IIAR

The International Institute of All-Natural Refrigeration’s Education Committee announced that it has finalized the creation of a one-pager fact sheet regarding the AIM Act phasedown, to quickly illustrate the scope of refrigerants currently being used, based on their global warming potential.

The IIAR AIM Act Fact Sheet can be downloaded as a PDF from the IIAR AIM Act website: What is the AIM Act? (iiar.org)

The one-pager fact sheet lists 33 refrigerants by GWP relative to EPA limits across four categories: all natural refrigerants; HFO refrigerants; HFC/HFO blends; and HFC refrigerants.

The AIM Act was enacted in 2020, and while it is the primary vehicle for phasing down the production and consumption of listed HFC’s as well as the vehicle for managing these HFC’s and their substitutes, other regulations may be on the horizon that could further restrict the use of these refrigerants.

A growing number of states and federal regulatory agencies are examining the effects of perfluoroalkyl substances, known as PFAS, and regulatory frameworks are evolving alongside the HFC phaseout, due to concerns over their persistence in the environment and potential health impacts.

PFAS have been incorporated into some refrigerants to enhance their stability and performance, and the refrigeration industry is still awaiting clarity on which refrigerants will be designated as PFAS in the U.S.

According to the North American Sustainable Refrigeration Council, regulations do already exist at the state level, with more than 30 states having introduced or adopted regulations related to PFAS. Until recently, refrigerants were not at the forefront of those discussions, but that is starting to change, adding PFAS regulations to the mix of potential future restrictions on HFCs.

Meanwhile, industry experts believe PFAS classifications could have a direct impact on refrigerants, including the synthetic alternatives coming to the table.

The U.S. Environmental Protection Agency has rolled out several requirements limiting PFAS, including a record-keeping and reporting rule under the Toxic Substances Control Act (TSCA).

Under the EPA requirement, any entities, including small entities, that have manufactured, including imported, PFAS in any year since 2011 will have to report PFAS data to EPA beginning in November 2024. Small manufacturers will have to begin reporting in November 2025. Under this rule, there are civil penalties and criminal prosecutions that can be levied against those who fail to report.

Under the TSCA rule, there is no minimum reporting requirement, so even trace amounts of PFAs are still under scope for reporting.

For more information on PFAS and the potential future classification of refrigerants as PFAS, see the Condenser article “States, Regulatory Agencies Focus on PFAS.”

For more information on the AIM Act and to view IIAR’s information on the AIM Act phasedown and resources available, visit: https://www.iiar.org/IIAR/IIAR/Government_and_Code/What_is_the_AIM_Act.aspx