HFC Phasedown
The HVACR industry is now in the third year of the HFC phasedown and is now under a 40 percent decrease in the production and import of HFC refrigerants. HFC refrigerants are commonly used in air-conditioning and refrigeration, and the largest transition in this phasedown will begin this year by shifting equipment from using high-GWP refrigerants to low-GWP replacements. While this transition will be similar to the phaseout of R-22 and ozone-depleting refrigerants, this transition will also come with additional challenges that the industry must prepare for.
Quick links:
HFC Phasedown Content
What it's all about:
The American Innovation and Manufacturing Act sets up a 15-year phase-down (See Figure 1) in the production and consumption of HFCs until only 15 percent of the baseline remains. This will allow consumers to keep operating their equipment, while future equipment installations will use newer low-GWP refrigerants.
Figure 1: Phasedown of the production and consumption of all HFC products, including refrigerants
Unlike the R-22 phaseout, the HFC phase-down does not limit how many pounds of refrigerant are produced yearly. Instead, the phase-down uses “Exchange Value equivalents” (EVe) to provide allocations for companies to import or produce HFCs. EVes are the same as GWP or Global Warming Potential measurement commonly used to describe refrigerants. By reducing the number of EVes allowed to be produced or imported in a given year, the industry will move to lower GWP refrigerants to meet demand.
Figure 2: Comparing GWPs of current and future refrigerants
Product manufacturing cut-off dates
Subsector | Product | Global Warming Potential Limit or Prohibited Substances | Manufacture and Import Compliance Date[1] |
Stationary residential and light commercial air conditioning and heat pumps (e.g., window units, portable room air conditioning) | Stationary residential and light commercial air conditioning and heat pumps (e.g., window units, portable room air conditioning) | 700 | January 1, 2025 |
Residential dehumidifiers | Residential dehumidifiers | 700 | January 1, 2025 |
Household refrigerators and freezers | Household refrigerators and freezers | 150 | January 1, 2025 |
Vending machines | Vending machines | 150 | January 1, 2025 |
Chillers (as a stand-alone product) | Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) | Not covered | Not covered |
Chillers (as a stand-alone product) | Industrial process refrigeration with exiting fluid greater than or equal to -50 °C (-58 °F) and less than -30 °C (-22 °F) | 700 | January 1, 2028 |
Chillers (as a stand-alone product) | Industrial process refrigeration with exiting fluid equal to or above -30 °C (-22 °F) | 700 | January 1, 2026 |
Chillers (as a stand-alone product) | Comfort cooling | 700 | January 1, 2025 |
Chillers (as a stand-alone product) | Ice rinks | 700 | January 1, 2025 |
Data centers, computer room air conditioning, and information technology equipment cooling | Data centers, computer room air conditioning, and information technology equipment cooling | 700 | January 1, 2027 |
Industrial process refrigeration (not using chillers) | With refrigerant entering the evaporator below -50 °C (-58 °F) | Not covered | Not covered |
Industrial process refrigeration (not using chillers) | With refrigerant entering the evaporator equal to or above -50 °C (-58 °F) and less than -30 °C (-22 °F) | 700 | January 1, 2028 |
Industrial process refrigeration (not using chillers) | High temperature side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -30 °C (-22 °F) | 150 | January 1, 2026 |
Retail food - refrigeration stand-alone units | Retail food - refrigeration stand-alone units | 150 | January 1, 2025 |
Retail food - refrigerated food processing and dispensing equipment | 500 g of refrigerant or less and outside scope of UL 621, edition 7 | 150 | January 1, 2027 |
Retail food - refrigerated food processing and dispensing equipment | More than 500 g of refrigerant and outside scope of UL 621, edition 7 | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 | January 1, 2027 |
Self-contained automatic commercial ice machines | Batch type: harvest rate <=1,000 lb ice per 24 hours | 150 | January 1, 2026 |
Self-contained automatic commercial ice machines | Continuous type: harvest rate <=1,200 lb ice per 24 hours | 150 | January 1, 2026 |
Self-contained automatic commercial ice machines | Batch type: harvest rate above 1,000 lb ice per 24 hours | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-442A, R-507, R-507A, HFC-134a, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, G2018C, Freeze 12 | January 1, 2027 |
Self-contained automatic commercial ice machines | Continuous type: harvest rate above 1,200 lb ice per 24 hours | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-442A, R-507, R-507A, HFC-134a, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, G2018C, Freeze 12 | January 1, 2027 |
Cold storage warehouses | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Cold storage warehouses | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Cold storage warehouses | High temperature side of cascade system | 300 | January 1, 2026 |
System install deadlines by end-use
Subsector | System | Global Warming Potential Limit or Prohibited Substances | Installation Compliance Date [5] |
Stationary residential and light commercial air conditioning and heat pumps | Residential and light commercial air conditioning and heat pump systems (e.g., mini-splits, unitary systems) | 700 | January 1, 2026 |
Stationary air conditioning and heat pumps | Variable refrigerant flow systems | 700 | January 1, 2026 |
Chillers | Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) | Not covered | Not covered |
Chillers | Industrial process refrigeration with exiting fluid from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Chillers | Industrial process refrigeration with exiting fluid above -30 °C (-22 °F) | 700 | January 1, 2026 |
Chillers | Comfort cooling | 700 | January 1, 2025 |
Ice rinks | Ice rinks | 700 | January 1, 2025 |
Data centers, computer room air conditioning, and information technology equipment cooling | Data centers, computer room air conditioning, and information technology equipment cooling | 700 | January 1, 2027 |
Industrial process refrigeration (not using chillers) | With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 150 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | High temperature side of cascade systems and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator below -50 °C (-58 °F) | Not covered | Not covered |
Cold storage warehouses | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Cold storage warehouses | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Cold storage warehouses | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - supermarkets | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2027 |
Retail food - supermarkets | With less than 200 lb refrigerant charge | 300 | January 1, 2027 |
Retail food - supermarkets | High temperature side of cascade systems | 300 | January 1, 2027 |
Retail food - remote condensing units | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Retail food - remote condensing units | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Retail food - remote condensing units | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - remote refrigerated food processing and dispensing equipment | Retail food - remote refrigerated food processing and dispensing equipment | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 | January 1, 2027 |
Remote automatic commercial ice machines | Remote automatic commercial ice machines | R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 | January 1, 2027 |
Fire Code Refrigerant Storage by Amount
Current Storage Amount | Major Action Item |
Less than 20,000lbs | Storage height limited without proper sprinkler density |
20,000-40,000lbs | Sprinkler density must meet the minimum standard |
40,000-160,000lbs | Build “control areas” to store refrigerant |
>160,000lbs | Additional “fire wall” required |
Safe Refrigerant Transition Task Force
To help make the transition as smooth as possible, HARDI and the other HVACR trade associations have come together to participate in the Safe Refrigerant Transition Task Force.
This task force is designed to identify areas of concern, educate the industry on solutions in training, transportation, storage, reclaim, and safety standards, and conduct outreach to the fire service and other interested parties.
The task force has identified five major areas that must be addressed before the industry can fully transition to A2L refrigerants:
Adopting building codes to allow A2L equipment to be installed in homes and businesses
Adoption of regulations identifying A2Ls for transportation and storage
Increasing allowable storage limits for A2L gases stored in cylinders in warehouses and other facilities
Training contractors and technicians for certification to future EPA regulations
Increasing recovery and reclaim to ease the transition for legacy equipment using current HFC refrigerants
Addressing these five areas will significantly ease the transition to A2L refrigerants and make it easier for the industry to help the US meet its 2036 phase-down goal.
