Federal action will make it unlikely that individual states pass their own HFC phase-down regulations and cause confusion in the HVACR industry. Several states have pledged to regulate HFCs due to the lack of federal regulations. The states that have expressed interest in phasing down HFCs include California, Connecticut, Maryland, New Jersey, New York, North Carolina, Vermont, and Washington. We do not expect any new state actions for the remainder of the year.

HARDI has been tracking the progress of legislation and regulations in the states. So far California, Delaware, Maryland, Massachusetts, New York, Washington, and Vermont have specific proposals, which are based on EPA’s SNAP Rule 20 and Rule 21. Other states have not advanced any specific policy proposals. Below is a summary of state actions:


Adopted EPA SNAP Rules 20 and 21 in 2018 which impacted foams, aerosols, chillers (in 2024), domestic appliances and some commercial refrigeration products exactly as noted in the EPA’s Rules. Their overall goal is a reduction in HFC emissions of 40 percent by 2030 using 2013 as a baseline. This more ambitious commitment has led California to start drafting rules beyond the SNAP program which will impact additional commercial refrigeration sectors and air conditioning. HARDI is actively working with CARB officials on the rule making process. CARB is expected to complete their rulemaking to limit commercial refrigeration and stationary air-conditioning by the end of the year.

For stationary refrigeration with more than 50 lbs of refrigerant, all new facilities must use equipment with refrigerant below 150 GWP starting January 1, 2022. For existing facilities the rules vary by end-use. For example, existing supermarket chains have options for reducing emissions from stationary refrigerating equipment. See CARB presentation for additional details on end-use limits.

For stationary air conditioning, CARB’s current proposal would limit all new equipment sales after January 1, 2023 to using refrigerant below 750 GWP. Most current replacement refrigerants below this GWP limit are A2L (lower flammability) and require changes to the building, fire, and mechanical codes for installation and storage and finalizing planned updates to DOT and OSHA regulations.

CARB hosted a webinar on July 22, 2020 with the latest proposal. Slides from this webinar are available here

HARDI is working with industry allies on an alternative proposal for stationary refrigeration, for more information please contact HARDI Director of Government Affairs Alex Ayers (aayers@hardinet.org)


The Colorado Air Quality Commission approved a rule following EPA’s SNAP 20 and 21 on May 22, 2020. The rule can be seen here.


Has announced intent to regulate HFCs.


Has passed the House Concurrent Resolution NO. 60 in support of the Natural Resources and Environmental Control (DNREC) to enact regulation that will phasedown the use of HFCs in Delaware. Additional information on the upcoming regulation can be found on DNREC’s rulemaking website.


Introduced legislation (HB 2492 and SB 3078) to implement SNAP 20 and 21.


The state has announced they intend to adopt an HFC phasedown.


Maryland has started the regulator process to adopt SNAP rules 20 and 21 with the intent to begin regulating HFCs in 2021 for stationary refrigeration and 2024 for chillers. Additional information on the upcoming regulation can be found on MDE’s website.


Massachusetts has started the regulatory process to regulate the HFC refrigerants listed in SNAP 20 and 21 and similar to Delaware and Maryland, plans to use dates that regulate refrigeration beginning in 2021 and chillers in 2024. In addition to adopting SNAP 20 and 21, Massachusetts is looking at implementing a refrigerant management program which would require additional disclosure of refrigerant sales by distributors and require all technicians to obtain a Section 608 refrigerant certification.

New Jersey

Has passed SB 3919 to adopt SNAP rules 20 and 21 to phase down the use of HFCs in specific end use areas.

New York

Regulators have announced a rulemaking process adopting the SNAP Rules with a delay.


The state has announced they intend to adopt an HFC phasedown.


The state has announced they intend to adopt an HFC phasedown.

Rhode Island

The state has announced they intend to adopt an HFC phasedown.


The Vermont Senate passed S. 30 on March 21, 2019 and the bill is currently awaiting action in the House. The legislation that would adopt SNAP Rules 20 and 21 with the goal of reducing the use of HFCs by 40 percent by 2030 using 2013 as a baseline.


The Virginia legislature included a requirement for the Air Pollution Control Board to adopt an HFC phasedown in their annual budget that was signed by Governor Northam.


Has passed legislation (House Bill 1112) that would adopt SNAP Rules 20 and 21 to meet the Governor’s goal of reducing GHG emissions of 25% by 2035. State regulators are now working on rules for disclosure of equipment containing HFCs and disclosure requirements. In addition, the WA Code Council has voted to fully adopt ASHRAE 15-2019 and the 3rd edition of UL 60335-2-40 which would allow for the use of flammable refrigerants in occupied buildings. Additional information can be found here.

EPA SNAP 20/21 Update

In 2015 and 2015 the EPA finalized Rule 20 and Rule 21 respectively that phased-down the use of HFCs and HFC blends because of their high global warming potential by delisting these refrigerants from the list of acceptable substitutes. This was the first time the EPA delisted a substance as acceptable instead of listing new substances that could be used to replace ozone depleting substances.

In 2017 the DC District Court overturned SNAP Rule 20. The courts determined the EPA exceeded its authority to regulate Ozone Depleting Substances (ODS) by banning the use of all HFCs regardless of what refrigerant was used in the equipment. Even though the rule was overturned by the district court, it remained in place until the Court of Appeals rejected a petition to review the case in 2018. The courts directed EPA to vacate the rule. Following the ruling HFCs are currently allowed to be used as alternatives to ODS substances. In early 2019 the court also ruled that SNAP Rule 21 did not have the authority to regulate HFCs and directed the EPA to also vacate rule 21.

The EPA plans to release an updated Rule 20 and 21. HARDI attended the EPA’s sector level stakeholder’s meeting to provide input on the best way to effectively regulate ODS. The court rulings have lead EPA to take a deep look at the methods used in the SNAP program and the industry is eagerly awaiting a proposed update to the rule.

EPA Section 608 Changes

In late 2018 the EPA released a proposed rule rolling back leak detection requirements on equipment using HFCs. In addition to this rollback, the EPA sought comments on ending the sales restriction for HFC refrigerants and some newer substitute refrigerants. HARDI submitted comments opposing any change to the sales restriction.
HARDI’s Comments