California May Adopt New Refrigerant Management Rules for HVAC and Refrigeration Equipment

October 25, 2017 / by Elizabeth Ortlieb

Elizabeth Ortlieb

When it comes to HVAC and refrigeration equipment with high-GWP refrigerants, the state of California may be about to bring some market certainty and a quiet upset to the ongoing debate on U.S. EPA SNAP Rule 20 (the first SNAP rule that restricts HFC usage). 

Here's the latest:

California Emerges as Key Player in Debate on U.S. EPA SNAP Rule 20

In recent discussions of the court case involving U.S. EPA SNAP Rule 20, a crucial question has been whether the refrigerant management rule will stay intact or be vacated. With prominent stakeholders both for and against it, a legal battle is underway at the federal level, and much of the HVAC/R industry has been thrown into limbo. 

However, amid all this, an additional upsetter has emerged: the state of California.

Yes, the California Air Resources Board (CARB) has decided to act by beginning a rulemaking process to adopt selected provisions from EPA SNAP Rules 20 and 21 that affect stationary refrigeration and air conditioning (A/C). In fact, yesterday, on October 24, 2017, CARB held a public workshop to gather information from all stakeholders on the proposed rulemaking.

Reducing the Emissions of HFC Refrigerants is Part of State's Longterm Climate Strategy

Basically, because of state GHG reduction targets, CARB has vowed to pursue this rulemaking in case the SNAP program to limit high-GWP refrigerants is indeed dismantled.

If you look at the details of CARB’s GHG reduction targets, it’s easier to understand the reasons behind its decision to pursue adopting the two SNAP provisions. Let’s take a closer look at the bills that explain the action:  

  • Assembly Bill 32 (AB 32) aims to reduce GHG emissions to 1990 levels by 2020 (~30% reduction) and then achieve an 80% reduction below 1990 levels by 2050.
  • Senate Bill (SB) 1383 sets statewide reductions for short-lived climate pollutants (SLCPs), which includes HFCs, and aims to achieve a reduction of HFCs by 40 percent below 2013 by 2030.

To achieve these targets, the state had originally planned to rely, at least in part, on federal regulations that govern high global warming (high-GWP) refrigerants, namely SNAP Rule 20 and 21.

With SNAP in Question at Federal Level, State Considers Alternatives to Achieve Reduction Targets

In the slide below from the presentation at the public workshop, you can get a sense of the role these EPA SNAP regulations play in the state's HFC emission reductions plan:

California Refrigerant Management HFC Emission Reductions-1.png

Image source

As you can see, these federal refrigerant management regulations took up 24% of the potential reductions. Now with them being in question at the federal level, the state has decided that the next-best option is to indeed adopt certain provisions of SNAP Rule 20 and 21. 

The workshop annoucement explains, "Although CARB is actively defending these Rules in court, and believes that the federal program is the preferred path to achieve these reductions, it must consider state law alternatives as well in order to reach state reduction targets." 

The proposed provisions focus on stationary refrigeration and air conditioning (A/C), including

  • Supermarket Systems (new & retrofit)
  • Remote Condensing Units (new & retrofit)
  • Stand-Alone (Self-Contained) Refrigeration
  • Refrigerated Vending Machines
  • Retail Food — Refrigerated Food Processing and Dispensing Equipment
  • Cold Storage
  • Chillers

Moreover, in the workshop presentation, CARB shows which parts of Rule 20 and Rule 21 are selected and of most concern: 

Screen Shot 2017-10-25 at 12.05.35 PM.png

Screen Shot 2017-10-25 at 12.05.47 PM.pngScreen Shot 2017-10-25 at 12.05.59 PM.pngImages source

If you need a more comprehensive refresher on U.S. EPA SNAP Rules and acceptable and unnaceptable refrigerants, check out this blog post on the topic, and download our free, refrigerant usage chart here.

The Big Takeaway: Monitor Your Usage of HFC Refrigerants

The point is, folllowing handling requirements for high-GWP refrigerants, like HFCs, will continue to be of importance. Regardless of what happens at the federal level with SNAP Rule 20, California is going to make sure it meets GHG reduction targets. 

That means you cannot turn a blind eye to the activity on your HVAC equipment that uses these high-GWP refrigerants. In fact, we recommend these four steps to best protect yourself for HFC emission reductions: 

1. Have an inventory of all your equipment (age, condition, use, refrigerant type, etc).

2. Know your leak rate.

3. Schedule proactive maintenance on your equipment.

4. Plan for regulatory changes.

Here at Trakref, our team will continue to closely follow this developing situation and alert you to any new updates.

In the meantime, if you have any questions or concerns, feel free to give us a call at (888) 834-0233, or visit us online at

We're here to help you improve your refrigerant management! 

That's why we created a free Refrigerant Use Chart to know what's acceptable and unacceptable in certain end-uses:

Get My Free Chart

(A must-have resource for your team. It shows what refrigerants are acceptable and unacceptable through 2024!)


If you enjoyed this article, you might want to check out our other articles around this topic and more:

New EPA Refrigerant Regulations - 6 Compliance Requirements to Know

HVAC News Roundup - September 2017

Did you know that in the book Drawdown refrigerant management is listed as the #1 solution to combat global warming? Find out more here

Topics: Announcements, HVAC/R, Compliance Reporting, HVAC/R Software, Industry Insights, Refrigerant Compliance, CSR & Sustainability, Refrigerant Management

Elizabeth Ortlieb

Written by Elizabeth Ortlieb

With an extensive background in public affairs and communications, Elizabeth serves as the Policy & Content Manager at Trakref, where she tracks HVAC/R policy trends and provides updates to multi-level stakeholders. Email the author at