Proposed California Refrigerant Law to Ban HFCs in Some Refrigeration End-Uses

October 24, 2018 / by Elizabeth Ortlieb

Elizabeth Ortlieb

On June 15, 2018, the California Air Resources Board (CARB) issued a notice of public availability of modified text for its proposed HFC regulation that bans HFCs in certain refrigeration end-uses.

We've got the latest on the modifications. ✅ 

 

Proposed New California Refrigerant Law on HFC Bans Has Modified Text

First things first, the proposed regulation impacts retail food refrigeration equipment in specific end-uses, much like the EPA's SNAP Rule 20 (now vacated).

However, unlike EPA's SNAP Rule 20, the proposed CARB HFC regulation only affects certain stationary refrigeration and foam end-uses. 

The proposed regulatory text was made available earlier in the year, in January (see screenshot below): 

Proposed California Refrigerant Law on HFC Bans

Image source. Note: Blue underline and arrow added by Trakref and not from original screenshot.

Shortly thereafter, on March 22, 2018, a public hearing was held to consider for adoption the proposed regulation for Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration and Foam End-Uses.

At this hearing, CARB approved for adoption the proposed new California refrigerant law on HFC bans.

In a press release dated March 23, 2018, CARB gives a brief explanation for why it decided to act with this new proposed regulation: 

"The action was taken to preserve and continue in California some of the U.S. Environmental Protection Agency’s (U.S. EPA) prior prohibitions on HFCs."  

Additionally, on March 28, 2018, CARB issued a resolution that approved the adoption of the HFC regulation.

Notably, in that resolution, it states"BE IT FURTHER RESOLVED that the Board directs the Executive Officer to determine if additional conforming modifications to the regulation are appropriate."

That leads us to the most recent update—that is, the notice of public availability of modified text posted on June 15, 2018 (see screenshot below). 

California refrigerant law on HFC bans

Image source. Note: Blue underline and arrows added by Trakref and not from original screenshot.

 In this notice, there are two things I want to bring to your attention today:

(1) some of the prohibited substance effective dates have been changed; and

(2) edits have been made to the text to clarify that the prohibition date "refers to the date of manufacture of equipment or foam system to dispel industry stakeholder confusion over how the regulation would be implemented and enforced."

 

Free Chart on California's Proposed New Refrigerant Law on HFC Bans

For your convenience, we've created a handy free chart that quickly shows which substances the proposed regulation prohibits in which refrigeration end-uses. 

In this chart, you will also see that all the specific refrigeration end-uses have prohibited substance effective dates of Jan. 1, 2019; Jan. 1, 2020; and Jan. 1, 2021. 

The original proposed regulatory text had some end-use sectors with prohibited substance effective dates listed as Sep. 1, 2018; however, this proposed modification changes all those end-use sectors with that date to Jan. 1, 2019. More on that here.

california refrigerant law 2018 chart on hfc prohibitions

Because we want you and your team to achieve HVAC/R and refrigerant management success, you need to be on the lookout for what's possibly to come. ⚠️

This chart does just that. 

As you will see in the chart or in the regulation, there are three main compliance deadlines with this new California refrigerant law on HFC bans:

  • Jan. 1, 2019;
  • Jan. 1, 2020; and
  • Jan. 1, 2021

We are closely following the developments from CARB, and we will notify you here on our blog when there is a new update. ✅

It is very possible that, "soon in California, millions of appliances, investment options, and maintenance practices will be impacted by regulations that will affect almost every commercial property owner and manager," says Ted, President of Trakref.

In the meantime, please feel free to grab a copy of the chart on the proposed new California refrigerant law: 

Get My Free Chart

While we're not for sure what will happen, we do urge all end-users to proceed with caution with high-GWP refrigerants, especially if you have buildings in California.

It's important to note that the final regulation has not yet been posted and this is a proposed regulation. This is not legal advice.

As always, thanks for joining us.

Be sure to tune in next week for the latest HVAC/R insight. Right here, on the Trakref blog. 

Proposed California Refrigerant Law on HFC Bans - Click to tweet this article

-- If you enjoyed this article on California's SNAP-like HFC regulation, you might want to check out our other articles on this topic and more:

For a background on the EPA snap lawsuit, see Here's What You're Missing from the Federal Court Decision on HFC Bans

To learn more on this CARB HFC regulation, see my previous article on the topic: Have You Heard? California Adopts New HFC Regulation

Topics: HVAC/R, Compliance Reporting, Refrigerant Compliance, Refrigerant Management, compliance, CARB, CARB compliance, california ARB, SNAP, legislation, EPA

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 eortlieb@trakref.com