On October 5th, Environmental Protection Agency (EPA) Administrator Michael Regan signed the Final Rule Technology Transitions authorized under the American Innovation and Manufacturing Act designed to phase down hydrofluorocarbon (HFC) use. The AIM Act authorizes EPA to address HFCs in three main ways: (1) phasing down their production and consumption, (2) promulgating certain regulations for purposes of maximizing reclamation and minimizing releases of HFCs from equipment and ensuring the safety of technicians and consumers, and (3) facilitating the transition to next-generation technologies through sector-based restrictions.

The AIM Act included a process by which interested stakeholders could petition EPA to establish sector specific policies regarding the phase down of HFCs. IIAR submitted a petition to EPA recommending phase down policies related to the refrigeration sector. IIAR’s petition, along with petitions from several other groups, was granted by EPA in October 2021, triggering EPA to initiate a rulemaking process. The Final Technology Transitions Rule addresses IIAR’s petition and is largely consistent with the policies recommended by IIAR. The Final Technology Transitions Rule restricts the use of higher-GWP HFCs in new aerosol, foam, and refrigeration, air conditioning, and heat pump (RACHP) products and equipment. EPA has listed entities potentially impacted by the rule to include companies that manufacture, import, export, package, sell or otherwise distribute products that use or are intended to use HFCs, such as refrigeration and air-conditioning systems, heat pumps, foams, and aerosols.

The rule provides three mechanisms to restrict HFC use:

• Prohibiting the manufacture and import of products that use higher-GWP HFCs
• Prohibiting the sale, distribution, and export of those products three years after the manufacture and import restriction
• Prohibiting the installation of new RACHP systems that use O higher-GWP HFCs.

In most subsectors EPA has set a maximum GWP limit on HFCs or HFC blends that can be used. In a few subsectors, such as some transportation applications, EPA has listed the specific HFCs or HFC blends that are restricted. Restrictions begin for many categories on January 1, 2025, with the latest restrictions going into place on January 1, 2028.

The chart below displays provisions for selected subsectors covered by the rule.

It is important to note that this rule does not restrict the continued use of any existing products or RACHP systems. EPA has stated that allowing existing systems to continue to operate to the end of their useful life is important to ensuring a smooth transition in the phasedown of HFCs. The rule clarifies that a product or system may be serviced and repaired throughout its useful life; this includes replacing components, as needed. Components needed to repair existing RACHP equipment may continue to be manufactured, imported, sold, distributed, or exported.

In the rule, EPA defines the distinction between maintenance of a system and installation of a new system. Specifically, the following actions, upon charging the system to full charge, are considered a new installation of a RACHP system and thus subject to the relevant HFC use restrictions:

Assembling a system for the first time from used or new components

Increasing the cooling capacity, in BTU per hour, of an existing system Replacing 75 percent or more of evaporators (by number) and 100 percent of the compressor racks, condensers, and connected evaporator loads of an existing system.

Continued implementation of the AIM Act should provide additional opportunities to expand usage of natural refrigerants. IIAR members are encouraged to familiarize themselves with the rule and EPA’s other policies related to HFCs. Additional information on the Technology Transitions rule and the AIM Act can be found on the EPA website at: https://www.epa.gov/climate-hfcs-reduction.