equipment needs and establish a foundation for industry-wide use of refrigerants that support environmental necessities such as reduced energy consumption and lower GWP.

In addition to phasedowns, the AIM Act’s Technology Transitions program -- often called sector-based controls -- will start to impact the industry as early as January 1, 2025. Rules under this program limit use of HFC refrigerants and support A2L adoption by calling for GWP limits for refrigerants based on specific applications, including commercial and industrial refrigeration. The marriage here is clear -- SNAP Rule 26 lists substitutes that meet the requirements of sector-based GWP limits in commercial refrigeration and other applications specified under Technology Transitions.

More about Rule 26

Under SNAP Rule 26, the EPA lists 10 acceptable refrigerants, subject to use conditions, for various commercial refrigeration applications, including commercial ice machines, industrial process refrigeration, cold-storage warehouses, retail food refrigeration, and ice rinks. Six of the refrigerants -- R-1234yf, R-1234ze(E), R-454C, R-455A, R-457A, and R-516A -- have a GWP under 150. A few refrigerants with a GWP greater than 150 -- R-454B and R-32 -- for example -- are also listed as acceptable substitutes, because their performance characteristics necessitate their use in certain applications. The rule also modifies use conditions for R-290 (propane) and exempts it from the venting prohibition in refrigerated food processing and dispensing equipment.

Because many acceptable substitutes are classified as mildly flammable A2L refrigerants, the EPA incorporates use conditions to ensure safety. These conditions rely upon the latest version of safety standards UL 60335-2-89, ASHRAE 15-2022, and ASHRAE 34-2022. A2Ls will be used in new equipment only. However, for practically any application using a higher-GWP HFC in an existing system, there likely is a lower-GWP HFC/HFO blend retrofit solution.

SNAP Rule 26 will first impact refrigerant manufacturers such as Chemours and original equipment manufacturers (OEMs). With the approval of several A2Ls as acceptable substitutes under SNAP Rule 26, OEMs now have the green light to use these new-generation refrigerants in new commercial refrigeration systems. Refrigerant manufacturers can also move ahead with the finalization and commercialization of approved A2L substitutes in the U.S., many of which have been commercially available and used effectively in Europe for years.

The impact of SNAP Rule 26 will next reach facility managers, store owners, and other decision-makers in commercial and industrial refrigeration. SNAP Rule 26 supports OEMs in developing a variety of new equipment options by allowing them to consider many different factors in refrigerant selection, such as energy efficiency, GWP, capacity, normal boiling point, temperature glide, cost, safety, and use conditions. Lastly, SNAP Rule 26 will impact HVACR technicians, who should engage in A2L training programs to ensure they can work safely with these mildly flammable refrigerants and use them properly to allow for optimum performance.

Prepared for Takeoff

In anticipation of SNAP Rule 26, Chemours and multiple OEMs have started to align strategies to embrace A2L replacements, such as R-454A and R-454C, and take steps to ensure a strong A2L supply chain. Chemours recently made a major capital investment to expand capacity for production of HFO-1234yf, which is used as a blend component in our A2L products listed as acceptable substitutes.

Representing the convergence of high performance, improved energy efficiency, lower GWP, and adherence to safety requirements and sustainability standards, A2L refrigerants possess incredible staying power. As not a requirement but an opportunity, SNAP Rule 26 has put in motion another critical step for the successful transition to A2L technology in commercial and industrial refrigeration.

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Schuyler Pulleyn is a senior regulatory consultant at The Chemours Company FC, LLC. He has established his specialty in chemical regulations over the past 15 years by being an integral part of the teams at DuPont and Chemours. As part of Chemours Thermal and Specialized Solutions, he focuses his regulatory expertise on providing the HVACR industry with insights that support the successful transition to lower-GWP refrigerant solutions.