Air Conditioning Industry Regulations

Most people associate the Montreal Protocol with phasing out ozone-depleting substances. The Montreal Protocol has also evaluated the global warming potential of HFCs for over a decade. In 2016, 197 countries met in Kigali, Rwanda and agreed on a global proposal to phase down HFCs.

The Kigali Amendment required ratification from at least 20 countries to take effect. A total of 174 countries have ratified it. As a result, the Kigali Amendment took effect for participating countries on January 1, 2019.

The American Innovation & Manufacturing Act (AIM Act) was signed into law in 2020. The AIM Act grants the federal government the authority to regulate HFC refrigerants in three primary ways through the Environmental Protection Agency (EPA).

1. Phasing down HFC supplies. The AIM Act reduces HFC production and consumption over a 15-year period. These supply-side restrictions began on January 1, 2022, with a 10% reduction in HFC production and consumption through 2023. Under the HFC phasedown schedule, an additional 30% reduction applies between 2024 and 2028, with 70% and 80% reductions required by 2029 and 2034, respectively. The phasedowns are expected to drive up the price of HFC refrigerants as supplies decrease. The phasedowns also signal the end of a high-GWP HFC era in HVAC.
2. Establishing sector-based approvals and HFC restrictions. These measures facilitate transitions to next-generation refrigerant technologies. HFC use restrictions would help specific sectors transition more quickly away from higher-GWP HFCs while providing additional flexibility for sectors that need more time. A key aspect of this effort is the EPA's authority to support demand for lower-GWP refrigerants by approving new alternatives under sector-based application guidelines.
3. Regulating HFC management. The AIM Act allows the EPA to establish standards for managing HFCs in servicing and repair, such as lowering leak rate thresholds and requiring proper recovery of "used" HFCs for purification and resale, also known as reclaim. These standards allow an efficient transition away from HFCs in line with the production and consumption reduction schedules.

With California taking a leadership role in environmental regulations, other U.S. Climate Alliance states have adopted a similar approach. The U.S. Climate Alliance shares a commitment to reducing SLCPs and HFCs and includes 23 states and Guam. Sixteen states have either adopted SNAP 20/21 into state law or regulation or are in the process of doing so.

To reduce the complexity of implementation, industry advocates have asked states to be consistent in how they adopt CARB's rules. These advocates include the Air-conditioning, Heating and Refrigeration Institute (AHRI) and the Natural Resources Defense Council (NRDC). From an HVAC perspective, these state rules prohibit chillers from using R-410A, R-134a and other higher-GWP fluids beginning January 1, 2024.

Meeting the targeted emissions reductions in California requires lower-GWP refrigerants. Many lower-GWP refrigerants, including hydrofluoroolefin (HFO), HFC and HFO/HFC blend refrigerants, are classified as A2L, or mildly flammable. The UL 60335-2-40 (4th edition) and ASHRAE 15 product and application standards have been updated for comfort cooling. The updates define charge limits and the mitigation required to limit the potential of a flammable event in case of a leak.

The UL 60335-2-40 (4th edition) and ASHRAE 15 safety standards will serve as the bases for codes that govern building, fire and other local authorities having jurisdiction (AHJ), who will ultimately oversee the applications in which these refrigerants are used.

Building codes vary from state to state. As a result, the adoption of flammable refrigerants takes place at the local level and may take years to accomplish.