October 28, 2024
The goal of the U.S. Environmental Protection Agency's (EPA) American Innovation and Manufacturing Act (AIM) is to reduce hydrofluorocarbon (HFC) production and consumption by 85% by 2036. The AIM Act's plans include a phasedown approach to using lower Global Warming Potential (GWP) refrigerants in new commercial and residential HVAC systems.
Is your new commercial construction or retrofit project ready for these changes? We'll explain the latest updates and answer your frequently asked questions below.
Changes in Refrigerants Over Time
You may be familiar with the term Freon®. Freon was the standard refrigerant used in air conditioners for decades. It was used for so long that most people simply refer to any refrigerant as "freon." In fact, the word Freon is one type of product, a hydrochlorofluorocarbon (HCFC) compound known by industry experts as R-22. The EPA began phasing out HCFCs in 2010 and officially banned their production and import in 2020.
As Freon was phased out, new HVAC systems began using a refrigerant known as R-410A, or Puron®, an HFC. More efficient and less harmful to the environment, R-410A has been in use since its introduction in 1996 and is found in most of today's modern HVAC systems.
The next step to reducing the use of these harmful greenhouse gases is to switch to R-454B or Puron Advance™. R-454B is an HFC and hydro-fluoro olefin (HFO) blend with superior cooling capacity and a 78% lower GWP than its R-410A predecessor.
However, these new, low-GWP alternatives come with a risk, and that's flammability. Classified as A2L, or mildly flammable, by the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE), R454-B will require updates to standards and building codes to allow for their safe installation.
Updated Rulings and Deadlines in the Phasedown
Initially, the EPA set a deadline for halting the manufacture and import/export of R-410A systems for Jan. 1, 2023, with installations outlawed after Jan. 1, 2024.
That ruling, made in 2022, brought about industry backlash regarding inventory concerns, as well as a lack of differentiation between self-contained products and field-assembled systems. The short deadline would potentially leave manufacturers with unsellable inventory and contractors with comprehensive supply chain and multi-component system design modifications. Additionally, the new, low-GWP R-454B systems designed to replace the R-410s would not be available until mid- to late-2024, creating a gap in availability.
Through its Technology Transitions Program, the EPA has now defined the systems and products and has extended these deadlines so that new R-410A systems must be manufactured by Jan. 1, 2025, and installed by Jan. 1, 2026.
Preparing for the Newest Guidelines
So, what do these changes mean for your HVAC equipment? That depends on the current systems you have in place, their operating efficiency and maintenance needs. We'll address some of the most common questions in our FAQs below.
Q: How do I know what refrigerant my current HVAC system uses?
A: The refrigerant type is listed on the manufacturer's label of your system. If the label is no longer accessible, a TDIndustries Service Technician can analyze and identify your refrigerant type.
Q: My system uses R-22 or R-410A refrigerant. Does the change to low-GWP refrigerants mean I have to replace my HVAC equipment?
A: No. This phasedown of harmful greenhouse gases does not require property owners to replace any existing HVAC equipment. The EPA has allowed for the ongoing maintenance of existing systems throughout their useful life. However, the cost and availability of banned refrigerants will increase over time. As with anything mechanical, your system's efficiency level will also decrease with age. Owners should consider whether replacing old units with newer, more efficient systems makes more financial sense.
Q: Can I retrofit my existing HVAC system to utilize R-454B refrigerant?
A: No. R-454B has different loading rates and pressure regulations that require systems designed specifically for its use. As a two-component gas, special sensors are also needed to detect leaks. You should avoid working with any contractor that suggests using the new refrigerant in systems not explicitly engineered for R-454B.
Q: Does this extension mean I have another year to change my HVAC equipment plans from R-410A to R-454B?
A: We encourage property owners to be proactive. Even though R-410A equipment will continue to be available, virgin R-410A refrigerant production will be slashed an additional 30% in 2024. And while recovery and reclamation efforts have intensified, concern remains that shortages will continue to drive up costs throughout the 12- to 15-year life span of R-410A equipment.
Q: I already have R-410A systems on hand or ordered for an upcoming installation. What do I need to do to comply with the new refrigerant requirements?
A: As long as you accept delivery of your R-410A systems by Jan. 1, 2025, and have it installed by Jan. 1, 2026, you will meet the Technology Transition and phasedown requirements.
Q: I have a new project in the design or build phase. How do I ensure my HVAC equipment complies with the latest regulations?
A: If you anticipate installation after Jan. 1, 2026, check with your Architectural or Engineering firm to ensure they have specified R-454B systems for your future projects.
Q: As a building owner or operator, is there anything I should know about the flammability of A2L refrigerants? How will TDIndustries address this issue?
A: Despite the "mildly flammable" classification, A2L refrigerants are extremely hard to ignite. They also require a high concentration of gas to become flammable. Extensive testing has been done using cigarettes, lighters, power tools and appliances, and no heat source has produced ignition. In the unlikely event an ignition occurs, A2Ls have a lazy flame that extinguishes once the heat source is removed.
The technicians at TDIndustries are undergoing training on the safe installation and servicing of A2L refrigerants. Fortunately, it will mostly be "business as usual," with the same best practices used to install existing R-410A systems also applying to A2L equipment. Most existing tools are already A2L approved and those that weren't have been replaced. As an EPA Section 608 certified contractor, TDIndustries' technicians will not need to be recertified by the EPA.
Q: Do these regulations apply to any system that uses a refrigerant or just my HVAC units?
A: Different equipment types (including process refrigeration, retail freezers, ice machines, etc.) can have varying deadlines and requirements. Refer to this EPA Technology Transitions Fact Sheet for more details.
Q: Are the phasedown requirements the same for every industry?
A: No. Data centers, food processors and automotive manufacturers are some of the industries that have different timelines. Again, refer to the EPA Technology Transitions Fact Sheet for additional information.
Q: Are the phasedown requirements the same throughout the United States?
A: Not necessarily. While we are addressing the requirements at the Federal level, U.S. Climate Alliance member states may have specific guidelines. If your project is within a Climate Alliance state, check with your equipment provider or installer on any unique requirements.
Let the Experts at TD Help
Contact our service team for a system evaluation and recommendation. Our expert service engineers will ensure you fully comply with these new requirements and that your system is operating at peak performance.
TDIndustries offers integrated and comprehensive building solutions – from design and construction to facilities and maintenance. Proud to be 100% employee-owned, our passion for what we do is reflected in the quality of our work and our culture of service and industry leadership.
Freon® is a registered trademark of EI duPont de Nemours & Company
Puron® is a registered trademark of Carrier Corporation
Puron Advance™ is a trademark of Carrier Corporation
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