HFC Phase Out Continues Amid Uncertainty Over Regulations

Refrigeration industry end users are continuing to phase out ozone-depleting and high-global-warming-potential refrigerants to comply with regulatory requirements and proactively address environmental needs, but a lack of concrete direction from the federal government has resulted in uncertainty as well as a patchwork of state-by-state efforts.

efforts. “There is no consistent approach or timeframe for retailers preparing for the hydrofluorocarbon (HFC) phaseout, due in large part to the fact that there has been a lack of regulatory consistency at the Federal level,” said Danielle Wright, executive director of the North American Sustainable Refrigeration Council.

What’s more, the current administration has made several changes from the previous administration, and the U.S. did not ratify the Kigali amendment, which establishes multiple legally binding schedules for participating countries to cap and phase down the use of HFCs in favor of alternatives with lower global warming potential, said Tristam Coffin, president of Livingstone Consulting and the former director of sustainability and facilities for Whole Foods.

for Whole Foods. “I think everyone is trying to navigate what seems to be quite the mixup of different regulatory environments globally, nationally and at the state level,” Coffin said.

said. If the Kigali amendment is ratified, Coffin said there would be a quick move toward the need for low GWP solutions. “A number of countries have already signed onto the Kigali amendment. In the U.S. it is administrationdriven. If we see another four years with the current administration, I’m not sure, based on past precedent, it will happen,” Coffin said.

Although there hasn’t been any commitment or rejection of Kigali federally, Caleb Nelson, vice president for Azane Inc., said refrigerant regulation continues to be the primary focus in efforts to curb greenhouse gas emissions globally.


In April, a federal appeals court restored a federal prohibition on switching to HFCs from ozone-depleting substances in large refrigeration systems, such as those in supermarkets and industrial process.

“The U.S. EPA SNAP [Significant New Alternatives Policy] rules that banned high-GWP HFCs as replacements for Ozone Depleting Substances in supermarkets were initially vacated by the D.C. Circuit Court of Appeals decision, and now just recently were partially restored again,” Wright said. “While most retailers have been moving away from the high-GWP HFCs anyways, this inconsistency from the Federal government causes uncertainty for retailers.”

According to the court ruling, the Environmental Protection Agency acted illegally in 2018 when the agency suspended limits on the uses of HFCs, following a 2017 ruling by the same court.

As part of its earlier 2017 ruling, the court said that EPA’s 2015 Rule 20 prohibiting the use of high-GWP HFCs in certain applications could not be applied to systems that had already switched to HFCs. The court allowed the EPA to continue prohibiting end users still using ozone depleting substances, notably R22, from moving to HFCs. However, the EPA later issued guidance abandoning any prohibition on HFCs.

abandoning any prohibition on HFCs. Peter DeMarco, an attorney for the Natural Resources Defense Council, said the decision was an important victory for the climate. “The court’s decision restores common-sense restrictions on HFC use that EPA had illegally removed. EPA must ensure that as companies complete their transition away from ozone-depleting substances, they switch to alternatives safer than climatepolluting HFCs,” he said.

Since the EPA issued its guidance abandoning HFC regulations in 2018, several U.S. states have adopted SNAP Rules 20 and 21.


“Approximately a dozen states are pursuing HFC legislation, and they all seem to be following California’s lead,” Nelson said. “In many cases, the targets that are being set will require more than marginal steps in GHG reduction from one type of HFC to another. They will require some use of natural refrigerants to meet their aggressive goals,” Nelson said.

The U.S. Climate Alliance states have been working to backstop the vacated SNAP rules, but this also creates slight variations in timing that make it challenging for national chain retailers to implement a consistent approach, NASRC’s Wright said.


The industry has gained experience through the phaseout of R22. “As of Jan. 1, 2020, the production and import of R22 have been halted in the U.S.,” Wright said, adding that the price per pound has increased by at least 300 percent in the last decade and will only increase further as the supply decreases. “The challenge is the shortage of service workforce and the limited time window in the year to complete the retrofit.”

Several companies approached the R-22 phaseout proactively, Coffin said. “I think that is because there was more clarity at the point it went into effect.”

clarity at the point it went into effect.” Many companies went from R-22 to another synthetic refrigerant, such as 407A. “People weren’t necessarily thinking of the next phase of what might be coming,” Coffin said. “We got away from R-22 because of the ozonedepleting potential, but not thinking about the high global warming potential of alternatives. I think in a lot of ways, the industry did itself a disservice.”

Glenn Barrett, an engineering manager at D.C. Engineering, said the industry responded early and effectively to prepare for the elimination of R-22 and all HCFCs. New synthetic refrigerant options were developed for new applications to replace R-22 along with “retrofit” options for existing systems. “R-22 uses a different type of oil than the vast majority of synthetic ‘drop-in’ replacement refrigerants. This caused some trouble early, as retrofit specifications and best practices were still being developed,” he said, adding that the HCFC phaseout did somewhat prepare the commercial refrigeration industry to be able to retrofit high-GWP refrigerants to lower-GWP options.

As for the R-22 phaseout, Barrett said most commercial refrigeration end users acted early with designing new systems with synthetics or retrofitted most of their R-22 systems to a better option. “As for HFCs, without the pressure that would come from something similar to the yet-to-be-ratified Kigali amendment, it is generally understood that the industry will be relatively slow to react. The current time frames for action typically coincide with the EPA and state level codes and restrictions for use of HFCs and the associated compliance and reporting requirements,” Barrett said.

However, Nelson said there are still several users in need of conversion from R-22. “These systems are all basically near their end of life, and so owners are taking advantage of a full system replacement scope to consider ammonia and carbon dioxide as a future-proof solution,” Nelson said.

Coffin added that those that didn’t rush to get out of R-22 might be in a better position today to just gut the whole asset and move to a natural refrigerant. “If you managed to properly maintain your system, which is the most important part of refrigerant management, you can continue to utilize an asset that may be near its end life, then replace in full rather than retrofit,” he said.

For many retailers, the R-22 phaseout has been a long, painful and costly process. Some retailers transitioned from R-22 to high-GWP HFC refrigerants, “This has put them in a vulnerable position as future bans on high-GWP HFCs would force them to yet again retrofit to a lower GWP refrigerant,” Wright said. “The prospect of a continued cycle of refrigerant phaseouts is one reason some are turning to natural refrigerants as the ‘future-proof’ solution for regulatory compliance.”

Anyone still using R-22 is trying to get out of it as fast as possible, commented Wright.


End users are turning to synthetics as well as to natural refrigerants as they phase out HFCs. “The lion’s share of the refrigerant that needs to be dealt with is in existing systems. The challenges with existing systems and naturals is that naturals aren’t a drop-in substitute for synthetics,” Coffin said.

“When we look at the next phasedown, people are looking at a phaseout proof or regulatory-proof solution. They don’t want to continue going through this challenge every five years or so,” Coffin said. “Natural refrigerants are a phaseout-proof solution. In new stores, I think it is almost a nobrainer to be moving to naturals at this time.”

Wright of NASRC said the use of synthetics or natural refrigerants depends on the company’s long-term strategy and the location of the store. “For instance, in states like California, we are seeing many retailers choose natural refrigerants for new-store applications. For existing stores, the most common and cost-effective option is to retrofit to a hydrofluoroolefins (HFO) blend, such as R-448a or R-449a,” she said.

However, pure HFOs are not well suited for all applications, especially low-temperature applications which are common in frozen warehouses and many other industrial refrigeration applications, Nelson said.

“HFOs tend to have a very low volumetric capacity that requires very large compressors, and the systems often run in a vacuum when serving low-temperature loads. This can be problematic as the HFO oils also tend to be very hygroscopic — meaning they will absorb moisture from any air that gets into the system, which does not bode well for the reliability of the semihermetic compressor and its motor,” Nelson explained.

Companies also approach HFCs differently depending on whether it is a new or existing location, Barrett said. Approaches can range from ‘wait and see’ to the more proactive approach of retrofitting higher GWP refrigerants to lower GWP drop-in replacement refrigerants with their existing stores and remodels. “To go from synthetic refrigerants to natural refrigerants takes a different solution, different design and different considerations,” Barrett said.

Many new stores are moving toward lower refrigerant charge system designs, natural refrigerant systems and/or using lower GWP HFC options, Barrett said. He added that a lot of companies are using smaller charged systems with synthetic refrigerants or natural refrigerants such as propane with lower GWP ratings.

Coffin said he has been advocating for an all-of-the-above approach for existing facilities, including charge reduction and partial system replacements, going to naturals, if possible. “The futureproof solution is more of a complete overhaul, which is more costly and a bit more extraneous due to the effort to execute it, but it can be done modularly and/or in phases,” he said.

Natural refrigerants are gaining ground quickly, Barrett said. “The two most popular choices for natural refrigerants in commercial applications are CO2 (R-744) and propane (R-290) with CO2 providing great design options for larger, or central, refrigeration systems and propane filling the ‘micro’ and selfcontained refrigeration system market quite nicely,” Barrett said.

The commercial refrigeration industry has moved past the discovery phase for natural refrigerant use and is now entering the deployment phase, Barrett said. There are many viable and attractive CO2 and propane refrigerant solutions, and the advent of smaller ammonia and CO2 condensing units to the U.S. market will provide an additional option for remodels or retrofits where only a portion of the refrigeration system will be addressed, he explained.

“We have designed and provided ‘apples to apples’ type comparisons of natural refrigeration systems to typical HFC systems and found that the natural solutions can have a lower first cost and operational cost than what would be typically considered a standard HFC rack design,” Barrett said.

There are several benefits to a natural refrigerant system. “We’re finding that the cost of installing a CO2 system can be the same cost as a synthetic HFC or lower, and CO2 if done right can be more energy-efficient than HFCs,” Barrett said. “Also, the cost of the refrigerant itself in dollars per pound can be less with CO2 and other natural refrigerants.”

What’s more, natural refrigerants are future-proof. “You don’t have to worry that you’ll ever have to change it out,” Barrett said.