EPA Finalizes New Restrictions in Ongoing HFC Phasedown

On October 24, 2023, the Environmental Protection Agency (EPA) issued final regulations to implement certain provisions of the American Innovation and Manufacturing Act of 2020 (AIM Act). The AIM Act authorizes EPA to address the environmental impacts of hydrofluorocarbons in several ways. This rulemaking is designed to facilitate the transition to next-generation technologies by restricting use of HFCs in the sectors or subsectors.

This final rule restricts the use of HFCs, whether neat or used in a blend, with high global warming potentials (GWPs) within the refrigeration, air conditioning, and heat pump, foam, and aerosol sectors. This final rule also prohibits the manufacture, import, or installation of certain equipment across approximately 40 subsectors, either based on overall GWP limits or restrictions on use of specific HFCs. The compliance dates for these restrictions vary depending on the subsector ranging from January 1, 2025, to January 1, 2028. The final rule prohibits the sale, distribution, and export of factory completed products that do not comply with the relevant restrictions three years after the prohibition on manufacture and import.

While the benefits of this rule may vary significantly, depending on the mix and timing of industry transitions made to achieve compliance in affected subsectors, EPA projects that this rule will yield incremental emission reductions ranging from 83 to 876 million metric tons of carbon dioxide equivalent (MMTCO₂ e) through 2050. This rule will go into effect on December 26, 2023.