HFC PGA Message Set, Allocation Reduction Set to Take Effect January 2024, EPA Officials Say

A new partner government agency message set isn’t the only thing coming at the beginning of 2024 for hydrofluorocarbon imports. On that date, EPA also will be rolling out much reduced allocations for HFC importers, increasing scrutiny on importers, EPA officials said on a webinar Nov. 14.

While allocations have been set around 90% of historic levels since EPA’s HFC quota system took effect in 2022, at the beginning of 2024 new allocations will represent only 60% of baseline levels, said Pete Rodrigue, an EPA environmental policy analyst. “It’s more important than ever that people fill out these import filings correctly,” he said.

Rodrigue reminded participants on the webinar of recent changes to filing timelines for reporting of bulk HFC imports. While EPA previously had required that HFC data elements be filed 14 days prior to a shipment’s arrival, that has now been cut to 10 days for ocean vessels, and five days for all other modes. That change took effect Sept. 18 under a final rule issued by EPA in July.

He also reminded importers that there is no de minimis for bulk HFC, and even small shipments require a filing. “There is no de minimis amount in this program,” Rodrigue said, noting that it’s a “common point of confusion.” Even a five pound sample of HFCs requires allowances and a filing.

In response to an audience question, Rodrigue said bulk HFC shipments that are approved but then arrive prior to the 10-day or five-day window are allowed to leave the port, as long as the shipment has been given a “may proceed.”

Once the filing is submitted for a shipment, corrections are possible, but only within a limited time, EPA’s Roy Chaudet said, also in response to a question. “Timing is really important,” he said. There’s a time limit on corrections after arrival, and “the answer is probably going to be 'no' beyond that time limit,” he said. But ”prior to arrival, prior to the filing data, corrections will be used and accommodated,” Chaudet said.