HRAI Submission to ODSHAR Consultation

Environment and Climate Change Canada (ECCC) agreed with HRAI’s suggestion to move its review of Ozone-Depleting Substances and Halocarbon Alternatives Regulations (ODSHAR) ahead by three years in light of technological advancements and regulatory developments.  

HRAI provided submissions to ECCC’s consultation process in April 2024, and also worked with members of the Joint Working Group for Refrigerant Transition to develop a response that was submitted to ECCC on August 8, 2024. This submission included member recommendations for: 

  • Overall consistency with the US EPA Technology Transitions Rule 

  • Treatment of used, recovered, reclaimed HFCs 

  • Factors for transferring HFC allowances 

  • Product types without alternatives to HFCs 

  • Barriers to very-low GWP alternatives 

  • Guidance on product definitions 

HRAI’s submission can be accessed through the following link

ECCC is expected to review comments received during this consultation stage, with recommendations and a summary of stakeholder feedback to be published on its Regulatory stock review plan website, available at the following link: https://www.canada.ca/en/environment-climate-change/corporate/transparency/acts-regulations/regulatory-stock-review-plan/2019-2029.html 

If you have any questions or suggestions, please contact Perry Chao, Director of Regulatory Affairs at HRAI, 1-800-267-2231 or 1-905-602-4700 ext. 250 or at pchao@hrai.ca. 

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