Let me preface this article by saying that this information is as of today, December 14th, 2017. This information may change in the future as it usually does but the facts that I present here are what is known today. In the summer of 2015 the Environmental Protection Agency added a new rule to their Significant New Alternatives Policy. (SNAP) This new rule, labeled Rule 20, was designed and targeted towards phasing out Hydroflurocarbon refrigerants. HFC refrigerants include some of the most popular refrigerants used today such as R-404A, R-410A, and R-134a.
The basis of these new phase outs are different from previous CFC and HCFC refrigerants. The HCFC/CFC’s were banned due to the Chlorine that they contained. The Chlorine actively damaged the Ozone layer when released into the atmosphere. While HFCs do not contain Chlorine they do have an extremely high Global Warming Potential, or GWP.
GWP is basically a measurement of how much greenhouse gas a certain chemical traps in the atmosphere. Every scale has to have a ‘zero’ measurement point and for GWP we use Carbon Dioxide, or CO2. CO2’s GWP is set at 1. That is our base line. Some HFC refrigerants on the market today have a GWP number of nearly 4,000. Think about that for a moment. If the refrigerant is released into the atmosphere it has 4,000 times the effect of Carbon Dioxide. You can easily see how governments and scientists began to grow concerned.
Like with most scheduled phase outs by the EPA the approach was staggered over different refrigerants and different applications. The thinking here is to allow businesses, contractors, and consumers to have time to adapt to the changes. If they were to flip a figurative light switch from on to off then chaos would ensue. Business owners would protest due to the cost. Contractors would protest due to the lack of training and available resources on the new refrigerants. End user consumers would complain. It would be an all around catastrophe and the EPA would lose all backing when it comes to scheduled refrigerant phase outs.
The staggered approach allows people to adapt and it also allows these same people the benefit of foreseeing and planning for the future. Typically, when a phase out is scheduled it is years in advance. So, if a phase out was announced today on XYZ refrigerant the actual phase out most likely wouldn’t begin until 2020, at the earliest. This was the case for the HCFC refrigerant R-22 and it is the same case for HFC refrigerants under the SNAP Rule 20.
R-404A’s Phase Out Date
Well folks, as I explained above there is no cut and dry date when it comes to R-404A being phased out. Each type of application has a different set of rules and years that are associated to it. The EPA has provided an official fact sheet on their Rule 20 and the phase outs associated to it. It can be found by clicking here. This is a large document consisting over six pages with a lot of text, so to make things a little easier I’m going to break it down for you below in the next section. If you prefer to read through the document though by all means go for it! Below are the various phase out dates of R-404A. (Please note that this is strictly for the United States. Other countries will have differing dates.)
- Retrofitted supermarket systems as of July 20, 2016;
- New supermarket systems as of Jan. 1, 2017;
- Retrofitted remote condensing units as of July 20, 2016;
- New remote condensing units as of Jan. 1, 2018;
- Retrofitted vending machines as of July 20, 2016;
- New vending machines as of Jan. 1, 2019;
- Retrofitted stand-alone retail food refrigeration equipment as of July 20, 2016;
- New stand-alone medium-temperature units with a compressor capacity below 2,200 Btuh and not containing a flooded evaporator as of Jan. 1, 2019;
- New stand-alone medium-temperature units with a compressor capacity equal to or greater than 2,200 Btuh and stand-alone medium-temperature units containing a flooded evaporator as of Jan. 1, 2020; and
- New stand-alone low-temperature units as of Jan. 1, 2020.
Remember at the beginning of this article that I said that all of this could change? Well, there was some drama over the summer of 2017. In August a federal court ruled that the EPA’s SNAP Rule 20 overstepped the EPA’s authority. The ruling in essence overturned the EPA’s Rule 20 and removed the planned phase outs of HFC refrigerants. In the SNAP Rule 20 the EPA used Section 612 of the Clean Air Act for their justification. This section of the Clean Air Act strictly specifics on products that contain Chlorine or that cause damage to the Ozone layer. HFC refrigerants do not contain Chlorine nor do they cause ANY damaged to the Ozone. The courts looked at this and ruled in favor of the filing companies, Mexichem and Arkema, and against the EPA. I wrote more in-depth on this ruling in a previous article that can be found by clicking here.
At the time of the ruling and shortly there after no one knew what was going to happen. Everything was up in the air. It was about a month later that an appeal was filed to the court’s ruling. On September 22nd, 2017 Honeywell and Chemours officially filed an appeal to the ruling. I wrote an article about this as well which can be found by clicking here. A few days later it was announced that the court’s August ruling would be overturned until a decision was made on the appeal. (Click here for more info.) So, we are back to square one and it’s like nothing even happened in August.
The question is what will happen next? What will 2018 bring? Will the phase outs continue? Or, will the court rule against Honeywell, Chemours, and the EPA? Personally, I hope that the court’s ruling stands and that we go through Congress to phase out HFC refrigerants. It’s the right thing to do instead of having a government bureaucracy force the rules upon everyone all the while using an outdated section of the Clean Air Act.