HVAC Residential Market / Air Conditioners / Air-Source Heat Pumps / Refrigerants & Reclaim / Standards & Legislation

Carrier Asks EPA to Stop Dry R-22 Units

June 13, 2011
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AHRI President and CEO Steve Yurek (left) talks with Carrier Vice President John Mandyck about a recently filed petition by Carrier with the Environmental Protection Agency.

Carrier Corp. recently filed a petition with the U.S. Environmental Protection Agency (EPA), formalizing a request to reclassify a residential condensing unit as a subsystem of a system to extend the manufacturing prohibition to dry R-22 condensing units. “The petition urges EPA to reconsider its current position and to issue a new rulemaking effective January 1, 2012,” said John Mandyck, Carrier vice president, sustainability & environmental strategies. “In our opinion, the rule as it currently exists is not in-line with the intent of the long-planned phase-out of R-22, nor is it in-line with the Clean Air Act’s mandate to curtail the use of ozone depleting substances.”

The effect of the Carrier action could serve to solve an industry dilemma - what to do about dry R-22 units.

In the middle of 2010, some manufacturers began producing R-22 equipment that did not contain refrigerant. These dry-shipped units exploit a loophole in the original EPA ruling of 2009 - designed to curtail use of R-22 - which stated that entire systems could not be manufactured and that any replacement components for aftermarket use could not be pre-charged with the refrigerant. As a result of allowing R-22 units back into the free market, industry sources, including a component manufacturer, equipment manufacturers, refrigerant manufacturer, and the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) have estimated the number of dry R-22 unit shipments in 2011 could represent between 10 and 20 percent of annual sales, possibly upwards of 700,000 units.

Mandyck said, “We think this is bad policy. The unintended consequence of this loophole is to encourage the sale of new R-22 condensing units, which the industry has been preparing to phaseout for more than a decade. The EPA never could have intended for all condensing unit manufacturers to re-enter the R-22 market, and we would like them to take action now to close the loophole.” Mandyck noted that Carrier was forced to restart the manufacture of R-22 condensing units after several competitors re-entered the market. “It became clear to us that the market was moving faster than the government could act, so we moved with the market to remain competitive, but if EPA banned the manufacture of dry R-22 condensing units today, we would support that move.”

Carrier believes this problem was created when EPA changed the definition of a condensing unit to a component. “In our view, a condensing unit is much more than a component. Eighty percent of the cost and technology [of a system] is really in the condensing unit,” said Mandyck.

“We took it upon ourselves to file the petition because we believe strongly in the initial intent of the Clean Air Act when it comes to the phaseout of R-22; we welcome anyone who is concerned about the issue to support us.”

Mandyck said that Carrier, other manufacturers, contractors, and distributors had all invested in new technologies and training in order to prepare for a 20-year expectation that R-22 would be phased out. Mandyck said “Non-ozone depleting condensing units are available from every manufacturer and have been sold and installed for more than a decade with an excellent performance record. This is not a situation where the industry is searching for a technology solution. The answer is there - we simply want the regulations to apply as we all thought they did.”

“Carrier filed the petition to be consistent with that belief. We also did so because of our support of ozone protection, and for energy efficiency - the replacement of a condensing unit without replacing the indoor coil was a step in the wrong direction,” said Mandyck. “Consumers won’t be getting the energy efficiency they think they are buying.”


According to Mandyck, Carrier met with EPA more than a month ago, at which time the agency “asked a lot of good questions.” The EPA indicated it would evaluate and respond to the petition.

Drusilla Hufford, director, Stratospheric Protection Division, U.S. Environmental Protection Agency said, “We have met with Carrier since receiving the petition, and are evaluating additional information provided not only by Carrier, but by others in the environmental community. No final resolution date is available at this time, but EPA is carefully considering this petition.”

Mandyck encouraged contractors to understand the issue and get involved. “We have all prepared; manufacturers invested in technology, contractors invested in training, and now that is all up in the air. We are 16 months into this issue, and still don’t have anything past a preliminary guidance from DOE as to how to rate the efficiency of the dry R-22 units. How are we supposed to view the next regulatory movements from the government? This issue has created a lot of uncertainty,” said Mandyck.

In September 2010, AHRI answered a request by EPA to submit an analysis of the consequences of the action. The response letter showed that if dry R-22 units were to represent 20 percent of shipments, that nearly 10 percent of the gains from the 13 SEER rulemaking (January 2006) would be wiped out. It also showed that if the market would grow to 80 percent, nearly one-third of the efficiency gains would be negated.

When asked about coordination with the U.S. Department of Energy regarding the impact on energy efficiency that projected dry R-22 unit sales will have in the market, Hufford said, “EPA understands that to achieve the best energy efficiency, outdoor condensing units must be properly matched with the indoor coils. The HVAC industry has done a very good job of emphasizing that over the last 10 years, and EPA wants to also help ensure that this practice continues.”

The losses would be the result of mismatching of indoor/outdoor coils - the AHRI sensitivity analysis showed that an additional emission of 2.5 million metric tons of CO2 would result from the mismatching of coils at the 10 percent shipment level, and 10 million metric tons at the 80 percent level.

With the continued manufacture of R-22 units, it is thought by some that prices will increase, and availability could tighten as a result. Mandyck also said, “By proliferating R-22 use, we are pushing the problem of service availability into the future. There is a step-down schedule we are following; in 2015 we have a huge drop to 10 percent of our 1989 baseline production of HCFCs. By pumping more R-22 units into the marketplace now, we are exacerbating the problem.”

According to information provided during a recent webinar sponsored by DuPont and The NEWS, sales of R-22 replacement refrigerants have grown at a 46 percent compound annual growth rate in North America, and this does not include R-410A.

According to Mandyck, an additional benefit of stopping production of dry R-22 units is to comply with ozone protection. “It remains a critical threat to our planet - the Arctic is in danger of record loss of ozone this year. Most common losses had been associated with the Antarctic region, but that has begun to change. We have to remain vigilant,” said Mandyck.


In November 2009, prior to the final EPA rule, AHRI’s Unitary Small Equipment Product Section classified all R-22 systems as discontinued as of Jan. 1, 2010 and removed these listings from the AHRI Directory as of Dec. 31, 2010. This meant that dry systems would not be certified by AHRI or listed in the AHRI Directory. Following issuance of the EPA rule, AHRI met with agency officials to encourage them to close the exception to the sale of non-charged R-22 condensing units for air conditioning applications. After the EPA made it clear that it would not do that, the Unitary Small Equipment Section in November 2010 re-visited its November 2009 decision and voted to return R-22 products to the scope of the AHRI Certification Program, thereby requiring dry R-22 models to continue to be listed in the AHRI Directory of Certified Product Performance. The R-22 models certified by AHRI and displayed in the AHRI Directory are High Sales Volume Tested Combinations (HSVTC) only with no mix match coil listings.

Publication date: 06/13/2011

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R-22 Units

Steve Wilson
June 13, 2011
REALLY? Now a manufacturer decides to Live up to the spirit of the law? I'm sorry, I Think it is a little late to try to be the conscience of the industry. This is definitely not our finest Hour. Shame on the EPA, and shame on every Manufacturer that circumvented the spirit of the Montreal Protocol! All of us look like gypsies, Tramps and thieves.

Carrier is full of cr#p

June 14, 2011
Like carrier's not selling R22 units in latin america, china and god knows where charged with 22. $ is what its all about like always. a bottle of whisky and a blonde and there won't be any more dry 22 units. drink up epa

Carrier in the Role of a THIEF

Stuart Gupton
June 14, 2011
As a contractor I do not care what the manufacturer thinks. They have made the decisions in the past and we, the contractors, are the bad guys who have to sell it to the customer. I cannot see making a customer with a 5 year old AHU completely change out the system because the heat pump or condensing unit goes bad.

epa is full of cr##p

June 14, 2011
we should have stayed with r-22.the montreal protocol is just another way for big government to get in our pockets.no wonder china can make everything cheaper than us.

Dry R 22 Units

June 14, 2011
Carrier decided to not sell the dry units in North America probably because The sell of those units was hurting the sells of the new 410 a units. The probably produced a ton of 410A units and need to move them. My answer to them is to lower the cost of those systems so the low to middle class costumers can afford them.Their should have been an effort to produce a verifiable replacement for the 22 units instead of shoving the 410A units down the throats of our costumers.

Big Biz in pocket of Government

Jerry Fenley
June 14, 2011
It's time to wake up the small business community & tell the EPA what they can do with "Global Warming" legislation! Not too long ago, R-12 was the evil culprit. By coincidence, the patent on R-12 had long expired. R134A was the savior. Now 134A is labeled as bad and auto manufacturers will be changing to HO1234YZ beginning in 2012. Why? you ask. They say its because 134A is now BAD as well.(Guess what, the patents for R-134A have expired.) Do you smell U.S. protectionism here? Government/Refrigerant manufacturer collusion? It wreaks of it!!! R-22 is a great refrigerant, proven, cheap to make and abundant. Global warming is natural. (Any temperature control expert understands energy is in constant motion, moving from hot to cold & from higher pressures to lower pressures. Since the Earth is always turning in front of a big heat lamp, her heat balance is shifting constantly, whereby controlling our weather patterns. there is absolutely NOTHING that little ole man can do to effect the abundant power & energy in our earthly environment. (BTW-In order to calculate heat transfer rates, one must know the heat content of the ambient space where the heat is to be removed.I was wondering how many BTUH of energy the sun is rejecting....I wonder how many gallons of water are in the ocean absorbing & rejecting this heat everyday and at what rate of heat transfer - "Tons"....) Does anyone have a pocket calculator for fast estimating these parameters? Said enough? I see this as one more area where a "Movement" is in order to fight back against government regulations infiltrating every aspect of our lives. Have you ever just sat & thought how many articles that we purchase are regulated by government? Look around-It's everywhere!!!!!! Wake Up America!!!! I say let the consumers & markets decide if "Dry" units are desirable. Carrier has had a monopoly on our industry for too long. This is another attempt to control the government for their own monopolistic business model. Consideration on this ruling needs to be given to the plethora of independent businesses taking care of the needs of the American consumer.

poor people riped off

June 14, 2011
did everyone know that with micro channel coil designs and micro tube designed coils that units capacity levels of r22 can be as less than 50 percent as old coil designs on which i know york has that technology and so does Goodman if installed correctly same performance less power usage and safer for the environment than the older units and poor people save money like there is rich people everywhere to go to 410a which by the way is proven but the customer needs some cash or a loan on there mortgages to go that direction and by the way purge these coils with nitrogen after brazing and pull a long vacuum and you will have no problems


June 16, 2011
Big business has a voice while the farther down the food chain you go, the less voice you have. Big business and junk science is ruling peoples' lives. R22 is not the problem. Money is the reason for Carrier, Dupont, the government, etc. acting as they do. We, the little people must drink the kool-aid and be good worker ants. No wonder there is a Tea Party movement.

Carrier asks EPA to Stop Dry R-22

Mike Murphy
June 16, 2011
Just an fyi for our readers that may help clarify some things: The initial shipments of dry R-22 units in 2010 came from Rheem Manufacturing (Editor's Note: Error in fact. See the July 5 comment from Mike Murphy for correct information.) for some new construction accounts, shortly followed by two other manufacturers (neither of which was Carrier Corp.) The whole thing "snowballed" and soon thereafter all seven of the major players began to manufacture and ship the dry units. I won't argue all the points of global warming or ozone depletion with any of you - all are entitled to their opinions, and the scientists have shown that even the most educated minds can't agree on these topics. Anyway, good discussions! Thanks. Murph

Refrigerant Blues

Autumn Air Conditioning
June 16, 2011
With a flick of a pen the EPA could do the right thing. I didn't like the idea of phasing out R-22 at first but I've changed my mind. I like the idea of a green refrigerant for the ozone and for it's energy efficiency. The thing that really ticks me off is how we all look like a bunch of idiots or liars because we've been heavily pushing 410a units for the past 5 years or so. This undermines the trust we've worked very hard to build with our customers. Jason Owner at www.bonitaspringsairconditioningrepair.com

Is this the same ethical company that is ripping of its salesman in southern California?

June 17, 2011
A San Diego civil jury taught corporate America a lesson about greed, promises and guarantees today, awarding a total of over $9.5 million in the first of several cases involving so far nine former employees. San Diego air conditioning salesman Tim Horner was hired away from a 18+ year job to work for a competing company (Carrier Corporation). More here: http://www.nbcsandiego.com/on-air/as-seen-on/Employee_Wins__8M_in_Lawsuit_Against_Carrier_Corporation_San_Diego-124075924.html

Dry r 22 units

June 18, 2011
I'n Florida these units are illegal unless an engineer signs off on the combination with the old air handler. Only shady contractors buy them who do not pull permits and know hot to sell what the homeowner really needs!!!

Murph you are probably wrong about other things too.

June 29, 2011
Nordyne was the first manufacturer to build and ship dry R-22 units not Rheem. What do we plan to do with the millions of metric tons of R-22 in operational equipment today if not reclaim, recycle and reuse? This isn't about a loophole because the intent of the act was to utilize the R-22 that is already out there today. Carrier and others have put all their eggs in the Puron basket and simply need relief from R-22 demand.

Hawk's comment

Murphy Wrong
July 5, 2011
Hawk, You may be right, as others have called my attention to Nordyne. I was referencing information I received from somebody at Rheem (and may have misunderstood)with regard to who was first in line. Please consider this a correction, if that be the case. Thanks for the update. You bring up the point about recycle,etc. Do you know how much is actually being vented to the atmosphere? Nearly 95%. If, like you say, the intent was to use the existing R-22, then this is a dismal failure by the EPA, who must think that by wishing for everybody to reclaim, recycle, and reuse that it would happen. This means pressure does get put back on the R-22 supply. thanks.

Correction to "Carrier asks EPA to Stop Dry R-22"

Mike Murphy
July 5, 2011
In one of the above comments I said "The initial shipments of dry R-22 units in 2010 came from Rheem Manufacturing for some new construction accounts ..." That was in error. Rheem was not the first manufacturer to produce the units, and when they did, it was actually for apartment replacements rather than new construction as I had stated in the comment. On behalf of The NEWS, my apologies to our readers for the mistake. I will be checking my facts better in the future. Thanks to all who brought this to my attention. Murph

Doesn't matter

August 9, 2013
The dry units don't care which refrigerant is used. All compressor are Poe oil. You can take a dry unit and change the txv to 410 and there you go... There argument is stupid but that's carrier for you...

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February 7, 2014
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