REFRIGERANT CHANGES COMING IN 2025:
R-410A IS OUT
The Environmental Protection Agency, or EPA, continually strives to create a more sustainable planet, and one of its latest proposals drives that goal forward. In December 2022, the EPA unveiled a refrigerant ban that will go into effect between 2025 and 2026 (depending on the industry).
The result? R-410A is out, shaking up the HVACR industry, which relies heavily on this refrigerant.
This article will discuss the EPA’s proposal in detail, shed light on the reaction, and propose what HVACR professionals can do as we inch closer to 2025.
Expanding the AIM Act – The EPA’s
New Proposal on R- 410A Refrigerant
In December 2020, the EPA passed the AIM Act, known as the American Innovation and Manufacturing Act of 2020 in full. Enacted under Section 103, Division S, Innovation for the Environment, of the Consolidated Appropriations Act, 2021, the EPA enacted the AIM Act to create solutions for the rampant use of hydrofluorocarbons.
The AIM Act has three phases:
R-410A, which goes by commercial names like Puron, R410, Suva 410A, AZ-20, Puron, Forane 410A, Genetron R410A, and  EcoFluor, is a hydrofluorocarbon comprised of pentafluoroethane and difluoromethane. It’s a popular heat pump and air conditioning refrigerant widely used by HVACR businesses. With the introduction of the AIM Act, it only became a matter of time before the EPA began cracking down on hydrofluorocarbon usage, as per the three phases outlined in its plan. That means the usage of R-410A refrigerant could be banned as early as 2025.
The phase-down, as the EPA calls it, had already begun in 2020. Its plan to eliminate hydrofluorocarbons under the AIM Act will continue through 2036. By that year, the EPA seeks to reduce hydrofluorocarbon usage by 85 percent from where they began when enacting the AIM Act. After 2025 or 2026, when the production of most hydrofluorocarbons would be strictly outlawed, in 2026 or 2027, the EPA would take a year to focus on banning the usage, exportation, distribution, importation, and selling of the products.
The EPA measures refrigerant usage and types by their Global Warming Potential or GWP. Here is an overview detailing the HVACR activity and GWP limit. The compliance date is January 1st, 2025 for the following.
How Has the HVACR Industry Reacted to the
AIM Act Refrigerant Changes?
The EPA allowed businesses across the HVACR industry (and others) to sound off, leaving public comments until January 30th, 2023. During that time, many HVACR industry stakeholders and businesses commented, with more than 150 written pieces of feedback. You can read the comments here.
We can’t go over the contents of each, but the Air-Conditioning, Heating, and Refrigeration Institute or AHRI stated that the R-410A refrigerant limitations would place an especially “unreasonable burden” on small HVACR businesses. AHRI also commented on the EPA’s proposal that refrigerant shipped with equipment uses an allocation process to account for it, stating that “The proposal may be impractical and result in double or triple counting of refrigerant.”
Carrier Global Corporation, a security and fire equipment, refrigeration, air conditioning, ventilation, and heating multinational company, stated in its feedback letter upfront that it does not support the proposed regulations. According to Carrier, “Providing the refrigerant type, refrigerant GWP, charge size, quantity of models produced or imported, total refrigerant mass, and date of manufacture or import for each unique model creates significant burden on manufacturers with no compliance value to the agency.”
Some other large names that commented on the EPA’s proposal are:
That doesn’t mean these corporations and organizations necessarily disagreed with the EPA’s proposal, only that they left public comments for the EPA to read and take into consideration.
The Biggest Issues with the
EPA’s Refrigerant Ban
Several glaring holes in the EPA’s proposal to the AIM Act have made themselves apparent besides those mentioned above. Let’s review them.
Strict GWP Limits
Many of the GWP limits imposed make sense for the type of refrigeration system listed, but not all.
For instance, capping domestic refrigeration, stand-alone units, ice rinks, and vending machines at 150 GWP is low.
Some of the comments left on the EPA’s proposal asked to increase those limits to more reasonable figures, such as 700 GWP for ice rinks and 300 GWP for stand-alone units and vending machines.
Equipment Selling
The EPA states that HVACR companies have a year to sell their noncompliant equipment for producing, transporting, and retailing hydrofluorocarbons like R-410A refrigerant. The enforceable limit is as early as January 1st, 2026.
However, many across the HVACR industry agreed that forcing all companies to sell equipment simultaneously would put an unnecessary burden on the wholesale distribution industry and negatively impact it.
According to many of the HVACR businesses that commented on the EPA’s legislation, a better plan would be to use its manufacturing date as a sell-through deadline rather than the arbitrary date of January 1st, 2026.
Tight Deadlines
Another point of umbrage was the deadline of January 1st, 2025 for installing refrigerant systems. Many comments requested pushing off this date by an entire year. This way, facilities can upgrade equipment to support proper handling and storage for flammable refrigerants, and the refrigerants would have ample time for Nationally Recognized Testing Laboratory or NTRL testing.
An infographic from Emerson and Copeland found that fewer than half of HVACR companies surveyed have an action plan in response to the refrigerant changes, despite 73 percent thinking the EPA changes will affect their everyday business operations.
However, while only 63 percent of surveyed HVACR companies in 2022 had a plan to meet the EPA standards, it’s 86 percent in 2023.
What Comes Next for HVACR Companies?
Although the leading names in the HVACR industry brought up many profound points the EPA should closely ponder, all signs point toward the EPA moving ahead with its changes as proposed, including sticking to GWP limits and deadlines.
The Emerson and Copeland infographic mentioned that wholesalers and traders are struggling to build marketing and inventory plans. However, they will finalize an action plan with points such as technician and servicepeople training, product information meetings, and communicating with their distributors.
Whether that will be sufficient remains to be seen, but this regulation is pushing forward one way or another.