Refrigerant Regulations: The Transition to Low GWP Solutions

This European Union F-Gas Regulation⁴ (EU 517/2014) aims to reduce emissions of fluorinated greenhouse gases (F-gases) in an accelerated timeline compared to that outlined in the Kigali Amendment. The regulation includes a multi-faceted approach to ensuring an overall reduction in emissions by:

• Implementing a quota system to manage HFCs in the EU market from 2015 on, phasing down to one-fifth of 2015 levels by 2030.
• Banning the use of certain high GWP F-gases in specific applications where lower environmental impact alternatives are available.
• Reducing emission of F-gases from existing equipment by requiring improved service practices such as leak checks and gas recovery at the end of the equipment's life.

AIM ACT Legislation

In December 2020 the American Innovation and Manufacturing act (AIM) was signed into US law with significant bipartisan support. The Aim Act creates the framework to grant the EPA the authority to begin the orderly nation-wide phase down of high global warming potential (GWP) hydrofluorocarbons (HFC). 

The Aim Act is expected to bring significant environmental and economic benefits including; 33,000 new jobs and the preservation of 138,4000 existing jobs, $38.8 billion in direct and indirect manufacturing output, and an improvement to the U.S trade balance in equipment and chemicals by $12.5 billion.

How the AIM Act grants authority to the EPA to regulate HFCs

• Grants authority to the EPA to phase down the production and consumption of HFCs over a 16- year period using an allowance allocation program; much like the way ozone-depleting substances were regulated under Title VI (the “Clean Air Act”).
• Authorizes the EPA to establish sector-based, use case restrictions by application to facilitate the transition to next-generation technologies. These use case restrictions would complement the broader production and consumption phase down. 
• Allows the EPA to establish standards for a Refrigerant Reclaim Program.

The AIM Act outlines a phase down schedule based on production and consumption levels from 2011-2013 as the baseline period. From the Baseline, the law outlines the following production and consumption phase down:

What the AIM Act Means for You?

• High-GWP products will be under new regulatory scrutiny 
• Price and availability of products will change through the phase down
• New refrigerants and system architectures will be entering the market to meet the new requirements 

What Can You Do?

• KEEP UP with industry news to make sure you understand the regulations as they develop
• CHECK your current equipment using HFCs and repair leaks in advance of upcoming HFC phase down measures. 
• PLAN for the phase down, with special attention to applications that require testing and validation processes
• EVALUATE your options for replacing High GWP HFCs with Low GWP HFC and HFO technologies
• REVIEW your current suppliers and ensure that they have the capacity and integrity to serve your future needs
• ASK FOR HELP Our local engineering teams are here to help you navigate the transition and evaluate next-generation options to support your business

Learn More About AIM Act

Significant New Alternatives Policy (SNAP)

Section 612 of the Clean Air Act of 1990 established the EPA's Significant New Alternatives Policy (SNAP) Program⁵ to identify and evaluate substitutes for ozone-depleting substances. The program includes some mandates that impact the use of different products and publishes lists of acceptable and unacceptable substitutes. These lists are continuously updated based on new findings. A complete list of approved solutions by application can be found at the following link: SNAP Substitutes by Sector | US EPA

State Regulations

Over the past several years, states around the US have started to implement regulations phasing down the use of higher GWP HFCs. States such as California, Washington, Vermont, and New York have either in progress or completed regulations that will impact future equipment purchase and service decisions. Chemours is committed to remaining engaged and providing the most up to date information on state regulations as they become available. Check out our one-page updates below or contact us today for more information on your particular application.

Increases in illegal activities can be a concern during a phasedown and when there is economic incentive, which occurred in the US with the prior chlorofluorocarbon (CFC) and hydrofluorocarbon (HCFC) phase-outs. Chemours is committed to working with industry and government agencies to ensure that regulations are implemented to support meeting climate goals, limit business disruptions, and ensure those entities operating legally are not penalized by illegal activities.

As an industry, we should work with the US EPA & Environment Canada, to uncover existing and identify new schemes that illegal operators may try to utilize during the HFC phasedown. Building the right regulatory framework along with diligent enforcement and harsh penalties for those companies and individuals that attempt to circumvent laws.

Chemours utilizes an anti-counterfeit program that includes holographic labels that customers can use to verify the cylinder is authentic Chemours product. The best way to safeguard against illegal and counterfeit products is to:

• Purchase products from a reputable distributor
• Closely examine the package prior to use
• Look for the key security features
• Confirm genuine product using Chemours’ authentication feature
• Report suspicious refrigerant offers (i.e., deals “too good to be true”) to authorities

Download our latest Illegal Refrigerant Fact Sheet to learn more about the disadvantages of illegal product and how you can help report suspected illegal activity.

To report possible violations of environmental laws and regulations, visit: https://echo.epa.gov/report-environmental-violations, or scan the QR code below.

Authenticate Your Refrigerant with a Quick Scan

The Japan Ozone Layer Protection Act⁷ introduced policy measures that expanded the scope of previous F-gas measures. The act shifted focus from F-gas recovery and destruction to include the whole lifecycle: manufacturing, maintenance, and leak checking. A separate regulation—the Act on Rational Use and Proper Management of Fluorocarbons, is specific to the emissions of CFCs, HCFCs, and HFCs. The Japanese laws also promote the use of low GWP options in designated products.

The December 2016 revision to this regulation enables Canada to meet its ongoing obligations under the Montreal Protocol. The most recent revision puts in place the framework for the HFC phasedown schedule adopted by the Kigali Amendment to the Montreal protocol. Regulations stipulate a permit system and CO₂ equivalent allocations, among others. Environment and Climate Change Canada⁸ has published five fact sheets to assist regulated entities with compliance.

The continued trafficking and sale of illegal hydrofluorocarbons (HFCs or F-gases) in the European Union (EU) is a significant concern since it undermines the EU’s climate goals, funds organized crime, and threatens small- and medium-sized businesses across the EU that have invested to comply with the law and supply legitimate refrigerants respecting the quota system.

To reduce F-gas emissions, in 2015 the EU adopted Regulation 517/2014, which seeks to progressively reduce the quantity of HFCs and drive the transition from high global warming potential (high-GWP) products to low-GWP alternatives. The regulation targets a 79% reduction of F-gas use by 2030, with the corollary effect of stimulating the transition to lower-GWP solutions.

Chemours supports the objectives of Regulation 517/2014 and continues to deliver non-ozone depleting, low-GWP refrigerant solutions to the industries we serve around the world. We are a member of the European FluoroCarbons Technical Committee (EFCTC), a sector group of the European Chemical Industry Council (Cefic), which provides vital information about the applications, safety, health, and environmental effects of HFCs and HFOs (hydrofluoroolefins), their next-gen, low-GWP replacements.

The EFCTC is engaged against the illegal trade of HFCs in the EU. We encourage you to join the effort to fight the illegal trade of HFCs in the EU by reporting suspicious or illegal offerings of HFCs via the EFCTC Action Line, or by joining the Pledge to #SayNoToIllegalHFCs. Together we can preserve our environment while driving the transition to low-GWP alternatives.

• Learn more about Illegal Trade of HFCs
• A Deep Dive into the HFC Trade
• Oxera Report Data
• Pledge to End the Illegal Trade of HFCs