U.S. EPA Publishes Final Technology Transitions Rule
On October 5, 2023, the U.S. Environmental Protection Agency published its Technology Transition Rule under the AIM Act, consistent with the Kigali Amendment to the Montreal Protocol, of which Canada is a signatory.
The intent of this final ruling is to address the production and consumption of hydrofluorocarbons (HFCs) by (1) a phasedown schedule; (2) implementing regulations that maximize reclamation and minimize releases of HFCs from equipment; (3) facilitating the transition to next-generation technologies through sector-based restrictions.
Beginning January 1, 2025, the U.S. EPA’s Technology Transition Rule will prohibit the manufacture and import of products that contain high-global warming potential HFCs followed by a prohibition on the sale, distribution, and export of those products three years after the manufacture and import restrictions take effect.
While the manufacture and import compliance dates for residential and light commercial air conditioners and heat pumps is January 1, 2025, the compliance date for variable refrigerant flow systems is January 1, 2026.
For all other products, including chillers, members can click the link above or visit the EPA’s website, which allows you to easily access the tables and the HFC restrictions by sector.
It will also prohibit the installation of new refrigeration, air conditioning, and heat pump systems that use high-GWP HFCs. However, components needed to repair legacy refrigeration, air conditioning, and heat pump equipment may continue to be manufactured, imported, sold, distributed, or exported.
For members who may not be aware, the phasedown schedule in the U.S. is as follows:
Thus, most of the HFC phasedown in the U.S. will occur within the next six years. In Canada, while we are on track to meet our HFC phasedown targets by 2036, this is primarily being accomplished through reductions in the automotive and foam sectors, not the HVACR sector.
However, what exactly does this final ruling mean for the Canadian HVACR market? How does it impact industry?
By accelerating the transition to next-generation technologies to phase out the production and consumption of high-GWP HFCs, manufacturers are retooling their factories to produce A2L refrigerants, which are characterized by their mild flammability, low toxicity, and overall low global warming potential.
While our members are ready for the transition to A2L refrigerants, under the current CSA B52 Mechanical Refrigeration Code, you cannot install or retrofit existing equipment with A2L-charged equipment. This includes residential and commercial applications as well as new home construction.
To address this challenge and avoid a potential supply chain issue, HRAI and AHRI formed a joint working group composed of industry experts to develop and implement a strategy to permit the installation of A2L-charged equipment in all applications and in all jurisdictions prior to January 1, 2025.
The 13th Edition of the CSA B52 Mechanical Refrigeration Code, which we’re expecting to be released December 2023 or January 2024 at the very latest, will allow the installation of A2L-charged equipment.
This joint working group is working diligently with both provincial and national building code officials to ensure the next edition is adopted before the U.S. EPA’s manufacture and compliance dates take effect.
Earlier this week, members from AHRI’s Unitary Regulatory Committee and at an AHRI conference call on the Technology Transitions Rule raised several concerns over the EPA’s final ruling and its impact on the distribution chain.
We will clarify these concerns as soon as possible and will provide members regular updates on our progress to ensure this refrigerant transition goes as smooth as possible for the HVACR industry.
Please stay tuned for a coming webinar announcement on the refrigerant transition in Canada, the EPA’s Technology Transitions Rule, and the actions HRAI is taking to ensure the timely adoption of the next edition of the CSA B52 Mechanical Refrigeration Code before January 1, 2025.
If you have any questions or concerns, contact Stephen Chartrand at 1-800-267-2231 ext. 276 or email schartrand@hrai.ca.
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