Last week the Environmental Investigation Agency (EIA) published a report that took a look United States supermarket chains. The EIA is an international agency that lobbies against environmental abuse from companies, governments, and groups. They were founded in 1984 in the United Kingdom by three environmental activists. Today they have offices within the UK and the United States. They are known for creating hard hitting reports based off of extensive research. They then use these reports to push for change either through a company level or through governmental legislation.

The most recent report that they published took an in-depth look at sixteen of the largest United States supermarket corporations based on retail sales of 2019. Specifically, the report looked at each company’s actions to reduce usage and emissions of HFC refrigerants. The data gathered for this report was collected by questionnaires sent to all of the companies involved. If no response was given then EIA answered the questions the best they could using public data.  They scored each major company on three main categories:

  1. Adopting of New Technology – This can range from retrofitting existing equipment, purchasing new systems that use climate friendly/low GWP refrigerants, as well as adopting more energy efficient refrigerants. Recommended approaches are cascade systems, transcritical systems, HFO refrigerants, or just your standard natural refrigerant/hydrocarbon approach.
  2. Refrigerant Management – This section focuses on two main areas. The first is early leak detection as well as correcting any leaks before they get out of control. The other point is the reclamation of existing refrigerant when a system is being retired. I had read an article the other day where a supermarket was being demoed but no one actually reclaimed any of the refrigerant before demolition occurred.
  3. Policy and Future Commitments – This point just focuses on company promises and commitments made to the public or to their share holders. An example would be when Coca-Cola committed to use non-HFC refrigerants for all of their new vending machines. (Source) A lot of times these public statements do not come to fruition.

The Results

Using the points we mentioned above the EIA gave each company a grade card score ranging from zero to one-hundred percent. Obviously, the one-hundred percent would be the highest possible score where as zero would be no effort made.

The results that were found were not surprising to me at all. There was only one grocery store chain that scored a passing grade from the EIA. That was Aldi with a seventy percent scorecard. And… if you ask me Aldi only did well because it is a European owned company and the trend has already occurred in Europe. Every other store failed. Yes, every single one. The second place winner with a score of only forty-six percent was Whole Foods. After that the percentages drop even lower for third place at thirty-four percent for Target.

To keep this article from getting too long I will not report what every single store received. Instead let’s look at some of the most recognizable names that we all shop at today:

  • Wal-Mart received a fifteen percent grade. Of that fifteen they received a forty-three percent in policy and commitments… but all of these promises seemed to be just that. They only received a ten percent on overall technology adoption.
  • Meijer received seventeen percent. Their technology adoption was only ranked at five percent and their future commitments only at fourteen percent. They do have one green light though and that is there refrigerant management which is ranked at nearly eighty percent. They may still be using HFC refrigerants but they are preventing leaks.
  • Kroger was ranked just below Meijer coming in at sixteen percent. They were similar to Wal-Mart where they made a lot of promises and commitments but have shown little action with only a twelve percent rating on technology adoption.
  • Costco, one of my favorite stores, came in with a four percent rating. Their leak detection/refrigerant management was ranked at zero and their technology adoption was rated at only five percent. Very little action take on HFCs from Costco. I was surprised by this as they are based out of Washington and Washington has been one of the leading states to push for HFC phase downs.
  • Trader Joes is the last one that I will mention and that’s because it is just funny. I was going to stop at Costco but when I saw the results for Trader Joes I couldn’t resist. Trader Joes came in at zero percent on the EIA scale. There have been no announcements or indicators that Trader Joes will be moving away from HFC refrigerants. They were fined back in 2016 by the EPA for R-22 leaks, but again there has been no future progress.


I have always considered myself somewhat neutral when it comes to phasing down HFC refrigerants. At times there seems to be a fanatical push to phase down all of these refrigerants as fast as we can regardless of the consequences to the wallet or to safety.

I mention safety as there has been a resurgence of hydrocarbon refrigerants as we begin to move away from HFCs. Flammability is a risk. One of the new recommended products to replace HFCs with is a cascade R-744 Carbon Dioxide and R-290 Propane system. Regardless of the precautions and safety steps taken there is a risk when using large quantities of propane. (In an example at Whole Foods there are seventy-five pounds of charged R-290 mounted on the roof of the building.) HFCs did NOT have this risk associated to them.

The other point is cost. So many of these businesses invested a ton of money into moving away from their older HCFC R-22 systems. That was the big push not too long ago, right? R-22’s phase out began in 2010 and ended in 2020. If I was a business owner in 2008/2009 and I saw the governmental pressure coming on R-22 I would have moved over to an R-404A system so I would be in compliance. But now, ten years later, I am being told that I now have to invest even more money to purchase a new system or retrofit all of my equipment… again.

Why? If there is no governmental mandate forcing my hand then I am going to hold on my to existing machines… because they work. I am not going to incur a significant expense until I absolutely have to. This is how a business is ran and it is how I would run mine. This report may attempt to shame these businesses in compliance but in truth it is just a paper tiger and it will have no impact. If the lobbyists behind this report seriously want change then there are two ways forward. The first is more states adopting HFC phase down policies. The second is a federal phase down program on HFCs. If these do not happen then there will not be change.

Thanks for reading,

Alec Johnson




RefrigerantHQ's Pressure Charts

One of the very first steps when it comes to diagnosing your home air conditioner, refrigerator, or even your vehicle’s air conditioner is understanding the temperature and the current pressure that your system is operating at. Having these facts along with the saturation point, the subcool, and the superheat  numbers for the refrigerant you are working on are essential when it comes to really understanding what is going wrong with your system.

After a visual inspection the very next step for the most seasoned technicians is pulling out their gauges and checking the pressure and temperature. It just becomes second nature after enough calls. I have heard stories of rookie techs calling some of the pros on their team for help on a system that they’re stuck on. It doesn’t matter what the situation is. It doesn’t matter if you’re in Miami or in Fargo. It will never fail that one of the first questions the pros ask the rookie is what is your subcool and what is your superheat? Having  and understanding these numbers is key to figuring out what to do next.

But, these numbers won’t do you any good if you don’t know what refrigerant you are dealing with and what the refrigerant’s boiling point is at each pressure level. This article aims at providing you with just that information.

R-448A Solstice N40 Basic Info & PT Chart

It seems that as the years go by we face more and more pressure to begin phasing down HFC refrigerants. As I write this article most HFCs have already been phased down across the European Union and we are not too far behind here in the United States. When a class of refrigerants are phased out there obviously needs to be another to step up and take their place. The debate is still raging on rather that should be natural refrigerants or if we should go with the newer class of refrigerants known as Hydrofluoroolefins (HFOs).

The newer refrigerant R-448A, also known as Solstice N40, is an HFO refrigerant. It was introduced by the Honeywell corporation under their new Solstice brand line. While 448A can technically be classified as an HFO refrigerant it actually has more HFC refrigerants in it. This refrigerant is a zeotropic blend of R-32 (26%), R-125 (26%), R-134a (21%), R-1234ze (7%), and R-1234yf (20%). This N40 refrigerant was designed to replace the ever popular HCFC R-22 and the HFC R-404A.

It can be used for new installations and in retrofits. I won’t get into retrofitting here, but there are many guides from OEMs and Honeywell that take you through step by step. One word of warning though is if you are trying to retrofit an R-22 unit over to this refrigerant you should know that R-448A requires POE oil while R-22 requires mineral oil. They are not interchangeable. R-404A does use POE oil so there won’t be a problem there.

This refrigerant is designed for use in low and medium temperature applications such as supermarket refrigeration, refrigerated cold stores, refrigerated transport vending machines, and industrial refrigeration. This N40 refrigerant from Honeywell has an A1 safety rating from ASHRAE. What that means is that the refrigerant is non-toxic and is not flammable. That is a big deal as so many refrigerants nowadays are rated either flammable or slightly flammable.

As I had mentioned earlier, the main point of switching to these new HFO refrigerants is to protect the climate. In the case of R-448A you will see a sixty-eight percent reduction in Global Warming Potential (GWP). That is a significant reduction. Let’s look at the numbers. R-404A has a total GWP of nearly four-thousand. R-448A has a GWP of fourteen-hundred. Along with the savings of GWP you will also find that this Solstice refrigerant runs between five to ten percent more efficient then R-404A. SO, you’ll get the benefit to the climate in two ways.

There is one big downside here on this refrigerant I want to mention before I get to the PT chart. I had stated that the GWP for this product is fourteen-hundred. While it is lower then R-404A you should be aware that it is still a very high GWP number. Because this number is so high I do not foresee this refrigerant lasting in the long run. Its GWP is just too high. I would fully predict that we would see this refrigerant being phased out in just about five years time. It will be replaced by something else down the road. This refrigerant is just a stop gap until we find something better.

Alright folks, I’ve talked enough. Let’s get to the pressure temperature chart. As you are looking over this data please reach out to me if you find something that is not correct. I strive to make these tables accurate and will get any errors corrected as soon as I can.

PSIGLiquid Temp (F)Liquid Temp (C)Vapor Temp (F)Vapor Temp (C)

Thanks for reading,

Alec Johnson



Towards the end of May the Environmental Protection Agency announced their latest proposed Significant New Alternative Policy (SNAP) rule. At this time the rule is just proposed and not finalized. That being said, this rule will definitely have an impact on the industry and the future of air conditioning within the United States.

This time it is a bit different then what we usually see from the EPA. In the past these new rules typically label certain refrigerants for specific applications as no longer acceptable. However, this latest proposed rule does the opposite. This SNAP Rule 23 moves a number of refrigerants to acceptable depending on the use conditions and others have had their use restrictions lessened. Let’s take a look at the changes:

Air Conditioning

The first change focuses on residential and light commercial air conditioning and heat pumps. The following refrigerants has now been added as acceptable in these applications: R-452B, R-454A, R-454B, R-454C, R-457A, and R-32. They are all are subject to use restrictions. Each one of these refrigerants have something in common. They are ALL rated as A2L from ASHRAE. For those of you who aren’t aware, the A2L rating indicates that the refrigerant is slightly flammable. This is the same rating that the popular HFO 1234yf refrigerant that we see used in our cars has.

This A2L label indicates refrigerants having a lower flammability limit of more than 0.10 kilograms per cubic meter or 0.0062 pounds per cubic foot at 21° Celsius (69.8° Fahrenheit) and 101 kPa (14.6488 pounds of force per square inch.) and a heat of combustion of less than 19 Kilojoule/Kilogram or 8.168 BTU/Pounds. Sorry for all of the conversions here but I wanted to cover my bases. I converted these using online tools but if you see something incorrect please reach out to me.

What this means folks is that flammable refrigerants COULD be approved in traditional split system air conditioners. I say could as this rule is still preliminary, but if the EPA does finalize it then we will begin to see new systems with these refrigerants being rolled out to residential and commercial applications. To me, the big story here is that R-32 is being considered. R-32 has been becoming wildly popular over in the European Union as a more climate friendly alternative to the HFC R-410A.

While both of these refrigerants are HFCs R-32 has a significant lower GWP then R-410A. R-32 comes in at six-hundred and seventy-five where as R-410A Puron is at two-thousand and eighty-eight. So, more then double that of R-32. This is why we have begun to see the use of R-32 in newer home/commercial air conditioners in Europe and also why it is now seriously being considered within the United States marketplace.

While R-32 caught my attention I will have to admit that I wasn’t as familiar with the other refrigerants named in the proposed rule. I looked these up and found that they are all varying HFC/HFO refrigerant blends that are all rated as A2L flammability.

  • R-452B – Blend of R-32, R-125, and R-1234yf with a GWP of 675.
  • R-454A – Blend of R-1234yf and R-32 with a GWP of 239.
  • R-454B – Blend of R-1234yf and R-32 with a GWP of 467.
  • R-454C – Blend of R-1234yf and R-32 with a GWP of 146.
  • R-457A – Blend of R-32, R-1234yf. and R-152a with a GWP of 139.

Now as I mentioned earlier each one of these flammable refrigerants would be subject to use conditions. In other words, it would not be free reign or the Wild West. There would still be some restrictions and regulations. Instead of me rehashing all of these specific requirements I’ll instead just provide some direct text straight from the EPA’s proposed SNAP rule. Feel free to click on the sources as well to view the text for yourself:

    1. “This refrigerant may be used only in new equipment specifically designed and clearly identified for the refrigerants (i.e., none of these substitutes may be used as a conversion or ‘‘retrofit’’ refrigerant for existing equipment designed for other refrigerants).” – Source Page 21
    2. These substitutes may only be used in air conditioning equipment that meets all requirements in UL 60335–2–40.123 In cases where this appendix includes requirements more stringent than those of UL 60335–2–40, the appliance must meet the requirements of this appendix in place of the requirements in UL 60335–2–40.” – Source Page 21
    3. The charge size for the equipment must not exceed the maximum refrigerant mass determined according to UL 60335–2–40 for the room size where the air conditioner is used. The following markings must be attached at the locations provided and must be permanent:” (Click here and go to page 21/22 to read the text on the markings, it was too long to include in here.) 
    4. The equipment must have red Pantone Matching System (PMS) #185 or RAL 3020 marked pipes, hoses, or other devices through which the refrigerant passes, to indicate the use of a flammable refrigerant. This color must be applied at all service ports and other parts of the system where service puncturing or other actions creating an opening from the refrigerant circuit to the atmosphere might be expected and must extend a minimum of one (1) inch (25mm) in both directions from such locations and shall be replaced if removed.” – Source Page 22

Retail Food Refrigeration

These changes aren’t as big of a story as the previously mentioned air conditioners, but they are still worth mentioning. These focus on the retail food refrigeration industry specifically on medium temperature stand alone units. There were three additional refrigerants that would be deemed as acceptable with this new EPA rule: R-448A, R-449A, and R-449B. It is also worth mentioning that these were refrigerants were NOT rated as A2L from ASHRAE but instead just the standard A1 that we see with the current HFC refrigerants we use today such as R-134a, R-410A, and R-404A. So, this isn’t as big of a change.

Let’s take a look at these refrigerants:

  • R-448A – Blend of R-32, R-125, R-134a, R-1234ze, and R-1234yf.
    • GWP of 1,387
    • A1 Safety Rating from ASHRAE
  • R-449A – Blend of R-134a, R-1234yf, R-125, and R-32
    • GWP of 1,282.
    • A1 Safety Rating from ASHRAE
  • R-449B – Blend of R-32, R-125, R-134a, and R-1234yf
    • GWP of 1,296
    • A1 Safety Rating from ASHRAE

Also, like before with the air conditioners these new refrigerants would have use restrictions.  The difference here is that these refrigerants are almost seen as a last resort. See below from the EPA’s fact sheet:

“Acceptable only for use in new medium temperature standalone units where reasonable efforts have been made to ascertain that other alternatives are not technically feasible due to the inability to meet Americans with Disabilities Act (ADA) requirements.” – Source


As I stated a few times in this article this rule is NOT approved or finalized yet. It is still preliminary and it very well may change. If you would like to voice your opinion on the topic it is open to public comments for forty-five days from when the rule was published in the Federal Register. If you are thinking about making a comment I suggest you do it soon. If this rule does come to fruition we will be looking at a whole new demand for flammable refrigerant training for ALL of the residential and commercial contractors and technicians.

Thanks for reading,

Alec Johnson




More dominoes fell last month when Colorado and Virginia announced that they will be phasing down HFC refrigerants. This now brings the total states acting, or working towards, phasing down HFC refrigerants to sixteen. If you count just the states that have moved forward with legislation or regulation then Colorado and Virginia is now the fifth and sixth. They now accompany California, Washington, Vermont, and New Jersey. Other states have committed to their own action in the near future, some of these include: Maryland, New York, Pennsylvania, Hawaii, Oregon, Delaware, Connecticut, Maine, Massachusetts, and Rhode Island.

All of these states mentioned above are part of what’s known as the United States Climate Alliance. This alliance was formed back in June 1st, of 2017 immediately after the Trump Administration pulled the United States out of the Paris Climate Accord. The goal of this alliance is to set a climate policy as a collection of states rather then one state at a time. It also gives bargaining power with the federal government and manufacturers. At this time the alliance is up to twenty-four states and is expected to continue growing. 

Towards the end of May Colorado’s Air Quality Control Commission announced their new regulation known as ‘Regulation 22’ that intends to phase down the use of HFC refrigerants throughout the state. On May 21st Governor Northam of Virginia signed a law targeting HFC refrigerants as well. In both cases between Colorado and Virginia the new requirements closely mocked the EPA’s SNAP Rules 20 and 21.

As I had mentioned earlier, there are other states in the Climate Alliance that are expected to begun their own work on HFC refrigerants as well. So, why is all of this occurring at a state level? Well folks it goes back to a ruling back in 2017 where a federal court overturned the EPA’s SNAP Rules 20 and 21. These rules aimed at phasing down HFC refrigerants using the same authority that the EPA used to phase down CFC and HCFC refrigerants. The court ruled against them stating that their authority only extended to refrigerants with ozone depleting substances. It did not allow them to phase out HFC refrigerants which did not harm the Ozone but did contribute to global warming.

Since then there has been no update from the federal government on what the next steps will be. In essence, there has been no HFC phase down within the United States over the past few years. There was hope initially for the Montreal Protocol’s Kigali Amendment but that has stalled as the Trump Administration has not sent it to the Senate for ratification.

This is why we have seen states begun to announce their own HFC refrigerant phase down plans. The hope is to have so many states on board that manufacturers are forced to switch over to the more climate friendly refrigerants. With the addition of Colorado and Virginia we now have twenty-five percent of the United States’s GDP with a formal HFC phase down plan. If we add up the GDP percentage of all sixteen states that are considering HFCs laws then that GDP total increases to forty-five percent! (Source from Wikipedia) Imagine the impact on having nearly half the United States’s GDP with HFC phase down regulations. Businesses will have no choice but to adapt.

There is one major concern though about each state having their own policies. It will be a nightmare for businesses to comply. If California has one requirement, but Nevada has a different one and Arizona has a different one then how are you, as a business, going to adapt?  The good news here is that with the lack of a federal presence the United States Climate Alliance published their own model rule for future states that are looking to phase down HFC refrigerants. The hope is that with this model rule we will have a consistent rule state by state. States won’t have to make up their own regulations. This will make things much easier for manufacturers and distributors knowing that each state will have more or less similar rules. While researching for this article I found a quote from the the Climate Alliance team, “This (model) framework is designed to ensure all the states have substantially similar rules,” said Julie Cerqueira, Executive Director of the U.S. Climate Alliance. “It is essentially a mirror of SNAP.” – Source.

Technically, there is still hope for a federal response as well. There are bills in the Senate and the House being debated this summer. The aim of these bills will be to give the power back to the Environmental Protection Agency so that they can begin regulate HFC refrigerants like they had intended back in 2015 when they announced their famous SNAP Rules 20 and 21. However, I do not foresee these bills moving forward with the Trump Administration in office. They could perhaps be stalled until after the election cycle, but that is a gamble in itself. We could see a very different political climate come January of next year. Or, we could be right where we are today. This is why we see the states moving forward now. They are tired of waiting for federal action.

Thanks for reading,

Alec Johnson




Last week I saw a few headlines surface about R-1234yf that caught my attention. The premise of these articles was that the very popular HFO R-1234yf was toxic. Now, if true, this is a huge deal. There was already a significant battle in the European Union when R-1234yf was first being rolled out about the flammability risk and now… we may have a potential toxicity risk as well?

Let me back up for a moment here folks. First a brief history lesson, as many of you know the HFO R-1234yf was brought into the market as a replacement for the HFC R-134a. This was done due to R-134a very high Global Warming Potential number of one-thousand four-hundred and thirty. Every time R-134a was released into the atmosphere either by leak, accident, or on purpose it actively impacted Global Warming and Climate Change.

To prevent further damage to the climate automotive manufacturers begin transitioning away from 134a over to this new HFO. 1234yf only had a GWP of four. A remarkable difference when compared to 134a. The problem with 1234yf is that it is flammable. This flammability rating caused a lot of hesitation from automotive manufacturers. In fact one of them, Daimler, fought the change tooth and nail. Eventually, they came up with their own automotive air conditioning system using R-744 Carbon Dioxide.

Eventually the fight on the flammability risk was nullified and we began to see more and more vehicles switch over to R-1234yf. As I write this article today ninety percent of new vehicles are using this HFO refrigerant. Each year that passes we are seeing more and more manufacturers switch over. The flammable risk was accepted as a necessary risk for helping the environment.

The Study

Last week there was a study done by the Advancing Earth and Space Science association (AGU). AGU is a scientific research firm that works in growing the exchange of scientific knowledge through publishing studies and holding meetings. They are based out of Washington District of Columbia. One of their most recent studies found that R-1234yf is toxic. Now when I use the word toxic it is not like how other refrigerants are toxic. For example, if there is an ammonia leak then it can be extremely deadly. That is why that refrigerant is rated as a B2L from ASHRAE.

R-1234yf is still rated as an A2L refrigerant from ASHRAE. Class A rating on toxicity signifies refrigerants for which toxicity has not been identified at concentrations of less than or equal to four-hundred parts per million. The difference here is that this study focused instead on what the refrigerant does when released into the atmosphere, specifically on Trifluoroacetic acid. I wasn’t familiar with this type of acid so I had to do a bit of research.

“Trifluoroacetic acid (TFA) is a breakdown product of several hydrochlorofluorocarbons (HCFC), regulated under the Montreal Protocol (MP), and hydrofluorocarbons (HFC) used mainly as refrigerants. Trifluoroacetic acid is (1) produced naturally and synthetically, (2) used in the chemical industry, and (3) a potential environmental breakdown product of a large number (>1 million) chemicals, including pharmaceuticals, pesticides, and polymers. The contribution of these chemicals to global amounts of TFA is uncertain, in contrast to that from HCFC and HFC regulated under the MP.” – Source

As you can see from the above quote these Trifluoroacetic acids are found in all of the man made refrigerants such as HCFCs, HFCs, and HFOs. The difference though is the amount that is found in each classification of refrigerant. You see folks, it turns out that HFOs are significantly worse when it comes to TFAs. The below quote is from the study that AGU completed:

“Replacement of HFC‐134a with the short‐lived hydrofluoroolefin (HFO) HFO‐1234yf as the coolant in mobile air conditioners will lead to an increase in TFA deposition. The yield of TFA from HFC‐134a is <0.2, while the yield from HFO‐1234yf is 1. One model estimates replacement of HFC‐134a with HFO‐1234yf will result in annual TFA wet deposition of 160–240 μg m−2 in continental North America (Luecken et al., 2010), which is higher than the cumulative deposition during the last decade of record for each ice core (Devon Ice Cap, 110 μg m−2 (2005–2014); Mt. Oxford icefield, 127 μg m−2 (2007–2016)). Another model predicts annual TFA deposition of 42.3 μg m−2 to the area including the Devon Ice Cap (Wang et al., 2018). This represents an increase compared to our observed annual TFA fluxes from 2001 to 2014, which ranged from 3.9 to 21.5 μg m−2 a−1. Both models suggest a large future increase in TFA deposition in the Arctic compared to our measurements from 1970 to 2015.” – Source

That definitely paints a picture of the difference between HFCs and HFOs. The HFOs contribute five times as much TFA when broken down into the environment. The question now though is what impact will this have on the environment? Does everything need to change? The below quotes I found from National Library of Medicine. They go into the impacts that TFAs have and will have on the environment:

“Total contribution to existing amounts of TFA in the oceans as a result of the continued use of HCFCs, HFCs, and hydrofluoroolefines (HFOs) up to 2050 is estimated to be a small fraction (<7.5%) of the approximately 0.2 μg acid equivalents/L estimated to be present at the start of the millennium” – Source

“As an acid or as a salt TFA is low to moderately toxic to a range of organisms. Based on current projections of future use of HCFCs and HFCs, the amount of TFA formed in the troposphere from substances regulated under the MP is too small to be a risk to the health of humans and environment. However, the formation of TFA derived from degradation of HCFC and HFC warrants continued attention, in part because of a long environmental lifetime and due many other potential but highly uncertain sources.” – Source


So the question now is what will happen next? Will this be enough to warrant another phase down in the next five, ten, or twenty years? If so, then what will be the next logical step for automotive applications? Also, it is not just automotive applications. Could this TFA problem found in 1234yf carry over to other up and coming HFO refrigerants?

Should we continue to pursue the HFO route, or should we begin looking at natural refrigerants such as CO2, Ammonia, and Hydrocarbons more seriously? Time will tell I guess…

Thanks for reading,

Alec Johnson




As you all know, a few days ago I sent out a survey to the industry asking questions on hydrocarbon refrigerants.  The goal of this was to help me understand how folks who are working in the industry everyday feel about them. Does it make sense to switch over to hydrocarbons? Should the charge limits be increased? What parts of the world have adopted them, what parts are hesitant to move forward?

This was a new idea for the RefrigerantHQ website and I had high hopes for the results. After letting the surveys come in for the past couple days I am more then happy with the participation that I received. As I write this article eighty surveys have come in. Now, I know that may not sound like a lot but I believe it is enough to at least give us a glimpse on what the industry thinks of hydrocarbons.

What I was most happy with is that we received feedback from across the globe. Yes, the majority of the surveys, about sixty-five percent, came from the United States. But, there were many others from around the world. Fifteen percent of responses came from various countries within the European Union. Seven percent came from Australia. Five percent came from east and central Asia, and another five percent came from Africa. We had some come from the Middle East and even one entry from the island of Fiji.

Hydrocarbon Training

One of the questions I asked on the survey was about hydrocarbon training. In order to handle hydrocarbons applications you have to have proper training. These are flammable refrigerants and if a laymen is trying to repair them there is risk. That is why I saw this question as so important. How many of us out there have had proper training on handling these refrigerants?

With the results I received I was able to break it down by country and also by type of company. Let me first start with training percentages by country. In this I am only going to include the European Union and the United States as the other datasets from other countries was too small to make an accurate judgment. When participants were asked if they have received hydrocarbon training eighty-two percent of people from the EU stated that they had. I also added up the results from all of the ‘other’ countries which includes Africa, Australia, Asia, etc. Their training percentage was at seventy-five percent. If we compare the same question to the United States we see sixty-two percent.

It is obvious to see that the United States is lagging behind other countries when it comes to hydrocarbon training. I had suspected this already before the survey was taken out. There is a certain fear associated with these types of refrigerants, especially within the United States. As an example, a survey participant stated,

“Use of any flammable, explosive, or toxic refrigerants should be outlawed. Anyone who installs one will eventually find himself being sued when it explodes. The natural refrigerants like Ammonia are toxic, and the natural refrigerants like CO2 are explosive because of their exceedingly high ambient pressures. This makes them very dangerous for anyone to work on.”

There were many results similar to the one I quoted above. They weren’t all from the United States either. There were just as many negative comments on hydrocarbons from the European Union as well. Here are a few:

“The use of hydrocarbon refrigerants such as R290, R600, R600a etc need to controlled very carefully. of course, I understand that they are low global warmers, but they are also explosive & present a very significant safety hazard. No good in reducing global warming if we blow ourselves up in the process, ie witness the disaster at Grenfell Tower in London where many people died to the use of hydrocarbons initially in the refrigeration unit & then in the cladding. In my view, the European are going entirely in the wrong direction by easing the restrictions on HCs in EN378. There are other, and much safer, ways of reducing global warming, both direct & indirect, than enabling HCs to become mainstream refrigerants, which would be a disaster & inevitably lead to many accidents & fatalities. Indeed, we as a company are working on such alternatives which are non flammable & with low GWPs.” – Survey Participant from the EU

Another One:

“In Europe for chiller/HPs we’re introducing low GWP (but not so low) HFC R32, R454B, R452B classified A2L. It is already hard to introduce these gases to customers used to work with no-flammable A1 (R410A basically). So I think A3 hydrocarbons would be definitely not accepted at all, except for some niches where they have already some market share.” – Survey Participant from the EU

Reading these comments had me look at the training numbers again. This time I looked at who has been trained by company type regardless of country. This way of looking at the data revealed a lot more. Over eighty percent of the entries from distributors and manufacturers have had hydrocarbon training. The same goes with the automotive sector, but that is most likely due to the HFO-1234yf slight flammability. Now if we look at the training percentage on HVAC contractors the number is only fifty percent. Because of this low number it dragged down the entire overall training percentage to sixty-five percent.

What does all of that mean? There are two things at work here. I believe part of this is a fear of the unknown but another part, just as big, is a legitimate fear of flammability risk. The flammability danger will always be there but what we can do is work on better training to alleviate the fear of the unknown. Looking at the percentages we recorded through the survey there is a gap in training offered or required when working with hydrocarbon refrigerants. Like it or not folks it is the way the industry is moving. HFCs are on the way out and many companies are moving towards hydrocarbon refrigerants. Training needs to occur.

From what I can gather there is one country that is doing an outstanding job when it comes to using hydrocarbons everyday and also ensuring that the proper training is not only given but is required. That country is Australia. I received a few surveys from over there and each one of them had great feedback. Here are a couple of their responses:

“Yes, we work with R600a as well and to be honest we have found no issues with either of them except for the actual weight allowance so it is only good for the smaller self contained cabinets. We would like the charge luted to 500grams so them a much wider self contained market can come int play and as this refrigerant is very efficient it also helps with power / ozone.
We have good training over here for these refrigerants from our training colleges and also the refrigerant suppliers which means after the training you actually get a certificate so you can purchase it legally. Now over here they are talking about putting it A/C units which is madness as these units can hold weights up to 5kgs or more. So far we have said we will not support this maddness as it is far too dangerous.” – Survey Participant from Australia

Another response from Australia:

“Firstly, because approximately only 40% of original charge is used to obtain equivalent super heat & sub cooling settings, then the flammability is reduced to the lower charge with a hydrocarbon. We have been using hydrocarbons now for approximately 4 -5 years with no issues what so ever. The most important aspect I see is that techs or tradies using hydrocarbon refrigerants are not “cowboys” of the industry. We have attended many installations done by cowboys of the industry and they obviously do not own or do not know how to use the following:

  • Nitrogen Regulator & Nitrogen
  • Vacuum Pump
  • Digital Vacuum Gauge
  • Leak Detector

Their installations leak due to badly cut copper and no de-burring, no oil used on the seat or shoulder of the flare and the use of leak lock on a flare – all incorrect and bad installation practices.
Then they fail to pressurize the system to at least 1.5 times operating pressures of the refrigerant. Next they fail to vacuum the system correctly, ie. Evacuate to under 500 microns, isolate the vacuum pump and ensure vacuum does not rise beyond 500 microns.

Until installers can get this right then to me they are a hazard to the community if allowed to work with hydrocarbon refrigerant. Hydrocarbon refrigerant is an excellent refrigerant in the hands of good techs and fridgies. As here in Australia a person does not have to be licensed to buy Hydrocarbon refrigerant, unlike not being able to buy Hydrofluorocarbons because they are not licensed opens up a Pandora’s box to probable fires etc, not acceptable.” – Survey Participant from Australia

I really liked the term ‘cowboys’ that the last participant used. I am sure you have all seen the cowboys of the industry or even the homeowner/business owner who thinks they can do it themselves. When R-404A or R-410A is being used the worst that happens it that it gets vented into the atmosphere by someone who doesn’t know what they are doing. With hydrocarbons though it is a different story. A cowboy can cause significant damage and risk to themselves and others.

So the question now to everyone is how do we as an industry get better at training? We all know hydrocarbons are coming. What is the correct answer here? How can we minimize the risk? Do we introduce new national training legislation for each country? The biggest gap in training right now are the contractors who are actually in the field working on these systems. What can we do to provide the knowledge they need to keep them safe?


This article only covered the training section of the survey questions. I will be doing another article on the charge limit and preferred refrigerant choice of the future in the coming weeks. Hopefully by then I have even more survey results back!

While I hope to achieve more survey results the next time we do one of these in the future I am more then pleased to see this initial pilot go so well. I will see how this results article does on traffic. If this performs well also, then I will begin thinking of an additional survey for a month or two down the road. Perhaps we could turn it into a quarterly industry survey. I believe it could be quite the success. With that in mind, if any of you have ideas on what you would like to see in the next survey please reach out to me.

Also, if you’d like to see more detailing statistics on this survey please reach out to me.

Thank you all for reading,

Alec Johnson


Greetings everyone. I hope that you and your families are staying safe and healthy during these recent times. It seems that the COVID crisis has slowed most everything down across the world including the HVAC industry. I have been watching the headlines  but have not found anything major enough to write an article on in the past few weeks. That got me thinking though, if there isn’t trending news at this time then why not attempt to make our own?

I had the idea this evening to put together a short survey for my readers. I assure you that it is quite short and will only take a few minutes of your time. The topic is hydrocarbon refrigerants such as R-290 propane and R-600a isobutane. The goal here is to get enough feedback from the readers so that I can not only disseminate everyone’s feelings about hydrocarbons but am also able to find a consensus amongst the industry. It will also give a unique view by area of the world. I am very interested to see how thoughts differ between United States and other countries.

If this goes well I will write a followup article that goes over the results and what some of the most frequent comments are. If this doesn’t go well, then you can be assured that I will go back to our standard article format. Either way, thanks for reading!

What part of the world are you from?
What type of company do you work for?
How likely are you to work with hydrocarbon refrigerants? *
Have you had any training on flammable refrigerants?
Do you believe charge limits should be increased on hydrocarbon applications?
If a customer is looking to move away from HFC refrigerants, which path would you recommend?

As most of you know there is pending legislation within the United States Senate that aims to phase down HFC refrigerants across the country. It is titled the ‘S.2754 – American Innovation and Manufacturing Act of 2019.‘ I wrote about this when it was first introduced back in October of 2019.  This legislation is yet another attempt to push HFC refrigerants out of use in the United States. We’ve seen the EPA’s SNAP rules from 2015 get over turned. We’ve seen the Kigali Amendment stall. Will it be any surprise if this proposed bill stalls as well? I think not.

That being said it does appear that the bill is picking up steam within the Senate. I took a look at the bill today and noticed that it now has thirty-three Senators as cosponsors. While there are still many hurdles to get through it may be time to start taking it seriously. As I said earlier the bill aims to phase down HFC refrigerants across the country. This covers all of your popular refrigerants such as R-134a, R-32, R-125, and R-143a. (There are others as well, for a full listing visit the actual bill text.) It should be noted that while R-410A and R-404A are not mentioned their components are… and if the components are phased down then the blends will be too.

Just like with other phase downs the approach is staggered over multiple years. The aim is to reduce usage based off of the baseline usage quotas from January 1st, 2011 to December 31st, 2013. The timeline is rather generous giving nearly sixteen years to achieve their final phase down goal. The proposed timeline in this bill looks like this:

Date% of Production Baseline% of Consumption Baseline
2020–202390 percent90 percent
2024–202860 percent60 percent
2029–203330 percent30 percent
2034–203520 percent20 percent
2036 and thereafter15 percent15 percent.

What is pushing this bill though folks is not the timeline but the benefits. Yes, according to the bill if we move forward with this plan to phase down HFC refrigerants then the United States will see thirty-three-thousand new manufacturing jobs created, billions invested into innovation/research, and over twelve billion per year in positive trade balance. At first glance who wouldn’t vote for this? It seems like a ‘jobs’ bill. Since its introduction I have seen very little arguments against it. It has been mostly positive from the larger players within the industry so it definitely got my attention when I found a dissenting opinion that was submitted to the Senate.

The Argument Against

At this point the bill is still in the Senate Environment and Public Works committee and has not been pushed to the Senate for a vote. In an effort to gain more knowledge on the industry and the impact of the potential bill the Senate introduced an information gathering session between March 25th and ending on April 8th. This period allowed submission of written testimony from any parties. There was also a similar period for questions to be submitted that ended on April 15th another period for answers to be submitted to the committee by April 29th (Tomorrow).

It was during the first period we had mentioned, March 25th to April 8th, that we saw the submission of a written testimony from Dave Stevenson at the Caesar Rodney Institute. The testimony can be found by clicking here or by visiting our sources page at the bottom of this article. There are a few arguments that he presented. The first is the assumption that if we pass this bill then the United States will become a leader in refrigerant technology which will cause a trade balance surplus in the billions. But as he argues, since the year 2000 the trade imbalance has been growing. Each year the United States is importing more and more refrigerant and related equipment while our exports are only slightly growing. The majority of these imports are coming from Mexico and Canada with China and Korea not too far behind. So, what will stop this from continuing? How will this bill incentivize these companies to start manufacturing in America again? Will we really see the new jobs that the bill promises?

The other argument, and the biggest one, is the factor of cost. As we all know the cost of HFC refrigerants versus the cost of HFO refrigerants is dramatic. For a perfect example just look at R-134a versus R-1234yf. R-134a can be anywhere from three to five dollars a pound. 1234yf can be anywhere between fifty to seventy dollars a pound. In the best case scenario we are still looking at a nine-hundred percent increase in cost.

Who will be paying this extra cost? All of this will be an extra burden on businesses and eventually end user consumers. Again, going with the car example we could see standard air conditioned repairs see their price tag raised by over a one-hundred dollars all because of HFC versus HFO refrigerant. Now imagine this extra cost passed on all air conditioning and refrigeration equipment found in homes, offices, gas stations, grocery stores, and everywhere else. There will be a significant impact to businesses and end users.


I believe Mr. Stevenson makes some valid points here. When the bill was proposed back in October I was very skeptical of the thousands of jobs and the billions of dollars of increased revenue. It all seems like a pipe dream that is told so that we can finally phase down HFC refrigerants. It is difficult to say if the promises in this bill will hold true. That being said, I believe we do need a comprehensive HFC legislation passed at the Federal level. Otherwise we are going to have a smattering of various state regulations that all vary slightly from state to state. This will make business difficult and burdensome for manufacturers and contractors. Having one centralized policy across the country will make things much easier for everyone.

Thanks for reading,

Alec Johnson



I was thinking about this very topic earlier today. As we all know HFC refrigerants are being phased down across the world. While we are still lagging behind within the United States we can be assured that HFC’s do not have much of a future. There are many states pushing their own individual legislation on HFCs as well as bills in the Senate and the House. We have seen it all before with CFCs and most recently HCFCs with the phase out of R-22 finalizing at the beginning of this year. It is something we have grown accustom too and something that many business owners have to adapt to.

There have been a few proposed solutions to replace popular HFC refrigerants such as R-404A, R-134a, R-410A, and R-507. The first is getting back to our roots and using classic refrigerants such as hydrocarbons, ammonia, or carbon dioxide. These refrigerants have all been tried and true and while they each have their own specific downsides it may be time to look at them again. Over the decades technology has improved these natural refrigerant systems. There aren’t as many failures in the high pressure carbon dioxide systems. There are more specific safety precautions and charge limits built into hydrocarbon systems. Best of all, these natural refrigerants are all nearly climate neutral. They have no Ozone Depletion Potential and very low Global Warming Potential. The obvious downsides is that they can be expensive when compared to artificial refrigerant systems and there is also the flammability, toxicity, and high pressure risks.

The other proposed solution and one which is taking on steam right now are the new classification of refrigerants known as Hydrofluoroolefins, or HFOs. These HFO refrigerants are synthetic refrigerants just like their HFC predecessors. The difference is that the HFO refrigerants are more environmentally friendly then the very high Global Warming Potential HFC refrigerants. One of the most successful HFC to HFO switchovers can be found in the automotive market. Rewind about six or seven years and every vehicle was using the HFC R-134a. 134a has a GWP of one-thousand four-hundred and thirty. Around 2014/2015 vehicle manufacturers begin switching their new models away from HFC 134a and over to the newer HFO known as 1234yf. This yf refrigerant has a GWP number of only four. That is a huge difference between the two refrigerants.

The Global Warming Potential scale is a measurement of how much impact a specific gas has on the environment, or more specifically on global warming. The common HFC refrigerants we use today are known as ‘Greenhouse Gases,’ or ‘Super Polluters.’ These gases contribute a significant amount to the warming of the planet, more so then standard carbon dioxide. In fact the GWP scale is based off of carbon dioxide, or R-744. R-744’s GWP is one. So, any gas that has a GWP number greater then one can be seen as harmful to the environment. This is precisely why we are seeing the phase down of HFC refrigerants across the globe.

Now we know that there are no perfect refrigerants and alternatives to HFCs are still going to measure on the GWP scale. It is now just a question of how much? In the example we gave above on automotive applications we saw that switching from R-134a over to R-1234yf we were able to shrink the GWP number by over one-thousand fourteen-hundred. That is a significant amount and I can see the HFO R-1234yf being used in cars in the distant future. This is what we want to see when moving applications away from HFCs and over to HFOs.

The question now though, and the reason I am writing this article, is what to do when a new alternative HFO refrigerant is suggested or used even though that new refrigerant still have a high GWP? Earlier today I was reading an article on how the National Hockey League has been transitioning their ice rinks away from their older R-22 or R-507 systems and over to a newer HFO refrigerant known as R-449A (Under the brand name of Opteon XP40).

This is all well and good but when I looked at the GWP of R-449A I was quite surprised. This HFO refrigerant has a GWP measurement of one-thousand four-hundred and forty-nine. That is NOT a low number. While, yes, it is significantly lower then R-404A and R-507 it is still high. Let us look at a few numbers here. R-404A and R-507 has a GWP of nearly four-thousand. By switching away from these HFC refrigerants and over to R-449A there has been significant impact on the environment. However, if we look at switching from an old R-22 system over to R-449A there is much less of a savings. R-22 has a GWP of around eighteen-hundred. The difference here is that when switching over to R-449A you are removing the Ozone Depletion Potential risk that you have with R-22.

My concern is for the businesses that are investing in these all new machines with HFO refrigerants. In the example of the article I mentioned above, lets say that an ice rink retired their old R-22 system and installed a new HFO R-449A system. While they are reducing their environmental footprint at the time what happens in the future when it is decided that refrigerants with a GWP of over one-thousand are no longer suitable? Or, let us go even stricter and say that refrigerants with GWP of no higher then five-hundred? Stricter regulations and laws are always being introduced on refrigerants and I just do not see it making sense to investing in a whole new system only to have it deemed as environmentally harmful in five, ten, or fifteen years later.

Now, I am not saying all HFO refrigerants are like this. There are many that have very low GWP just like the 1234yf that we had mentioned earlier. The question on my mind though is should businesses really be looking at these HFO refrigerants that come with a high GWP? If it was me then I would only look at the HFOs with a high GWP if I am aiming to retrofit my existing system away from an even higher GWP refrigerant. If instead I am looking to purchase a whole new system then I would either go with a natural refrigerant or with an HFO refrigerant that has a very low GWP number. This would significantly reduce risk of another phase out on the refrigerant you selected.


The table above shows the various HFO refrigerants out there and their related Global Warming Potential number. You’ll notice that more then half of them have a GWP of over five-hundred. How long will these refrigerants be around? Will they be sustainable in the future? Or, will they end up biting the dust just like CFCs, HCFCs, and now HFCs?

Thanks for reading,

Alec Johnson



RefrigerantHQ's Pressure Charts

One of the very first steps when it comes to diagnosing your home air conditioner, refrigerator, or even your vehicle’s air conditioner is understanding the temperature and the current pressure that your system is operating at. Having these facts along with the saturation point, the subcool, and the superheat  numbers for the refrigerant you are working on are essential when it comes to really understanding what is going wrong with your system.

After a visual inspection the very next step for the most seasoned technicians is pulling out their gauges and checking the pressure and temperature. It just becomes second nature after enough calls. I have heard stories of rookie techs calling some of the pros on their team for help on a system that they’re stuck on. It doesn’t matter what the situation is. It doesn’t matter if you’re in Miami or in Fargo. It will never fail that one of the first questions the pros ask the rookie is what is your subcool and what is your superheat? Having  and understanding these numbers is key to figuring out what to do next.

But, these numbers won’t do you any good if you don’t know what refrigerant you are dealing with and what the refrigerant’s boiling point is at each pressure level. This article aims at providing you with just that information.

R-449A XP40 Basic Info & PT Chart

R-449A is a non-azeotropic blend comprised of R-134a (25.7%), R-1234yf (25.3%), R-125 (24.7%), and R-32 (24.3%). This refrigerant falls into the new classification of refrigerants known as Hydrofluoroolefin family. You may also see R-449A labeled as XP40 or under the brand name Opteon which comes from the Chemours company. It has an A1 rating from Ashrae which means that it is one of safest refrigerants out there. (As safe as your standard HFC refrigerants like R-134a or R-404A.) This is a big point of note as most HFO refrigerants are either flammable or slightly flammable, but 449A is not.

This XP40 refrigerant was designed as a replacement for the commonly used HFC R-404A. The problem with R-404A is its immense Global Warming Potential of nearly four-thousand. R-449A is able to cut this number down to 1,397 which is almost a seventy percent reduction. It is also between eight to twelve percent more efficient then your standard R-404A systems.

Just like R-404A, R-449A’s primary applications range from industrial refrigeration and air conditioning over to commercial refrigeration found in your typical grocery store or gas station. It can even be used in ice rinks if needed. It can be used in new equipment and can also replace R-22, R-404A, R-507, and R-407A in existing equipment as long as the proper retrofitting is done. The good news is that the retrofitting procedure is quite simplistic compared to other alternative refrigerants. For a full retrofit guide click this link to be taken to the official Chemours official document.

Lastly, is your pressure temperature chart. As always if you see anything that looks incorrect please reach out to me and I will get it updated as soon as I can.

Temp (F)Temp (C)Liquid Pressure (PSIG)Vapor Pressure (PSIG)

Thanks for reading,

Alec Johnson


Earlier this week the United States Department of Commerce (DOC) made a preliminary ruling on hydroflurocarbon refrigerant components coming in from China. The components are brought into the United States and then mixed or blended domestically in an effort to get around the 2016 antidumping tariffs. The 2016 ruling installed tariffs on the blended HFC refrigerants themselves such as R404A, R407A, R407C, R410A, and R507A. Because this ruling did NOT pertain to the actual components of these blended refrigerants the United States saw an over four-hundred percent increase in imports of R-32, R-125, and R-143a in the years after the initial 2016 ruling. To top it off, there was also nearly an eighty percent decrease of finished HFC blends being imported into the United States. It was obvious to anyone watching that the tariffs from 2016 had no impact.

It was in early April of last year that a new antidumping circumvention case was launched with the Department of Commerce. This case focused instead on the actual components to create these refrigerant blends. After some months of debate the DOC announced an official inquiry investigation would began in June of 2019. Since then it had been relatively quiet up until this week where the DOC preliminarily found that the imports of these refrigerant components are indeed circumventing the previous antidumping order. As a result of this the DOC ordered that Customs and Borders Protection suspend liquidation on these imports and also require large cash deposits on imports of the impacted refrigerant components.

Now I’ll be the first to tell you that I am not an import/export expert. At the time of writing this article I wasn’t fully aware what liquidation was when it came to customs enforcement. But, like anything, it can be learned. From my understanding and research the act of liquidation with imports is an agreement between Customs and Border Protection and the importer on duties, fees, and tariffs of the shipment. The CBP normally has a 314 day period from the time of import to the date of automatic liquidation. During this time the importer and CBP may go back and forth determining the proper fees that are owed. After the liquidation has occurred though the importer can no longer be responsible for tariffs or other new fees that occurred after… unless:

The one-year statutory liquidation requirement may also be suspended by statute or due to court action. Actions that might suspend liquidation include countervailing or anti-dumping duty investigations. Because the entry remains open, the importer is liable for any duty orders resulting from resolution of these investigations.” – Source

This is exactly what the DOC ruled this week on these HFC component refrigerants. The DOC ordered CBP to suspend liquidations on R-32, R-125, and R-143a as of June 18th, 2019. (The initial date of the investigation.) What this means is that all of the products that were imported at or after June 18th, 2019 COULD be subject to tariffs if the Department of Commerce rules in favor of the antidumping duties. The DOC is also requiring cash deposits to be submitted in estimation of what the proposed tariffs will be (Ranging from 101.82 to 285.73%). Lastly, the DOC announced that their final decision on this has been pushed back to July 2nd, 2020.

As you can imagine there is still quite a bit that is unclear at this time. I cannot imagine the position business owners or importers are in if this gets passed. Having to pay duties on product that you brought in nearly a year ago… that has most likely already been sold. It is going to hurt. This holds especially true the way the economy is right now. This latest news this week has also caused the prices on HFC refrigerants to rise and rise. A major refrigerant manufacturer announced that they were suspending all of their published pricing until further notice. This just shows you how much of an impact this ruling had on the marketplace. Now normally when we see this huge price increase it starts to settle back down… and we may see that as the final ruling is still three months away.

Lastly, there is a glimmer of hope for some companies out there. The DOC has said that they may entertain exclusions to a positive antidumping ruling. These exclusions could apply to companies who import these components but claim that they are NOT blending the refrigerant and are using it for other means. There was also talk of exclusion if the company doing the importing is an HFC refrigerant manufacturer as well. This can get a little gray though as what constitutes a manufacturer? If I am blending in house does that make me a manufacturer? Personally, I feel like these exclusions could get us down a rabbit hole and eventually lead us to more loop holes for companies to get around tariffs.

But Wait Folks… There’s More!

Another angle of this story folks is that it is not just about China anymore. Yes, it really has always been about China but there has been yet another loophole found since the 2016 ruling on HFC blended refrigerants. This time we had companies importing the Chinese blended refrigerants into India and then American companies buying these products from India. Along with our previous topic there was a second preliminary ruling decided this week by the DOC:

Further, in response to a request from the American HFC Coalition (the petitioners), we initiated an anti-circumvention inquiry, pursuant to section 781(b) of the Tariff Act of 1930, as amended (the Act), and 19 CFR 351.225(h), to determine whether HFC blends, containing HFC components from India and China, that are blended in India prior to importation into the United States, are subject to the Order. Based on the information submitted by interested parties and the analysis below, we recommend that, pursuant to section 781(b) of the Act, Commerce preliminary find that imports of HFC blends R-404A, R-407A, R-407C, R-410A, and R-507A/R-507 produced in India using one or more HFC components of Chinese origin, that are blended in India prior to importation into the United States, are circumventing the Order.”

The full scope of this antidumping investigation covers HFC blends R-404A, R-407A, R-407C, R-410A, and R-507A/R-507 produced in India using one or more HFC components of Chinese origin. This investigation started on the same day of the previous one, June 18th, 2019. In some cases the companies were importing fully blended product from China to India and then to the United States.

In other cases though R-32 would be imported from China to India and then an India company would blend it with domestic R-125. They would then import the finished R-410A product from India into the United States. You see the first way of importing the fully blended product from China and into India didn’t work as well as they still had to state the country of origin on their commercial invoice… but by doing some of the blending process in India they could claim that the country of origin was India.

For the reasons discussed above, and in accordance with 19 CFR 351.225(d) and (k)(1), we recommend finding that R-410A from India is not within the plain scope language of the Order because the Order covers HFC blends from China. However, U.S. imports of HFC blends from India consist of components imported from China, which are further blended in India into subject HFC blends, prior to being exported to the United States. Therefore, we recommend that, pursuant to section 781(b) of the Act and 19 CFR 351.225(h), Commerce issue a preliminary affirmative circumvention determination that imports of HFC blends R-404A, R-407A, R-407C, R-410A, and R-507A/R-507 produced in India using one or more HFC component of Chinese origin, are circumventing the Order.”

At this time it is not known exactly what percentages will be installed on these imports from India but in the document was a referenced amount of 216.37 percent. If this does go into effect then the India manufacturer will have to prove to the CBP that they have not bought or imported any Chinese refrigerant components in the last twelve months. So, the proposed tariff isn’t necessarily on India… but China.


All of this folks just seems to be a game of whack-a-mole. It seems that when the Department of Commerce makes a ruling it only takes a few months for some businesses and companies to find a loophole to get around it. Everyone is looking for that competitive edge… even if it isn’t the most ethical way to do it. After this summer passes and these two anti-dumping cases have either been passed or rejected there will always be more. That I can assure you. Heck, just a few months ago there was another new antidumping filed on R-32. Who knows what the next one will be…

So, the only real question I have here is if retroactive duties are imposed can the companies who have been importing survive the hit? Can they survive those tariffs coming all at once? Or, will we begin to see a consolidation the marketplace by having some companies fold?

Thanks for reading,

Alec Johnson



Yesterday a Federal Court of Appeals ruled against the Environmental Protection Agency. This is a bit different then what we have seen over the past few years. In previous rulings the courts have been ruling against the Obama Era regulations and policies. This time though the court’s ruling struck down a rule made by the EPA during the Trump Administration. The court restored a prohibition on switching from ozone depleting substances to HFCs in uses such as large refrigeration systems in supermarkets.

In other words, lets say you have a supermarket that is running an old HCFC R-22 system. It needs to be replaced and soon before a major failure occurs. During the Obama EPA and up until a few years ago you would NOT be able to replace your R-22 system with a high Global Warming Potential HFC refrigerant as this was seen as harmful to the environment. Instead business owners had to work with more climate friendly refrigerants such as R-744, R-717, hydrocarbons, and the newer HFO lines from Honeywell and Chemours. These refrigerants had a low GWP number and had no Ozone Depletion Potential.

As most of you know, in 2017 a federal court ruled against the EPA’s suggested HFC phase down plan. The plan, known as SNAP Rules 20 and 21 aimed at phasing down high GWP HFC refrigerants such as R-404A and R-134a. About a year after this ruling the Trump Administration’s EPA announced that they would be rescinding all HFC regulations in response to the previous year’s court ruling. We also just saw another ruling by the EPA similar to this a few months ago when they announced they were removing the HFC leak regulations. (Article can be found here on this.)

In reference to today’s court decision, the EPA’s actions in 2018 allowed business owners to move their R-22 HCFC system over to an R-404A HFC system. This is what the court restored yesterday. The courts ruled that the EPA acted illegally in 2018 when it vacated this particular rule. The reason for their ruling was that the EPA did not allow for a notice and a comment period on their 2018 announcement to rescind the HFC regulations.

The case itself was pushed shortly after the EPA’s announcement in 2018. It was brought by the National Resource Defense Council (NRDC) and a collection of states with New York leading the way.  Obviously, I have not ready every page of the documents but I was able to pull some excerpts from the document itself as well as from some of the key players.

The Mexichem court struck down (or, “vacated”) only part of the HFC rule. It upheld and left in place other parts of the rule. But the Administrator lifted the entire HFC rule – even the parts the court approved. And he did it with no rulemaking. No proposal, no opportunity to comment. This is doubly unlawful. ” – Lissa Lynch from NRDC

Another quote, this time from the court ruling document itself:

Notice and comment rule making is a central part of the administrative framework set forth in the APA and the Clean Air Act. When an agency issues a legislative rule by exercising its delegated authority to establish new obligations with the force of law, it must follow these procedures. In the 2018 Guidance, however, EPA simply interpreted the immediate and necessary consequences of our decision in Mexichem and left rewriting the regulatory framework for future notice and comment rulemaking. Because the 2018 Guidance advised the public of the EPA’s interpretation of legal obligations created by this court, it was an interpretive rule properly issued without notice and comment procedures. I respectfully dissent.” – Source

One more quote this time going into what the EPA did in 2018 and how it did not require comments or follow proper procedures:

In 2015, EPA issued a regulation disallowing the use of HFCs as a substitute for ozone-depleting substances. That rule was challenged in our court in Mexichem Fluor, Inc. v. EPA, 866 F.3d 451 (D.C. Cir. 2017). We determined that EPA could validly forbid current users of ozone-depleting substances from  switching to HFCs. But we also concluded that EPA lacked authority to force users who had already switched to HFCs to make a second switch to a different substitute. We thus vacated the rule in part and remanded to the agency.

On remand, even though we had sustained EPA’s bar against use of HFCs with regard to entities who were still using ozone-depleting substances, the agency decided to implement our decision by suspending the rule’s listing of HFCs as unsafe substitutes in its entirety, meaning that even current users of ozone-depleting substances can now shift to HFCs. And EPA did so without going through notice-and-comment procedures.” – Official Court Document Source


So, what does all this mean? In the short term it means that business owners can no longer move their older CFC or HCFC systems over to HFC refrigerants. They will be forced to go with a lower GWP alternative. In the long term though it is quite uncertain. I was expecting a string of rulings in favor of the Environmental Protection Agency and the Trump Administration. I’m not advocating for that… it just the way the wind has been blowing lately.

Who knows though, maybe the winds have changed and we may begin to see a tighter grip on HFCs at a federal level.

Thanks for reading,

Alec Johnson



The other day I was reading an article from on the prospect of using R-290 propane in refrigerated transportation. The headline caught my eye and dragged me in. The company Transfrig has been experimenting with the idea of using R-290 propane in their refrigerated trucks. The idea is still in its infancy but I believe it has a lot of opportunity within the United States and the rest of the world.

The company Transfrig is based out of South Africa and has been around since 2002. They specialize in transport refrigeration and aim to be the number one choice for businesses within Africa. In recent years they have also expanded internationally to countries including Hong Kong, China, the Middle East, Libya, Liberia, Australia and Nigeria. In 2018 Transfrig was acquired by the automotive research group out of Paris known as Valeo.

The choice for R-290 for their new refrigerant was a unique one. They had originally looked at using R-744 but after some further research they decided they wanted to stay with a subcritical system. The hydrocarbon R-290 has been around for centuries and was one of the first refrigerants used before we saw CFC/HCFC refrigerants come to market. Propane is not going anywhere. It is also one of the best refrigerants out there when it comes to environmental impact. R-290 has a Global Warming Impact of only three and has no Ozone Depletion Potential.

Also, along with the lower GWP using R-290 for refrigerated transportation is more efficient then R-404A. In fact it has between a fifteen to twenty-five percent better coefficient of performance (COP) in medium temperature applications and between a ten to thirty percent COP increase in lower temperature applications. This increased efficiency also translates into around a sixteen percent savings in diesel usage. You get the benefit of having a very low Global Warming Potential refrigerant as well as having increased system efficiency for both the refrigeration system as well as the diesel engine.

The proposed unit from Transfrig uses a charge of only one point three to one point four pounds. That is an eighty percent decrease in charge when compared to your standard R-404A models. (A 404A unit could have between 6 and 8 pound charge.) Not only is R-290 cheaper then R-404A but you will also need less per recharge.


Obviously the biggest fear here when using a hydrocarbon like R-290 is the chance of ignition. Over the evolution of refrigerants certain countries have adopted use of hydrocarbons in everyday use while other countries, like the United States, have shied away from mainstream hydrocarbon usage. Here in the US we have always preferred safety over climate, but times are changing and the push for climate friendly refrigerants are gaining traction.

The good news here is that there are a few good points here to help alleviate some of these flammability concerns. The first is that we had mentioned earlier the charge of these systems is quite small at less then two pounds. That is about ten percent of the propane that you’d find in your standard grill tank. (Yes, I am aware that propane used on grills and refrigerant are different.) The point I’m making here is that it is quite a small charge.

You can look at this another way too folks, almost all new cars nowadays are using the newer HFO 1234yf refrigerant. This refrigerant is classified as slightly flammable and the typical charge on a car can range between one to four pounds of refrigerant. So, you are looking at either the same, or even a smaller, charge then what is already in your car that you drive everyday. It puts things into perspective.

Transfrig also understands the concerns of possible ignition. To compensate for this have have installed a leak detection system that alerts the driver if the system falls below fifty percent charge capacity. If this does happen an alarm sounds and it is then recommended for the driver to pull over, open the container hold, and let it air out. After some time it can then be driven to a dealer for servicing.

The prototype unit was tested over a one year period on a refrigerated truck from the Ola Ice Cream Company based out of South Africa. The article at puts the change of ignition at a thousand times less likely then that of an vehicular accident with the same truck. Throughout these tests there were no major issues found and since the test went so well the decision was made at Transfrig to migrate all of their refrigeration range of products over to the new R-290 design.

United States

As most of all you know HFC refrigerants, such R-404A, are on their way out. There has been countless debate and as back and forth on the United States’ HFC policies… but one thing is certain: HFCs do not have much longer and one of the top targets is R-404A.

Even if the Federal Government never comes up with an HFC phase down law it will not matter as there are so many states right now offering their own individual regulations and phase downs on HFCs. As the snowball begins to pick up speed we will see more and more states joining and mimicking other states policies. It will get to the point, if it hasn’t already, that it will not make financial sense to continue using HFC refrigerants. Why make one system for one state and another system for a different state? Business wise it makes sense to adhere to the strictest restrictions and be in compliance everywhere with your product.

So, what we will be left with is a hole for manufactures to fill. What refrigerants will be used instead of R-404A? In my opinion I believe R-290 has a legitimate chance. It makes sense. The only question now is can Transfrig truly prove their concept over the next few years… and if they do will United States government and importers take notice?

There are many folks who believe once a refrigerant has been chosen for an application then that refrigerant is it. Yes, it will never have one-hundred percent market share but it will have the lion’s share. There are many reasons for this but the biggest one is that it is just easier this way. Technicians only really have to become familiar with just a few refrigerants. There are very little surprises. Some of you may not agree with this statement, but we have a recent example to reference. Just look at R-134a’s transition over to R-1234yf. Yes, there are some outliers out there using R-744… but for the most part every new car is using R-1234yf.

Now that we are beginning to see the end of R-404A there is a hole in the marketplace when it comes to refrigerated transportation. Could R-290 fill this? There are a lot of hurdles to go through if Transfrig wishes to pursue. They have to test further. They have to roll trucks off the line and ensure there are no problems. Also, as I was writing this article I went and checked the EPA’s SNAP approved refrigerants on refrigerated transport. I was ninety-nine percent sure R-290 wasn’t approved… and I was right. So, they would have to through the EPA’s SNAP approval process as well before R-290 units could start being seen within the United States.


Let’s say though folks that we do end up seeing R-290 units in a few years across the globe and maybe even within the United States. What is the next step? If we are already using it in refrigerated trucks why couldn’t we use it in our vehicles as well? Remember how I said that R-1234yf was slightly flammable? Well… so is propane. The big difference here is that R-290 isn’t nearly as expensive as the HFO R-1234yf.

I’m going to throw some numbers out there and am also going to overestimate price on R-290 just so we can get a clear picture of the differences. Let us say that R-290 is about eight dollars per pound today. Then if we look at R-1234yf we can see that it is sixty dollars per pound. That is nearly a ninety percent savings when you go with R-290. Both refrigerants are flammable, both have very low Global Warming Potential, and both are Ozone friendly.

Now, I am not an engineer by any means, but I am wondering after researching this article… what is stopping us from using R-290 in our vehicles? If we can prove concept and go through the traditional SNAP approval process… why not? It would be an alternative to the 1234yf and it would save consumers a significant amount of money. What if, down the road, R-290 does get approved for vehicle usage? I could see a whole aftermarket industry dedicated to retrofitting away from 1234yf and over R-290.

Thanks for reading,

Alec Johnson



Over the past few years there have been a number of anti-dumping cases within our industry. In fact, there are a few cases open right now that are expected to come to conclusion in the next few months. Most of these cases focus on Chinese product that is being subsidized by the Chinese government and brought into the United States at unfair market prices. This dumping practice prevents the companies who are manufacturing within the United States from competing with the cheaper mass imported Chinese refrigerant.

In most cases within our industry these anti-dumping suits are approved by the Trade Commission. When a ruling is made in favor the Trade Commission initiates a tariff on the goods in question. The tariff itself can have a number of conditions and amounts associated to it, but the idea is to artificially raise the price of the imported product so that US companies can compete. Over recent years we have seen anti-dumping tariffs installed on R-134a, R-410A, R-404A, R-407C, R-507A, and many other refrigerates. There is also a pending anti-dumping suit on the popular HFC R-32 refrigerant and another one on the actual blending components used to create popular HFC refrigerants.

The one that was filed most recently though was something I had not seen before. Yesterday, March 27th, Worthington Industries filed an anti-dumping and countervailing duties case with the International Trade Commission. Their target was not refrigerants but instead the cylinders that they come in. These are the cylinders that all of our refrigerants come in. (Harmonized codes 7311.00.0060, 7311.00.0090, and 7310.29.0025.) More information on what types of cylinders:

“The merchandise covered by these petitions is certain non-refillable steel cylinders meeting the requirements of, or produced to meet the requirements of, U.S. Department of Transportation (“USDOT”) Specifications 39, TransportCanada Specification 39M, or United Nations pressure receptacle standard ISO 11118 and otherwise meeting the description provided below (“non- refillable steel cylinders”). The subject non-refillable steel cylinders are portable and range from 300-cubic inch (4.9 liter) water capacity to 1,526-cubic inch (25 liter) water capacity. Subject non-refillable steel cylinders may be imported with or without a valve and/or pressure release device and may be filled or unfilled at the time of importation.”

Worthington Industries is the last remaining United States company manufacturing non-refillable steel cylinders. Yes, they are it folks. If they stop producing cylinders then ALL of it is imported in. They are asking for a sixty-one percent duty to be imposed on the Chinese imports. I am sure most of you within the industry have heard of Worthington Industries before. They are a Columbus, Ohio based metals manufacturing company that had revenues exceeding three billion dollars last year. While three billion dollars is a lot of money… this is a business and if a certain product line is no longer profitable they will no longer pursue it. If this anti-dumping duty is not passed then Worthington may have to give up their cylinder manufacturing.

In yesterday’s filing there is a list of ALL nineteen companies that are importing these Chinese cylinders as well as the fifteen Chinese companies that are supplying them. The country of China would be targeted on these anti-dumping duties but we could also see the specific companies listed treated more harshly. This is pure speculation my part as the Trade Commission still needs time to review and even determine if they will be accepting the case.

This initial review on rather or not the Commission will begin an investigation is expected to conclude on April 16th, 2020. If they agree to move forward during this review they will then make a preliminary determination if damages were incurred on Worthington by May 11th, 2020. If the investigation moves forward it is expected to take around a year with a final decision to be made around April 21st, 2021.

I am quite curious on how this case will move forward. With the other refrigerant anti-dumping filings I had a pretty good idea on where the Trade Commission would settle. There has been a track record over the years that indicates that they will be voting in favor of refrigerant anti-dumping tariffs. But, this is the first time I have seen such a filing on the actual cylinders. The good news here is that the cylinders themselves are relatively cheap when compared to the actual cost of refrigerant. So, if a tariff does get put on the Chinese cylinders I do not believe it will raise the overall cost of refrigerants by very much.

Thanks for reading,

Alec Johnson


Counterfeit Refrigerant is a growing problem throughout the world.

The other day I was notified by one of my contacts that there has been a rash of counterfeit R-421A refrigerant within the United States marketplace. I always try to cover these stories as counterfeit product can end up hurting not only the original manufacturers but also the end-users. 421A is a patented refrigerant made under the brand name of Choice Refrigerants. It is an R-22 alternative that is designed for an easy retrofit/conversion away from R-22.

421A is an HFC blended refrigerant that consists of R-125 (58%) and R-134a (42%). Its pressures are nearly identical to that of R-22 which makes for ease of retrofitting. The temperature glide is quite low due to the blend only containing two relatively similar refrigerants. There is also no oil change required so you can continue using the existing mineral oil within the system. All those benefits aside, R-421A does have a significant Global Warming Potential number of  two-thousand six-hundred and thirty-one. So, it is not a perfect refrigerant – there never is one, but it is a very good choice when converting a system away from R-22.

As I had mentioned earlier, R-421 is patented and can only be distributed and supplied by Choice Refrigerants or an approved Choice Refrigerants distributor. Today there is counterfeit 421A product being distributed within the market. I will not get into what company is doing this, but the impact of this counterfeit product was significant enough to get Choice’s attention. This counterfeit product is not only infringing on the existing patent but it is also not the exact same formulation. This slightly different refrigerant can result in poor system performance and could even lead to damage to the system itself. Along with that, since it is counterfeit and slightly modified it is NOT approved by the Environmental Protection Agency’s SNAP program. That means that it is illegal to use or sell the counterfeit product.

R-421A Refrigerant
R-421A Refrigerant

Legal action is being taken against the companies that are distributing this counterfeit product. In the meantime though you can tell that it is genuine R-421A refrigerant product through a few ways. The first is actually asking for the specific brand name of Choice Refrigerants. This product is patented and cannot be sold under any other brand name. Another way to identify if the product is legitimate is by reviewing the packaging. The package should show the ‘Choice’ brand name as well as their tag line stating, ‘The Easy Choice.’ Lastly, every cylinder made by Choice Refrigerants comes with a QR code printed on it. This code can be scanned by your phone or computer and will take you to a product information page from Choice.

We at RefrigerantHQ are partnered with a certified distributor and if you are interested in purchasing or trying out the product please reach out to me by following this link to our contact page.

Thanks for reading,

Alec Johnson




It is amazing how quickly things can change in the course of a week or two. I was brought up to always follow the news and goings on within the country and around the world. I have been following the news on this virus since it first started making headlines in China. Like most folks I didn’t pay it much heed as I did not believe that it could come to the United States, or if it did then it wouldn’t have any impact on us.

When it started making headlines in Seattle it surprised me. My brother and his family are located just a few miles away from that unfortunate nursing home. I spoke with him the other day and his kids are out of school, his work has shutdown entirely, and his wife is working from home. For such a populated area it now feels like a ghost town. It has been this way for a few weeks but we still had seen no impact or change in things here in Kansas City. It wasn’t until the past couple days that things began to pick up here.

There were a few cases announced in the county where I work and a few additional in a neighboring county. I believe it was on Thursday where Kansas had its first reported death from the virus. My wife and son went to the grocery store on Friday to stock up on the essentials and it was a madhouse. Many people were panicking, for some reason. It seemed they had lost all respect for their fellow men. Businesses have already begun to shut down and I believe it is only a matter of time before they shutter the schools here as well.

This virus, along with the economic instability that comes with it, is now impacting everyone across our country and the world. At this point there is no telling just how long this panic will last. I am not worried about the virus itself. I am not a medical professional, but I believe this has been hyped up by the media to an extreme level. I can only hope that we will all begin to come to our senses. In the meantime all of us have to deal with the impacts of shuttered businesses and so called social distancing.

From what I understand there has been minimal impact on the pricing and supply side of refrigerants. This is good news, but the question is what impact will we see in HVAC industry overall? I was thinking about this yesterday and I do not believe there will be too much downturn. For an example, let’s look at grocery stores. The demand for food, toiletries, and supplies have been through the roof. So, that would mean the necessity of having running refrigerators and freezers at the supermarkets would be even higher then normal. The supply chain of reefer trucks to move the product between warehouses and stores will still have to flow. The warehouses will still need to store the product. The plants will still need to manufacture the product. The good news is that a lot of these businesses are operating at overload capacity. When that happens systems will break or fail sooner. This means repair bills, refrigerant recharging, and perhaps whole new installs.

As of now the supply chain looks to be intact. If that starts to crumble then things will get much worse for everyone and we will see all of this demand fall. Assuming the supply chain stays up and everything is fine on that front the other avenue I was thinking about is the air conditioning sector. If businesses are closed down then that means far less demand and far less chance of failure of commercial units. This could be in office buildings, department stores, or restaurants and bars. The demand from these customers on HVAC repair may dry up rather quickly.

The opposite side of the coin is with all of these folks staying home there is going to be much more demand on your traditional split systems. If this social distancing and working from home continues for months then we could see a sort of boom of air conditioner repairs at home. It is not yet hot here in Kansas City, but if we look at Miami I can see they are already in the eighties. Give it another month and folks will be turning on their air conditioners if they are not already. Imagine the impact of running air conditioners all day and night due to self quarantines. No more turning the AC up before you leave for work. This increased demand will no doubt cause an increase in failures.


In closing folks I think it is important to remember that so far this Coronavirus is very similar to previous timelines. If we go back to 2009 when the Swine Flu was in full swing there was not near as much panic. This is odd because if you look at the overall numbers of the Swine Flu they are very surprising. According to Wikipedia nearly seven-hundred million people were infected with the H1N1 Swine Flu from 2009. Out of those seven-hundred million there was an estimated three-hundred-thousand fatalities. (Some estimates as high as five-hundred-thousand.)

So far with this Coronavirus there have been around six-thousand deaths. It has been making headlines now for about ten weeks. Six-thousand deaths divided by ten and then multiplied by fifty-two gives us an estimated fatality rate for the year. This equals out to about thirty-one-thousand fatalities. For argument’s sake lets times that number by ten to account for compound growth since the virus is still relatively new. That puts us at around three-hundred-thousand deaths across the world.

Now, please don’t take this the wrong way. I am not trying to minimize anyone’s death to this virus. Each death is a tragedy. The point I am trying to make here is that this Coronavirus may not even surpass the Swine Flu pandemic that we had back in 2009. I honestly don’t even remember the Swine Flu from 2009… so I am hoping that this Coronavirus goes the same route and in a few months time we would have all but forgotten about it.

Thanks for reading folks,

Alec Johnson


The trend of recent years continues folks. Just a few days ago on February 26th Andrew Wheeler, the head of the Environmental Protection Agency, signed a rule on 608 refrigerant management regulations known as ‘Protection of Stratospheric Ozone: Revisions to the Refrigerant Management Program’s Extension to Substitutes.’

This version signed by Wheeler is not the final version, but there is little expected to change. It was sent to the Federal Register for final verification and once verified will be published for all to see. The draft rule can be found in our ‘Sources’ section at the bottom of this article. This announced change is not instantaneous. The leak detection and record keeping rules will change thirty days after the final version is published by the Federal Register.

The initial rule for leak detection on HFCs was announced by the Obama Administration’s EPA back in 2016. In essence, they copied the rules that were already on file for CFC and HCFC refrigerants such as R-12, R-502, and R-22. These new HFC rules applied mostly to commercial applications or businesses such as super markets, plants/factories, large refrigerated warehousing, ice rinks, and any other large scale operations.

With the repeal of this rule businesses across the country are estimated to save around twenty-four million dollars per year. (Source) That is a significant amount but another factor, that is very difficult to measure, is the overall peace of mind of these business owners and managers. They no longer have to worry about compliance or the threat of the EPA breathing down their neck. Let’s take a look at exactly what will change once the Federal Register has published the final rule:

Today, the following rules have to be followed for any appliance that holds fifty or more pounds of HFC refrigerants (Source from

      • Conduct leak rate calculations when refrigerant is added to an appliance.
      • Repair an appliance that leaks above a threshold leak rate.
      • Conduct verification leak tests on repairs.
      • Conduct periodic leak inspections on appliances that exceed the threshold leak rate.
      • Report to Environmental Protection Agency on chronically leaking appliances.
      • Retrofit or retire appliances that are not repaired.
      • Maintain related records.

Reading the above requirements can really illustrate just how many hoops and regulations that these business owners had to go through to stay compliant. Don’t get me wrong folks, I am not entirely against having these regulations. What I am against though is how they came about. Any of you who have read my posts in the past know exactly how I feel about this. But, for those who aren’t as familiar with what I am talking about let us review.

The EPA and the Obama Administration used the Clean Air Act as their basis for authority when it came to phasing down and the regulation HFC refrigerants. Herein lies the problem though. The Clean Air Act sections that they were referencing strictly refers to Ozone Depleting Substances. These are your CFC and HCFC refrigerants such as R-12, R-22, R-502 that we all saw get phased out over the past thirty years.

Here’s the thing though… HFC refrigerants do not harm the Ozone. Not in the slightest. HFCs do harm the environment though, just in a different way. HFC refrigerants are known as super-pollutants or greenhouse gases. They directly contribute to Global Warming when they are vented or released into the atmosphere. So, they do cause a problem… but they do not cause any problem to the Ozone.

This reasoning is what the current EPA used when repealing the Obama era regulations. They claimed that the EPA overstepped its authority when introducing these HFC laws. I agree with them. While their intention was good back in 2016 it was NOT the right way to go about it. It was an overreach of the government. Just like with everything though, there is an opposing argument. This argument comes from those who are in support of the 2016 leak regulations. Their argument is that the Clean Air Act authorized them to regulation Ozone depleting substances AND their replacements. Those last two words are where the debate comes from.

I am not going to get into who is right here and what side should win. Let us instead just look at the facts. The EPA is entirely biased depending on what administration is in control. It was biased for Obama and now it is again for Trump. So, the real question is will we see all of this change again after this year’s election cycle? Who knows…

Purchase Restrictions?

When the EPA originally announced last year that they would be looking at rescinding the HFC leak regulations there was also talk that they may rescind the Obama era purchase restriction on HFC refrigerants. I am sure everyone remembers when anyone could go out and buy a cylinder of R-134a or R-410A and keep them on hand for those just in case situations. On January 1st, of 2018 the option to purchase HFC refrigerants without being either 608/609 certified with the EPA went away.

No longer could anyone purchase refrigerant cylinders. They could still purchase smaller quantities like cans, but the option to purchase those large cylinders was gone. This was again an example of the EPA moving the original regulations on CFCs and HCFCs over to HFCs. Overall, I think this had a positive effect on the industry itself. Yes, there was less demand but the contractors who were selling refrigerant to their customers could enjoy that extra mark-up without the risk of the customer purchasing their own cylinder.

I am in favor of removing the purchase restriction. It opens the market back up and, to be honest with you, before the restriction I was selling quite a bit individual cylinders on this website. It’d be nice to have that revenue stream open back up again! Regardless of my opinion though, it is looking like the purchase restriction may be rescinded as well. After all, if they removed the leak detection requirements why not remove purchasing as well?


The announcement of this rule change by the EPA is only going to fuel the United States Climate Alliance. The Climate Alliance is a grouping of states across the country that was formed a few years ago when the Trump Administration announced that the US would be pulling out of the Paris Climate Accord. This alliance is dedicated to all forms of climate protection but one that has seen recent activity are regulations on HFC refrigerants.

With the removal of the EPA’s SNAP Rules 20 and 21 the Climate Alliance stepped up to the plate and began announcing their own HFC phase down laws. California, as usual, was the first of these states. It all began a domino effect though and we are seeing more and more states either pass HFC phase down legislation or announce that they are working on their own version. Just a week or so ago it was announced that Maine, Massachusetts and Rhode Island are all working on their own version of regulations. In most cases the phase down laws closely mimic the original EPA’s SNAP Rules 20 and 21 but there are some states, like California, who went for a stricter approach.

One thing is certain, the Federal Government and the States are heading towards very different goals. If we keep seeing these EPA regulations repealed then we will begin to see more and more states announce their own plans and all of these Federal changes won’t mean squat. But hey, at least the states are going about this the right way and not trying to circumvent the law by using the Clean Air Act as a cover.

Thanks for reading,

Alec Johnson




During the summer of last year I wrote an article on the most recent anti-dumping petitions to be filed on HFC refrigerants. Anti-dumping petitions are nothing new to the refrigerant world. In fact there have been a slew of petitions filed over the past ten years. These range from R-134a, R-410A, R-404A, and other common refrigerants. Last year’s petition focused on the actual blending process on tariffed refrigerants. Most recently, just last month, another petition was filed this time on the HFC R-32.

There are now three major anti-dumping petitions out there. The first is a potential duty being installed on the blending process of common HFC refrigerants such as R-410A and R-404A. The duty would apply if the required refrigerants were imported from China and then blended within the United States. This would prevent the circumvention of already established duties on completed HFC blended refrigerants. A final ruling is expected on this petition by April 7th, 2020. I would highly expect the Trade Commission to rule in favor of anti-dumping duties on this. It is the logical decision based on their previous rulings.

Unfinished Blends

The second petition is similar to the first only it targets ‘unfinished blends’ being imported in from China. The term unfinished blends is rather ambiguous, but it basically means HFC blended refrigerants that are either already fully blended or are partially blended. This can get rather shady. What classifies a blended refrigerant as unfinished or finished?

There was a refrigerant distribution company that was importing blended refrigerant from China but labeling it as ‘unfinished blends.’ (I will not state this company’s name within this article.) It was unclear exactly what this company was doing to the product once it had reached the United States. How did it go from an unfinished blend to a finished blend? Was there a process involved at all, or was this just a clever way of skirting around the previously ruled anti-dumping duties on blended refrigerants?

The other refrigerant distributors out there were importing R-32, R-125, R-134a, R-143a refrigerants into the United States. Once there they would blend the refrigerants themselves to come up with R-410A, R-404A, R-407A, R-407C, etc. While this was still using a loophole from the previous rulings it was not a flat out deceit such as importing unfinished blends was.

The company involved in this petition declined to comment on a questionnaire that was sent to them. Because there was no reply the International Trade Commission announced a preliminary ruling on the case last week. Their ruling stated that:

“The Department of Commerce (Commerce) preliminarily determines that imports of unfinished blends of hydrofluorocarbon (HFC) components R-32 and R-125 from the People’s Republic of China (China) are circumventing the antidumping duty (AD) order on HFC blends from China. As a result, imports of blends of HFC components R-32 and R-125 from China will be subject to suspension of liquidation effective June 18, 2019. We invite interested parties to comment on this preliminary determination.”

“For the reasons described below, we preliminarily determine, pursuant to section 781(a) of the Act, that imports of unfinished blends of HFC components R-32 and R-125 from China are circumventing the Order.”

The final ruling on this case is expected in April as well, but at this time it looks like the International Trade Commission will be ruling against these unfinished HFC blends. Hopefully this is the last of the ‘unfinished HFC blends’ being imported into the United States.

R-32 Petition

Finally, the last and third petition is the most recent one. I touched on this one earlier but this petition was announced just last month and it focuses on the HFC refrigerant R-32. R-32 is a critical component when it comes to some of the most popular HFC refrigerant blends. As an example, R-410A is fifty percent R-32. If this petition is ruled in favor of we can expect to see a significant impact to the cost of refrigerant throughout the US market.

Within the petition it was stated that in the year 2018 there was an estimated twenty-one and a half million dollars worth of R-32 imports brought into the United States. I would say that nearly all of that imported refrigerant is being blended into HFC refrigerants that have duties assigned to them. (There is little stand alone R-32 applications in our market at this time.) This R-32 petition does seem a tad redundant though considering there is already a petition out there on the actual blending process. Who knows though, this latest petition from Arkema could be an insurance policy in case their petitions from last year fall through.

I am not sure how this one will go. If the ITC rules in favor of the blending petition then why would they bother with this one as well?  We may see this one tossed out if the blended petition goes through. On the other hand, like I said earlier, if the blended petition falls through then Arkema has a fall black plan. I can only imagine what would happen to the price if both petitions were approved.

The International Trade Commission is expected to make a market injury determination on March 6th, 2020. If injury is found then the ITC can expect to make a preliminary determination on July 2nd, 2020. Lastly, if everything goes how it should a final ruling will be scheduled for October 5th of this year. If the ITC rules in favor of anti-dumping duties on R-32 then they could take effect on November 5th. The expected duty is 87.98 percent.


Ok, so I went through all of that and now my mind is spinning. There is a lot to these petitions and I have read through a number of documents that folks have sent my way. I believe I have a pretty firm grasp on the matters, but if I missed something or misstated something in this article please let me know! I intend for this to be accurate and do not like to  have errors within the article. Feel free to contact me via e-mail.

Thanks for reading,

Alec Johnson


I apologize for two e-mails in just a couple of days but  it has been a busy week in refrigerants! Last week on the 23rd the Arkema Corporation filed a new petition with the United States’ International Trade Commission. For those of you who have followed this saga over the past few years you won’t be surprised that this was yet another anti-dumping petition.

This time the petition focuses on the HFC R-32. Arkema is stating that R-32 imported from China is being brought in at an unfair price and is causing the market and prices to crash. This mass import prevents domestic manufacturers, like Arkema, from selling their product… and if they are able to sell it is at very low margins. From what I have ready while doing research on this article it appears that Arkema is the ONLY domestic manufacturer of R-32 within the United States. (They have a plant in Calvert City, Kentucky.) If you know otherwise please let me know.

In this latest petition Arkema asks for a ninety percent anti-dumping levy put against Chinese R-32 imports. That is a hell of an increase, but some of you may be wondering why are they focusing on R-32? Why aren’t they focusing on the more popular HFC refrigerants like 410A? Well folks to understand that we have to travel back in time to 2016. Back then there was a similar case sent to the United States Trade Commission. This case was anti-dumping on R-410A. Arkema and others won this petition and anti-dumping levies were issued against Chinese R-410A .

The problem here though was that these levies were issued only against the fully blended R-410A refrigerants. The levy did NOT apply to the components of these blended refrigerants. What that meant was that you could import Chinese R-32 or R-125 into the United States without any levies or tariffs applied. So, what happened was that we had distributors and importers shipping in these components in mass and then blending them at their facilities within the United States. This got around the anti-dumping levies entirely and kept the market at rock bottom prices.

In 2018 the mistake was realized and the interested parties began to form a new plan. In April of 2019 a new case was filed by the HFC Coalition  with the International Trade Commission. This one was slightly different. This time it aimed to add the levies to any imported refrigerants that were then used as components for blended refrigerants.  An excerpt from the filing reads as follows (Source):


So this time folks they got a bit smarter and went after the actual components of refrigerants. The outcome of this case is still pending and a ruling is expected sometime this spring. Meanwhile, this new petition was filed just last week. As we said earlier, this one doesn’t focus on the blending process but instead solely on R-32. R-32 is the key ingredient when it comes to blending R-410A. So, if this does pass then we can all expect a hefty increase when it comes to pricing.


The question is will these new petitions work? If you ask me I say they will. I believe that the initial ruling back in 2016 was an oversight by the courts and by those who filed it. When they ruled for levies on R-410A I am sure that it was meant for the components as well… but that’s not how the law works. There are loopholes.

If they had ruled in the past that Chinese imports were damaging the market why would they not rule that way again on a more specific matter? If these rulings do come through what will be next? Can we expect to see a new petition filed on R-125 as well? And, even if all of these petitions work are businesses and consumers ready to pay those higher costs for the American made product? Time will tell…

Thanks for reading,

Alec Johnson



New Jersey

Last Friday, the 26th of January, New Jersey Governor Phil Murphy signed into law Senate Bill 3919. This law mimics the Environmental Protection Agency’s SNAP Rules twenty and twenty-one. The New Jersey bill does have not specific dates set yet for each of the proposed phase downs. These will be released at a later time and will have to be modified from the EPA’s original dates.

This now brings the total up to five states who have now signed into law various HFC phase down measures. These include California, Washington, New York, Vermont, and now New Jersey. There are many more to come though folks as all of these states belong to what’s called the Climate Alliance. This Climate Alliance was formed in the summer of 2017 shortly after the Trump Administration pulled the United States out of the Paris Climate Accord.

The states that joined this alliance disagreed with the Trump Administration and announced that they would be taking their own individual state action. Their goal would be to honor the pledges made in the Paris Climate Accord as well as other climate treaties and regulations. As of today there are now twenty-three states in this Climate Alliance. This is important because all of the states that have moved forward on phasing down HFCs were part of this alliance and that the other states within this alliance have announced that they are looking towards HFC phase downs as well. It is just a matter of time before another state announces their HFC phase down plan.

We are beginning to see the domino effect here folks. But why? Why hasn’t the Federal Government or the EPA’s rules gone into effect? Well, to answer that I’ll have to give a bit of a history lesson. The infamous EPA SNAP Rules twenty and twenty-one were introduced in 2015. These rules were the initial HFC phase down regulations. They mainly targeted R-134a and R-404A. 404A wouldn’t be acceptable in new applications as of a certain date and R-134a wouldn’t be acceptable in automobiles as of a certain date.

When these new regulations were introduced it was taken as the law of the land and the industry moved forward. It wasn’t until the summer of 2017 that everything changed. You see there was a lawsuit brought against the EPA and their new SNAP rules. The suit stated that the EPA had overreached its authority when it came to phasing down HFC refrigerants. The EPA had cited authority from the Clean Air Act and the Montreal Protocol Treaty but both of these documents only referred to Ozone damaging substances. There was no mention of Greenhouse Gases or refrigerants with a high Global Warming Potential (GWP).

The EPA had truly stretched their authority here and the federal courts saw it this way too. The EPA’s SNAP rules twenty and twenty-one were overturned and the national HFC phase down was gone in a blink of an eye. Now on one knew what to do or what to expect. The industry had operated for the past two years on the knowledge that HFCs would be phased down shortly and now all of that was gone.

There were multiple appeals on this federal court ruling but they were all rejected. One such appeal went all the way to the Supreme Court but the court refused to hear it… probably because it was so cut and dry that the EPA overreached its authority. The other chance to phase down HFC refrigerants came from what’s known as the Kigali Amendment. This was an amendment to the Montreal Protocol that aimed at phasing down HFC refrigerants on a global scale… just like we did with the Montreal Protocol back in the 1990’s and 2000’s. The problem with the Kigali though is that it has never been sent to the United States Senate to ratify. The Trump administration has sat on it for years and they have shown no intention to send it to the Senate.

But wait folks, there’s more! As I write this article there are now two separate HFC phase down bills in the United States Senate and the United States House. Both of these bills more or less aim to accomplish the same thing: Give the EPA the power to phase down and phase out HFC refrigerants. So far these bills have stalled and do not look to be going anywhere. Even if they do pass both houses and a joint bill is reached chances are Trump will veto it and then we will be back to where we were earlier.

So, we are now left with states’ rights. Politically, I am a big states’ rights guy anyways. This is why we are seeing individual states come out with their own laws. As more time passes additional states will come aboard with their own HFC phase down plan. As more states join manufacturers will be forced to adapt to these states’ new requirements and regulations. What that means is that we will eventually get a national phase down rather we like it or not.

This will be a battle of convenience to the manufacturers out there. Is it easier and cheaper to comply with the strictest regulations and be able to sell in all fifty states? Or, do you stick with the status quo and only be able to sell your product in forty states? How many manufacturers are willing to write off the California and New York market? Not very many I’m guessing. This is why we will see these manufacturers actively start moving away from HFCs even without a federal program.

So, in closing folks… there is no need for a federal or EPA plan. Let’s just keep this going with States’ Rights and eventually over time HFCs will be a thing of the past… rather you like it or not.

Thanks for reading,

Alec Johnson