With climate change front and center on the global stage, reducing the use of harmful hydrofluorocarbons (HFCs) has become a critical environmental goal. Bob Miller, President of Coward Environmental Systems, Inc., provides insights into the background, regulatory actions, and phasedown plans that are reshaping the refrigerant industry in the U.S. and globally.
Background: The Montreal Protocol and Ozone-Depleting Substances
The journey began in 1987 with the signing of the , an international environmental agreement aimed at protecting the ozone layer. Initially, the Protocol focused on phasing out chlorofluorocarbons (CFCs), compounds like R-12 used in refrigeration and air conditioning but notorious for depleting the ozone. “The Montreal Protocol set the foundation for environmental accountability in our industry,” explains Miller. “It showed the power of global cooperation.”
In 1992, the Protocol took a step further, initiating the phase-out of hydrochlorofluorocarbons (HCFCs) like R-22. Although HCFCs were less harmful than CFCs, they still contained ozone-depleting chlorine. By 2016, the Protocol expanded to address greenhouse gases, targeting HFCs, which have a high global warming potential (GWP) despite being ozone-safe. These gases, including refrigerants like R-410A, became the focus due to their significant climate impact.
The Kigali Amendment: A Phase-Down, not a Phase-Out
The Kigali Amendment, adopted in 2016, added a new chapter to the Montreal Protocol by mandating a phasedown of HFCs. Unlike previous agreements that called for complete phase-outs, the Kigali Amendment aims to reduce HFC production and consumption gradually, targeting an 85% reduction by 2047. The U.S. is set to reach this goal even earlier, by 2036.
鈥淭he Kigali Amendment was a necessary shift,鈥� says Miller. “It addresses not just the ozone layer but also climate change by targeting greenhouse gases like HFCs. Our industry must evolve, and this phasedown sets the path forward.”
The U.S. Senate ratified the Kigali Amendment on September 21, 2022, and the President signed it on October 26, 2022. This commitment reflects the growing recognition of HFCs’ environmental impact, particularly their high GWP and role in global warming.
U.S. EPA SNAP Program and Allowable Refrigerants
In alignment with the Kigali Amendment, the U.S. Environmental Protection Agency (EPA) introduced the Significant New Alternatives Policy (SNAP) Program to promote lower-GWP refrigerants. Under SNAP Rule 23, the EPA approved the use of 鈥渓ower flammability鈥� A2L refrigerants for new residential and light commercial air conditioners and heat pumps. Refrigerants like R-454B and R-32 are now classified as acceptable under specific conditions.
鈥淭hese lower-GWP refrigerants are a huge step forward,鈥� Miller remarks. 鈥淏ut it鈥檚 important to note that they can鈥檛 be retrofitted into existing systems. This means we鈥檙e looking at new installations only, and that requires planning and investment from businesses.鈥�
In many states, adopting UL 60335-2-40 standards has enabled the use of split-system residential air conditioners with A2L refrigerants up to around four pounds. However, conflicts remain between SNAP use conditions and building code regulations, prompting the EPA to provide guidance aligning with the latest standards.
The AIM Act: A Legislative Framework for HFC Phasedown
The American Innovation and Manufacturing (AIM) Act, signed into law on December 27, 2020, gives the EPA authority to regulate HFCs, requiring an 85% reduction in HFC production and consumption over 15 years, consistent with Kigali goals. The AIM Act empowers the EPA to reduce HFCs by phasing down production, encouraging next-generation technologies, and minimizing emissions from equipment.
鈥淭he AIM Act is crucial for our industry,鈥� says Miller. 鈥淚t provides a structured approach to reduce HFC use and promote environmentally friendly alternatives. It鈥檚 more than just a mandate鈥攊t鈥檚 a road map for the future.鈥�
In December 2022, the EPA proposed restrictions on specific HFCs under the AIM Act鈥檚 Technology Transitions Rule, with the final rule published in the Federal Register on October 24, 2023. This rule outlines deadlines for selling and installing HFC-based products, with flexibility for service and maintenance.
Update on the Technology Transitions Rule
The Technology Transitions Rule includes provisions to ease the phasedown for manufacturers and consumers. Importantly, it allows existing systems to continue operating with original refrigerants until the end of their useful life. For new residential and commercial air conditioning systems, units manufactured or imported before January 1, 2025, can be installed until January 1, 2026.
In June 2024, an additional proposed rule extended this deadline to January 1, 2027, for Variable Refrigerant Flow (VRF) systems using HFCs with a GWP of 700 or higher, as long as they were manufactured or imported before January 1, 2026. “The phasedown can鈥檛 happen overnight,” Miller points out. “These extensions are critical for businesses to transition to compliant refrigerants without unnecessary disruption.”
Timeline for Split and VRF Systems
The EPA has set a timeline for split-system and multi-split systems, allowing the sell-through and installation of R-410A products until December 31, 2025. Importation of R-410A will cease on January 1, 2025, though some allowances for service will continue. Additionally, a restriction on R-410A outdoor units is expected from the Department of Energy in 2026.
For VRF and three-phase multi-split systems, the sell-through and installation deadline is expected to be December 31, 2026, pending EPA approval. “These timelines offer structure and clarity for everyone involved, from manufacturers to consumers,鈥� Miller notes.
The U.S. EPA and the HFC Transition
The AIM Act requires the EPA to regulate HFC phasedown alongside the Kigali Amendment鈥檚 goals. In 2022, the EPA implemented a 10% reduction in refrigerant supply, which increased to 40% in 2024. Additional equipment sector bans now enforce GWP limits, and the EPA plans to add HFCs to refrigerant management under Clean Air Act Section 608.
Miller emphasizes the significance of these measures: 鈥淲e鈥檙e seeing a comprehensive approach to reduce HFC reliance, setting an example for responsible refrigerant management and environmental accountability. This phasedown is ambitious but achievable.鈥�
Looking Forward: The Future of HFC Phasedown
The phasedown of HFCs represents a transformative shift for the HVAC and refrigeration sectors. By 2036, U.S. HFC consumption will have drastically declined, thanks to regulatory actions like the AIM Act, SNAP rules, and the Kigali Amendment. This transition is part of a global movement toward sustainable refrigerants that balance functionality with environmental responsibility.
鈥淭he future is about embracing these changes and moving toward greener alternatives,鈥� Miller concludes. 鈥淔or anyone in the HVAC industry or planning to upgrade equipment, staying informed is essential.鈥�
The phasedown of HFCs may pose challenges, but it鈥檚 achievable. As consumers and businesses adapt to efficient new refrigerants and technologies, they鈥檙e contributing to a sustainable future in air conditioning and refrigeration.
