Regulatory drivers in North America affecting HVAC-R

The technology transition to low Global Warming Potential (GWP) refrigerants in the refrigeration, chillers, air conditioning and heat pump applications around the world is driven by the HFC phasedown mandated by the Kigali Amendment to the Montreal Protocol, as well as electrification efforts and ever lower energy efficiency standards.

The phasedown is also happening in the United States, even though the US government has still not ratified the Kigali Amendment, and driven by legislation known as the AIM Act.
The US Environmental Protection Agency’s (EPA) implementation of the AIM Act is unique, and consists of 3 major pillars – allocations of allowances for production and consumption of HFCs, sector use restrictions, and reclaim.

The implementation began in 2022 with the first distribution of allowances, which are issued annually. EPA has also received a number of petitions addressing sector controls, most of which have been granted and are likely to go into effect towards the end of 2023, or later. Furthermore, EPA is proposing new rulemaking starting in 2024 that is being written now.

These new rules could further change the allowances available to producers and importers just as the next phasedown step occurs. A significant number of individual US states have their own regulations, which are not always consistent with EPA and each other.
Another challenge is the adaptation of new building codes allowing flammable refrigerants to be used in residential and institutional facilities. We will attempt to deconstruct this confusion by explaining what is happening and what we should be expecting.