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On Dec. 10, California became the first state in the nation to adopt regulations that will phase down the use of HFC refrigerants in commercial and industrial stationary refrigeration units, such as those used by large grocery stores, as well as commercial and residential air conditioning equipment. The leadership team from the California Air Resources Board (CARB), which approved the new rules, said they were necessary in order to meet the state’s mandate to reduce HFC emissions 40% below 2013 levels by 2030.

Under these new rules, starting in 2022, there is a 150 GWP limit for new or fully remodeled facilities that utilize commercial refrigeration equipment containing more than 50 pounds of refrigerant; there are varying requirements for existing facilities. The 750 GWP limit for many types of air conditioning equipment was pushed back to 2025, while VRF system manufacturers have until 2026 in order to comply with the new limit. Many equipment manufacturers attending the meeting expressed support for these new deadlines.

Air Conditioning Rules

Equipment manufacturers had been concerned about meeting CARB’s original deadline, which would have required a 750 GWP limit for most types of air conditioning equipment by Jan. 1, 2023. Due to these concerns, CARB adopted a proposed amendment that extends that date to Jan. 1, 2025.

Manufacturers said they needed this extension, because current codes and standards do not allow the use of lower flammability — or A2L — refrigerants in equipment. Right now, most alternative refrigerants that meet the 750 GWP limit are A2Ls. In addition, manufacturers said that the impacts from the COVID-19 pandemic could affect their ability to meet the 2023 mandate.

Kathryn Kynett, an air pollution specialist at CARB, who led the discussion regarding air conditioning equipment at the December meeting, noted that while A2L refrigerants are already used in room air conditioners and automobiles in California, the use of this type of refrigerant in all kinds of stationary air conditioning equipment would require further updates to the California building code. And those have not yet occurred.

“CARB relies on safety experts and entities with jurisdiction over the safe use of refrigerants, including the California State Fire Marshal, as well as nationally accredited standard setting organizations such as UL and ASHRAE, and others such as the US Environmental Protection Agency (EPA),” she said. “Each entity has its own timeline and cycle for incorporating updates, and the updates made to the California building code every few years generally follow updates to safety standards.”

In 2018 and 2019, ASHRAE and UL approved updated safety standards with provisions for the use of lower flammability refrigerants, and this year, the State Fire Marshal convened a working group to consider incorporating the latest UL and ASHRAE standards into the California building code for 2023. However, the Marshal had not finalized its decision by December 2020, which could delay potential building code updates from 2023 to the next code cycle. As a result, CARB proposed extending the implementation date from 2023 to 2025 for residential and commercial air conditioning equipment in order for building code updates to enable the use of alternative refrigerants.

RULE EXTENSION: Under CARB’s new rule, VRF system manufacturers will have until Jan. 1, 2026, in order to comply with the 750 GWP limit.

“We would like to keep the 2023 compliance date for room air conditioners and dehumidifiers, as building codes do not need to be updated for these categories,” said Kynett. “We are also proposing an extension to 2026 for VRF/VRV systems, which are highly energy efficient but require additional code changes. It is important for this equipment to transition to lower GWP refrigerants as soon as possible, and for this category, 2026 is the earliest date.”

In exchange for delaying the 750 GWP mandate, equipment manufacturers agreed to jump start CARB’s Refrigerant Recovery, Recycle and Reuse program – or R4 program. This refrigerant recycling program will put responsibility for compliance on manufacturers, and they will also be required to use some recycled refrigerant in their air conditioning equipment.

“Through this process, we've had many meetings with stakeholders…and we worked with them on policy options to increase the use of recycled refrigerant,” said Kynett. “We are asking manufacturers to commit to using 10% recycled refrigerant and offering an early action credit for low-GWP refrigerant use. We believe this will help kickstart the R4 program, which is necessary to achieve the remaining emissions reductions we need by 2030.”

CARB hopes the R4 program will be the catalyst to developing a robust recycling effort, which could serve as a national model. California is working towards 100 percent refrigerant recovery and recycling.

Refrigeration Rules

As noted earlier, the new CARB rules also affect commercial refrigeration systems that contain more than 50 pounds of refrigerant. Starting on Jan. 1, 2022, there is a 150 GWP limit for systems in newly constructed and fully remodeled facilities. In existing facilities, there are different GWP requirements, which vary by end use.

The 150 GWP limit essentially affects all non-residential systems and facilities that use systems above the size threshold, including retail food facilities like supermarkets and grocery stores and cold storage warehouses, said Richie Kaur, Ph.D., an air pollution specialist at CARB, who discussed the regulatory impacts for stationary refrigeration.

“Technological advancements have made it possible for new facilities to use refrigerants with very low GWP values today,” she said. “Low GWP alternatives to HFCs consist of natural refrigerants like carbon dioxide, ammonia, and hydrocarbons. Additionally, the next generation of synthetic refrigerants — HFOs — are under rapid development. The 150 GWP requirement would apply to newly constructed facilities and facilities that undergo remodels where most of the refrigeration equipment is being replaced.”

Originally, CARB had proposed that the 150 GWP limit apply to both new and existing facilities. However, stakeholders expressed concern about the costs involved with retrofitting existing facilities, as low GWP refrigerants such as CO₂ and ammonia are not compatible with equipment that utilizes HFC refrigerants. As a result, all the refrigeration infrastructure would need to be replaced in order to meet the mandate.

While the final rule differs from the original proposal, Kaur expects it will achieve similar emissions reductions. As such, CARB proposed company-wide reduction targets for existing supermarkets and grocery stores in California to cut their emissions by 2030. Large companies will have an interim compliance target — or progress step — in 2026.

Under the final rule for existing facilities, retail food companies with more than 20 facilities in California will be required to reduce their company-wide, weighted-average GWP for all refrigeration systems containing more than 50 pounds of refrigerant to less than 1,400 GWP by 2030 with a progress step in 2026. An optional compliance pathway for achieving similar emissions reductions is to reduce greenhouse gas emissions potential (GHGp) from their existing systems by 55 percent by 2030. Enforcement mechanisms will include registration, recordkeeping, and reporting requirements for existing retail food facilities.

“The first metric is really about reducing GWP of refrigerants used by each company, and the second metric gives credit for reducing the amount of refrigerant — for example, replacing an older system with one that uses less refrigerant,” said Kaur. “These are full company targets, which means companies have the flexibility not to retrofit every single system or store; they can leave some stores untouched. Companies also have the flexibility to plan their compliance over the next eight to 10 years.”

In recognition of the challenge faced by small businesses, Kaur noted that CARB has set a more relaxed pace for compliance by companies that own fewer than 20 stores and are not part of a national chain. She added that this would prepare this sector for a future HFC phasedown or a virgin refrigerant sales ban, since they would have already transitioned to lower GWP alternatives.

“CARB's intent ultimately is to eliminate the use of very high GWP refrigerants in every end use sector that uses these large refrigeration systems,” she said.

Going forward, CARB is considering a sales prohibition on new refrigerant above a threshold GWP, which would require using recycled refrigerant for servicing existing equipment, said Kynett.

“Using recycled refrigerant should decrease the amount of new refrigerant necessary and incentivize greater refrigerant recovery from existing equipment,” she said. “This is something that industry has proposed to us during our current rulemaking, but we think this is better suited to be its own separate rulemaking. You can keep an eye out for work to be done on that as early as 2021.”