Refrigerant scenario - Rules and regulations

Refrigerant scenario - Rules and regulations

Worldwide agreements

The history of refrigerants started almost 200 years ago. During the XIX century and beginning of the XX, refrigerants available in nature were used. However, security problems due to flammability and toxicity led to the use of CFC and HCFC synthetic refrigerants.

In 1973, it was found that the emissions of Cl-atoms present in CFCs and HCFCs depleted the ozone layer. The problem was first addressed in 1985, when representatives of different states met in Vienna to define the actions to protect the ozone layer.

The concrete actions for the reduction of the production and consumption of ozone depleting substances, like R-12 and R-22, are collected in the Montreal Protocol on Substances that Deplete the Ozone Layer, signed by 197 parties in the world on 16 September 1987 and entered into force on 1 January 1989. The initial agreement was designed to reduce the production and consumption of several types of CFCs and halons to 80 % of 1986 levels by 1994 and 50 % of 1986 levels by 1999. In the subsequent meetings, the last one was in Kigali (2016), the protocol was revised in order to speed up the phasing out of ozone-depleting substances. For example, the Copenhagen amendment included the phase out of CFCs by 1995 and the phase out of HCFCs by 2029 with a gradual phase-down.

In this context, the use of HFCs such as R-404A and R-410A was extended in refrigeration and air conditioning applications. Some years later, however, it was discovered that fluorinated refrigerants such as HFCs negatively affects the greenhouse effect. With the scope of address this new finding, the United Nations Framework Convention on Climate Change (UNFCCC) was celebrated in Rio de Janeiro (1992), that commits State Parties to reduce greenhouse gas emissions.

Within this framework, the Kyoto Protocol was adopted 5 years later (in 1997), entering into force on 26 February 2005. There are currently 192 parties (Canada withdrew effective December 2012) to the Protocol. In effect, the Kyoto Protocol required the world developed countries to reduce greenhouse gas emissions by 5% compared to the year 1990 levels by 2008-2010.

In this scenario, Montreal Protocol Parties were aware of the importance of reducing the greenhouse emissions to the atmosphere. To this end, they met in Kigali in October 2016, where a global agreement was signed by 196 countries that are parties to the Montreal Protocol. The international phase-down of 85 % of HFCs by the late 2040s was agreed, that would help to avoid up to 0.5 degree Celsius of global temperature rise by 2100, while continuing to protect the ozone layer.

First reductions by most developed countries started in 2019. These countries will follow with a reduction of HFCs consumption levels in 2024, whereas first reductions in most developing countries will start from 2029, as shown in the following graph:


  • EU will follow its own F-gas Regulation phase-down (dotted)
  • A2 refers to the developed countries (EU excluded)
  • A5 Group 1 are countries under development
  • A5 Group 2 are the following countries under development: GCC (Gulf Cooperation Council: Saudi Arabia, Kuwait, Bahrain, Qatar, UAE, Oman), India, Iran, Iraq and Pakistan.

Kigali amendment to Montreal Protocol entered into force in January 2019. Currently, some countries have established the concrete measures to comply with it. In the following, some of them are summarized.


Regulations by country

European Union: F-gas  

In European Union, F-gas regulations were published in 2014, establishing restrictions to the use of HFC refrigerants according to their global warming potential (GWP). F-gas Regulation classifies HFC refrigerants according to their GWP and specifies the date these are banned, if applicable, for each application:

Application Refrigerants Unacceptable as of
Domestic refrigerators and freezers HFCs with GWP≥150 1 January 2015
Refrigerators and freezers for commercial use
Refers to hermetically sealed equipment.
HFCs with GWP≥2500 1 January 2020
HFCs with GWP≥150 1 January 2022
Stationary refrigeration equipment
Multipack centralized refrigeration systems for commercial use with a rated capacity of less than 40 kW is included.
Exception: equipment intended for application designed to cool products to temperatures below -50 °C.
Blends with GWP<2500 that have components with a higher GWP (such as R-125) could still be used.
HFCs with GWP≥2500 1 January 2020
Multipack centralized refrigeration systems for commercial use with a rated capacity of 40 kW or more
Exception: primary refrigerant circuit of cascade systems where HFC with a GWP of less than 1500 may be used.
Existing installations prior to that date can use R-134a for service and maintenance until the end of life cycle of the installation. 40 kW applies to the refrigeration capacity of the system at rated conditions at ambient temperature of 32 °C.
HFCs with GWP≥150 1 January 2022
Movable room air-conditioning equipment
Refers to hermetically sealed equipment which is movable between rooms by the end user, including window air-conditioners.
HFCs with GWP≥150 1 January 2020
Single split air-conditioning systems containing less than 3 kg of fluorinated greenhouse gases
Refers to those systems for room air conditioning that consist of one outdoor unit and one indoor unit linked by refrigerant piping, needing installation at the site of use. The Regulation does not specify heating/cooling and type.
HFCs with GWP≥750 1 January 2025

F-gas also establishes that a regular leak checking must be carried out with a frequency that increases in accordance with the tonnes of CO2 equivalent per circuit.

Additionally, the Commission has allocated quotas for placing F-gases on the European market for each producer and importer from 2015. The percentages for each year, calculated with reference to the average consumption of HFCs in the period 2009-2012, are shown in the following graph:

It should be noted that the biggest leap is from 2017 to 2018. As a consequence, the prices of high GWP refrigerants dramatically increased during those years and the availability decreased, leading to the substitution of HFCs by low GWP refrigerants such as naturals.

United States: SNAP Regulations  

The EPA SNAP program publishes final rules that list specific refrigerants as acceptable or unacceptable for certain application categories. Initially aimed to phase down ODP refrigerants, the positive success in addressing this problem led the Environmental Protection Agency (EPA) under the previous Administrations to begin to tackle the issue of HFCs' direct impact to the environment. To this end, EPA SNAP Rule 16 listed HFO R1234yf as an acceptable substitute for the automotive air-conditioning application category. This was followed by Rule 17 & Rule 19 listing several refrigerant substitutes with flammability properties as acceptable for several HVAC/R applications. EPA SNAP Rule 20 was published in July 2015, de-listing R-134a for the automotive air conditioning. Rule 20 also de-listed the most widely adopted HFCs refrigerants for supermarkets, condensing units, vending machines, ice machines, and stand-alone units: R-404A, R-507A, R-134a. EPA SNAP Rule 21 followed closely in December 2016, de-listing multiple widely used HFC refrigerants (R-407C, R-410A, R-134a, and R-404A) in centrifugal & positive displacement chillers, cold storage warehouses, food processing and domestic applications. Rule 23 was published in 2021, listing R-448A, R-449A and R-449B as acceptable for use in new medium-temperature retail stand-alone units (subject to narrowed use limits) as well as R-32, R-452B, R-454A, R-454B, R-454C and R-457A in new residential and light commercial air conditioning and heat pumps (except R-32 in self-contained room air conditioners, that had previously listed as acceptable in 2015).

It should be mentioned that a three-judge panel ruled in August 2017 that EPA SNAP Rule 20 must be vacated as it was not legal under the Clean Air Act, and cannot require manufacturers to replace HFCs with a substitute substance However, a court ruling established their validity again in April 2020.

Due to the uncertainty caused by the vacation of the EPA SNAP Rules from 2017 to 2021, some states such as New York, California, Connecticut and Maryland, all members of the United States Climate Alliance, decided to impose their own rules for the phase down of Global Warming substances. For instance, California Senate Bill 1383 calls for 40% reduction of HFCs by 2030 and the California Air Resource Board (CARB), which is the state equivalent to the EPA, to act accordingly.

Japan: "Act on Rational Use & Proper Management of Fluorocarbons"  

This regulation addresses issues throughout the lifecycle of fluorocarbons. It classifies refrigerants according to their GWP and specifies the date these are banned for each application:

Designated products Present refrigerant Taret value (GWP) Target year
Room air-conditioning R-410A, R-32 Less than 750 2018
Commercial air-conditioning R-410A Less than 750 2020
Condensing unit and refrigerating unit R-404A, R-410A, R-407C, R-744 (CO2 Less than 1500 2025
Cold storage warehouse
(for more than 50,000 m3)
R-404A, R-717 (Ammonia) Less than 100 2019

Other requirements that HVAC/R equipment should comply are enumerated in the following:

  • indications and label to designated products (showing “non-F-gas using” or degree of achievements to the target GWP value, target year and target GWP value, GWP value of the refrigerant used in the products), with the purpose of promoting designated products using low-GWP or natural refrigerant;
  • regular leak checks, call service to arrange repairs before refilling as soon as leakages are found, record maintenance, and disclose to maintenance operators, etc;
  • calculation of the annual F-gas leakage amounts. If that amount exceeds 1,000 tonnes of CO2 equivalent, users, as a company, need to report it to the relevant competent ministries, with information on the offices and factories from which the leakage was detected. The Ministry of the Environment (MOE) and the Ministry of Economy, Trade and Industry (METI) will notify the relevant municipal and prefectural governors on the results and the names of the companies, etc., and will publish them.

China: "First Catalogue of Recommended Substitutes for HCFCs"  

An accelerated phase-out schedule for HCFCs is planned. The steps are: reduction of 10% by 2015, reduction of 35% by 2020, reduction of 67.5% by 2025, reduction of 100% by 2030, allowance of 2.5% of baseline (2013 annual CO2 - eq.) for the period 2030-2040, and complete phase out by 2040. The following table shows the recommended refrigerants that can substitute R-22 for each application according to Chinese authorities:

Refrigerant Recommended Substitute Application
R-22 R-290 (Propane) Room air conditioner; Commercial independent refrigeration system
R-22 R-600a (Isobutane) Commercial independent refrigeration system
R-22 R-744 (CO2) Household heat pump water heater; Industrial/commercial heat pump water heater; Vehicle air conditioner; Industrial/commercial freezing and refrigeration system (used as refrigerant and secondary refrigerant)
R-22 R-717 (Ammonia) Refrigerated warehouse; Transport refrigeration; Condensing unit; Industrial refrigeration system
R-22 R-32 Unitary air conditioner; Water chilling (heat pump) unit; Heat pump water heater
R-22 HFOs Water chiller (heat pump): Centrifugal unit and Screw chiller

Canada: "Regulations Amending the Ozone-depleting Substances and Halocarbon Alternatives Regulations (Proposal)"  

Canada proposal indicates refrigerants that are banned from 2020 onwards for each application according to the value of GWP:

Product Use Date GWP
Stand-alone medium-temperature refrigeration system Commercial or industrial 1 January 2020 700
Residential 1 January 2025 150
Stand-alone low-temperature refrigeration system Commercial or industrial 1 January 2020 1500
Residential 1 January 2025 150
Centralized refrigeration system Commercial or industrial 1 January 2020 1500
Condensing unit Commercial or industrial 1 January 2020 2200
Chiller Commercial or industrial 1 January 2025 700
Mobile refrigeration system Commercial or industrial 1 January 2025 2200

Australia: "Ozone Protection and Synthetic Greenhouse Gas Management Amendment Bill 2017"  

Australia Bill is scheduled to start in January 2018. It consists in a gradual reduction of the maximum amount of bulk HFCs permitted to be imported into Australia, that will be managed through a quota system on imports. It is planned to reach 85 per cent by 2036, more ambitious than the limits of Kigali agreement proposal for a global phase-down. The baseline will be equal to: 15% of average HFC imports + 75% of average HCFC imports for the period 2011–2013.

  • 1st January 2018: starting of phase-down, by limiting the imports of synthetic greenhouse gases to 8 Mt CO2-eq. (75% of the baseline).
  • The intermediate reduction steps of the phase-down between 2018 and 2036 will all be equal to -7% and enforced every second year: -25% in 2018, -32% in 2020, and so on down to -15% in 2036.
  • 31st December 2035: reduction of the imports of HFCs to 15% of the baseline; the imports will remain at that level from then on.


Current scenario

The requirements established in Kigali amendment to Montreal Protocol involve the phase down of fluorinated refrigerants. Among the alternatives to high GWP refrigerants with zero ODP potential, the diffusion of natural refrigerants, in particular HCs, CO2 and ammonia, is gaining ground. They are considered as the definitive solution to past and emerging environmental problems. The drawbacks that left them in abeyance at the beginning of the XX century are now being overcome by the new technology.

Script Non Cancellare - WhyNatRef