EPA Finalizes Bans on HFCs in Imported Products, Including HVAC, Cars, Starting in 2025

EPA is finalizing new regulations banning the use of certain hydrofluorocarbons with a high global warming potential in imported and newly manufactured aerosol, foam, refrigeration, air conditioning and heat pump products. The bans take effect between 2025 and 2028, depending on the product.

The agency’s Oct. 24 final rule sets maximum global warming potential limits on HFCs or HFC blends in over 50 products ranging from vending machines to automobile air conditioning systems, and residential air conditioners to data center cooling systems. For some products, the regulations ban specific HFCs and HFC blends.

The rule also bans the sale, distribution and exportation of these products three years after their manufacture and import restriction takes effect (i.e., sometime between 2028 and 2031, depending on the product). EPA is also setting labeling and recordkeeping requirements beginning on the effective date of the manufacture and import restriction (i.e., between 2025 and 2028, depending on the product).

The restrictions do not apply to components that are used to repair existing refrigeration, air conditioning and heat pump systems, which may continue to be imported, manufactured, sold and exported, EPA said in a fact sheet on the rule.

The final rule’s labeling requirements apply to all aerosols, foams and refrigeration, air conditioning and heat pump products that continue to use an HFC after the relevant product’s effective date between 2025 and 2028. “The label must indicate the HFC being used along with other information, including date of manufacture for products and components,” EPA said. New refrigeration, air conditioning and heat pump replacement components using higher-global warming potential HFCs “must have a label indicating they are for servicing existing equipment only,” EPA said in the fact sheet.

EPA also will require annual online reporting from manufacturers and importers of “products and specified components” of refrigeration, air conditioning and heat pump equipment covered by the final rule, beginning for all covered sectors and subsectors for calendar year 2025 data.

“Reports are due to EPA 90 days after the end of each calendar year,” the agency said in the final rule. “Thus, the first reports submitted by manufacturers and importers under this rule will be due March 31, 2026. EPA intends to conduct a series of trainings and stakeholder outreach as we plan for implementation of the reporting provisions,” it said.

The restrictions set by the final rule “apply equally to domestically manufactured and imported products and the restrictions on import and manufacture of new products containing higher-GWP HFCs take effect on the same dates,” EPA said. “Products restricted under this rule from using certain HFCs cannot be manufactured in the U.S. and then exported.”

Some products or systems are exempt from the rule, including metered dose inhalers, defense sprays, polyurethane foam for marine and trailer use, semiconductor manufacturing, mission-critical military end uses and onboard aerospace fire suppression, the fact sheet said.

EPA’s final rule comes amid a flurry of recent activity from EPA as the agency works to implement the American Innovation and Manufacturing Act, which requires a phasedown in HFC production and consumption to 30% of historical levels by 2029, and 15% by 2036.

One proposed rule issued last week would set requirements for leak repair and leak detection systems for equipment using HFCs, and would address uses of recycled HFCs in fire suppression equipment, including through registration, reporting and recordkeeping requirements for importers. It also would set conditions for the recovery of HFCs from cylinders and container tracking requirements.

Another proposal issued last week would establish recordkeeping and reporting requirements for uses of ozone-depleting substances as process agents. Comments on those proposed rules are due Dec. 18 and Dec. 4, respectively.

And EPA also set 2024 allowances for production and consumption of HFCs in a notice issued last week. The notice listed application-specific allowances for various companies and applications, as well as production allowances and consumption allowances. It also announced “administrative consequences” in the form of reducing some companies’ 2023 and 2024 allowances for importing HFCs in excess of their 2023 allocations, among other reasons.