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California Regulations

California has introduced a new law that will ban the use of higher GWP (Global Warming Potential) refrigerants above a certain threshold (CA SB1206).  Wholesalers and technicians need to be aware of these new rules taking effect January 1, 2025. Arkema would like to review some of the most important points so customers are aware of them and can properly prepare.  The full rule is available online on California’s CARB website. 

Notable points from SB1206: 

  • Virgin refrigerants with a GWP equal or greater than 2,200 are banned starting January 1st, 2025.  This would affect refrigerants such as R-422A, R-422B, R-422C, R-422D, R-428A, R-438A, R-404A, R-407A, R-408A, R-507 currently used in HVAC-R.   
  • Virgin refrigerants with a GWP equal or greater than 1,500 are banned starting January 1st, 2030.  This would affect, R-410A, R-407A and R-407C for example. 
  • Virgin refrigerants with a GWP equal or greater than 750 are banned starting   January 1st, 2033.  This would ban most of the currently available HFCs, with some notable exceptions such as R-32. 
  • Reclaimed refrigerant is exempt from these bans and can be used in OEM or for service. 
  • Wholesalers & Technicians need to remove all non-compliant refrigerants (i.e. virgin refrigerant above the GWP threshold) from service to avoid potential issues. 
  • Regulations apply to any person or business and to refrigerants in any quantity or type of packaging. 

 

Please note that technicians can still use Forane® R-427A for R-22 retrofits. Forane® R-427A is still allowed for service through the end of 2029. 

 

Any and all provisions of the AIM Act still apply. 

 

Consult with your refrigerant supplier for more information, or contact our experts at Arkema Inc. Forane® refrigerants for additional help at (800) 245-5858.  The GWP value for most refrigerants can be found by downloading our free Forane® App. 

Europe and F-gas

Arkema is working with the European Fluorocarbons Technical Committee (EFCTC), of which it is a member, to prevent the illegal import of HFCs into the European Union. The latest information can be found on the website: www.stopillegalcooling.eu

The European F-gas Regulation (No. 517/2014) went into effect on January 1,  2015. The aim of the regulation was to reduce F-gas emissions in the European Union by two-thirds of the levels of 2010 by 2030 and to encourage the use of viable and more climate-friendly alternatives, where they are readily available. In order to do this, the regulation established the following:

  • Cap and phase-down for HFCs
  • Bans or restrictions based on GWP on the use of F-gases in some new equipment, such as refrigerators and air conditioners, insulating foams, and technical aerosols
  • Conditions (for example reporting on quantities of HFCs contained and the need for HFC import quotas) on products and equipment containing or relying upon F-gases
  • Future restrictions on servicing/maintenance of equipment using HFCs
  • Rules regarding containment, use, recovery, and destruction of HFCs

The regulation and its measures will be subject to a full review following the publication of a comprehensive report on its effects no later than December 31, 2022, including, in particular, a forecast of the continued demand for hydrofluorocarbons up to and beyond 2030.

Replacement products

According to this regulation, the use of virgin refrigerant with a GWP higher than 2,500 in stationary refrigeration equipment will be prohibited from January 1, 2020, in Europe.  This prohibition will affect mainly the use of R-404A/R-507A in refrigeration applications.  As a replacement product, Arkema offers the Forane® 449A (XP40).  

From January 1, 2025, the use of R-410A will be prohibited in single split air-conditioning systems containing less than 3 kg in Europe. Forane® 32 is presented by Arkema as the best replacement for these applications because of its high efficiency.

Arkema has developed a new, non-flammable low-GWP product, Forane® 1233zd, for chillers, foam insulation, and energy recovery applications in order to increase equipment efficiency and reduce CO2 emissions, if other technologies are used.

Quota mechanism

The F-gas quota phase-down mechanism reduces the quantity of HFCs that can be sold on the European market to 21% equivalent CO2 in 2030, compared to 2015 as a baseline.

Years

Percentage*

2015

100%

2016-2017

93%

2018-2020

63%

2021-2023

45%

2024-2026

31%

2027-2029

24%

2030

21%

 

* Percentage to calculate the maximum quantity of hydrofluorocarbons to be placed on the market and corresponding quotas.

Source: REGULATION (EU) No 517/2014

For more information on F-gas regulation, visit the European Partnership for Energy and the Environment (EPEE) website:  https://epeeglobal.org/

US Federal


  • Both SNAP Rule 20 and Rule 21 have now been vacated to the extent they required HFCs to be replaced. EPA, therefore, cannot use SNAP de-listings to force anyone already using HFCs to stop or switch to other products.  

  • EPA has announced that it is working on a new proposed rule that will explain how it intends to address HFCs going forward.

  • EPA has issued guidance saying it would not apply any of the HFC SNAP de-listings, including uses where the transition from ODS to HFCs has not yet occurred, pending further rulemaking; a legal challenge to this position has been filed.

US Federal and State HFC Activities

  • The American Innovation and Manufacturing (AIM) Act went into effect in December of 2020 and requires US EPA to implement a phasedown of HFCs consistent with Kigali (i.e., a step-down process of 85% reduction by 2036).

  • EPA will publish a number of HFC phasedown regulations over the coming years, starting with the Allowance Allocation Rule expected to be finalized by September 23, 2021, and be effective in January of 2022.

  • A number of states are implementing their own HFC control programs, which may differ in specific requirements, but are likely to be consistent with the federal phasedown rules.

Arkema actively supports the AIM Act and believes that regulation of HFCs should allow for innovation, be market-based and be uniform (rather than implemented through a patchwork of state and local regulations). To help smooth the transition, we continue to invest in next-generation technologies.   

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