In the Air - HRAI Industry News

Will Canada Update ODSHAR? New HFC Data Adds Uncertainty

HRAI has previously commented on Canada’s approach to reducing the consumption of hydrofluorocarbons (HFCs), which are greenhouse gases commonly used as refrigerants, like R-410A. Member perspectives can be found in previous articles about HRAI’s submission to ECCC’s review of ODSHAR and recent changes to the U.S. refrigerant rules and their implications for Canada.

Canada uses two principal regulatory tools to meet obligations under the Kigali Amendment to the Montreal Protocol, an international agreement that requires countries to reduce production and consumption of HFCs:

• progressively reducing the supply of new bulk HFCs through consumption allowances; and
• restricting the manufacture and import of certain products and equipment containing, or designed to contain, higher-GWP HFCs.

Both approaches are implemented through the federal Ozone-depleting Substances and Halocarbon Alternatives Regulations (ODSHAR).

In 2024, Environment and Climate Change Canada (ECCC) conducted a review of ODSHAR to determine whether the Regulations remain appropriate, effective and capable of achieving their intended objectives. The review considered the HFC phasedown, controls on products containing HFCs, emerging uses, regulatory alignment and administrative requirements.

ECCC indicated that possible recommendations could include maintaining the Regulations without changes, amending certain provisions, or replacing some or all of the Regulations with another instrument. ECCC also stated that it planned to publish the recommendation resulting from the review together with a brief summary of stakeholder feedback. That material has not yet been published.

Many HRAI members have anticipated that Canada would strengthen its product controls and more closely align them with the U.S. Environmental Protection Agency’s Technology Transitions requirements. Alignment would be particularly relevant for products manufactured for an integrated North American market, although recent U.S. amendments and compliance extensions would need to be considered carefully.

The UNEP Ozone Secretariat’s database now shows Canada’s HFC consumption for 2025. Canada reported consumption of approximately 8.34 million tonnes of CO₂ equivalent for 2025. This figure may be important for several reasons.

Source: UNEP Ozone Secretariat, Canada country data. Figures represent data reported under the Montreal Protocol and may be subject to subsequent revision.

First, this amount was well below the Montreal Protocol control limit for 2024–2028 of approximately 10.8 million tonnes of CO₂e. The transition by many manufacturers to lower-GWP refrigerants and equipment may be contributing to reduced demand for higher-GWP HFCs, without any changes to ODSHAR.

The next major step in Canada’s phasedown begins in 2029, when the control level falls to approximately 5.4 million tonnes CO₂e. Canada’s reported 2025 consumption level was 2.9 million tonnes above the limit that will apply beginning in 2029.

Nevertheless, this recent data may reduce the immediate pressure on ECCC to introduce updated product controls solely to remain below the current limit.

Until ECCC publishes the outcome of its review, HRAI recommends that members consider more than one possible regulatory scenario in their planning for 2027 and beyond. These scenarios should include both continued application of the existing Regulations and the possibility of future amendments establishing additional or lower GWP limits for HVACR equipment.

HRAI is still expecting ECCC to publish a summary of the 2024 ODSHAR consultation in the near future, so please watch for a follow-up on this subject.

For more information, please contact HRAI’s Director of Regulatory Affairs, Perry Chao, at pchao@hrai.ca or by phone at 647-547-5545.

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