Refrigerant Regulations and Policies – 2019 Year-end Review

January 15, 2020
By Jeff Warther, National Training Manager, Chemours Refrigerants

As we enter 2020, the HVACR industry continues the transition to low-GWP refrigerants. As a point of reference, here’s an update of what was accomplished in 2019.

Kigali Amendment

The Kilgali Amendment is an amendment to the Montreal Protocol that was signed in 2016 in Kigali, Rwanda. The goal of the amendment is to reduce greenhouse emissions from HFC refrigerants through a phaseout process as shown in Figure 1. At the end of 2019, more than 90 countries had ratified the treaty, including Australia, Canada, the European Union, Japan and Mexico. To date, the United States has yet to ratify the amendment, leaving American jobs at risk in the world market.

Figure 1: Kilgali Amendment – HFC phasedown timeline & percentages

HFC Innovation in the United States

To maintain levels of innovation and production in U.S. refrigerant-related technology jobs, the U.S. Senate introduced bill S.2754 – the “American Innovation and Manufacturing (AIM) Act of 2019.” This bill necessarily creates a path for the U.S. Environmental Protection Agency (EPA) to implement a federal HFC phasedown. The HVACR industry is concerned that this bill does not contain a federal pre-emption, meaning individual states can still create stricter or quicker HFC phasedown timelines. S.2754 would give the EPA authority to establish guidelines for proper installations or servicing of the next-generation refrigerants or technologies, a move the industry hopes will strengthen the use of qualified technicians. A similar bill recently has been  introduced in the House of Representatives as well (H.R.5544 – the “American Innovation and Manufacturing Leadership Act of 2020”).

Without implementation of this type of legislation, the United States will continue toward a fragmented approach, as each state possibly could create their own HFC phasedown timeline and adopt standards for new refrigerants. The result will be confusing to end-users and negatively impacts manufacturers, suppliers and installers.

U.S. Climate Alliance

Due to the lack of action at the federal level over the last several years, states are stepping in to create their own HFC phasedown plans. The U.S. Climate Alliance is a group of 24 states and Puerto Rico that pledged to implement policies that advance the goals of the Paris Climate Agreement.

The Climate Alliance represents approximately 55 percent of the U.S. population and close to $12 trillion of economic impact. Several of these states have included HFC regulations as part of their climate plans. Two states – California and Washington – are the furthest along in implementing HFC phasedown legislation. The California Air Resources Board, or CARB, is the state agency charged with developing the regulations and is guided by California’s commitment to reduce greenhouse gas emissions from HFCs by 40 percent by 2030, compared to a 2013 baseline. The state of Washington’s Building Code Council recently voted to fully adopt ASHRAE 15-2019 and UL 60335-2-40 3rd edition, which allow A2L refrigerants (HFC alternatives) to be implemented into the state’s next building code cycle.

ASHRAE & UL Standards

ASHRAE and Underwriters Laboratory (UL) are organizations that develop standards for applications and equipment design. ASHRAE Standard 15-2019 and UL-60335-2-40, 3rd edition, both newly released in 2019, contain the information needed to implement the use of A2L refrigerants in “high probability systems” or “direct-systems.” Products that fit into this category include residential split systems, multi-split systems (VRF/VRV), rooftop units and similar equipment.

A2L Refrigerants

A2L refrigerants represent many of the new low-GWP refrigerants that are expected to be the replacement for air conditioning or refrigeration applications. A2L, as categorized by ASHRAE 34-2019, have some level of flammability, with the “2L” designation representing a “lower flammability” rating (see Figure 2) .While A2Ls have been incorporated into equipment globally for years (approaching 70m units), it will be new for the United States. The HVACR industry expects that additional equipment protection and field training will be required.

Figure 2: ASHRAE Standard 34 – Designation Safety Classification

Moving Forward

In the United States, the HVACR industry has created a Safe Transition Task Force to assure that the transition to low-GWP refrigerants is successful. PHCC and other organizations are working through this task force to educate many stakeholders at the federal, state and local government levels. Work is also ongoing with code bodies (UMC, IMC, etc.) to include new refrigerants in the building codes. There are still some issues that will need to be resolved, so stay connected to PHCC in 2020 for updates on this rapidly developing technology.


Free PHCC Member Webinar on
Refrigerant Options Beyond R410A

PHCC members have a prime opportunity to discover the latest refrigerant options during a free member webinar – “Beyond 410A” – presented by Chemours on Wednesday, March 11, at 2 p.m. ET. Registration information is coming soon at

National Training Manager
, Chemours Refrigerants

Share this article: