The HVACR industry understands the importance of regulations in driving technology innovation and improvements in safety and environmental sustainability. Specific to refrigerants, while regulations that have driven the eventual elimination or “phaseout” of ozone depleting substances (CFCs and HCFCs) have been in place for several decades and are familiar to most in the industry, newer regulations implemented or taking shape in recent years to address climate change with an HFC “phase-down” are frequently misunderstood or sometimes intentionally misrepresented.
Since HFC phasedown regulations are already in place in some parts of the world — such as the European Union, Japan, Canada, and the United States — and they are starting to take shape in other developing countries, it is important to take a closer look at the distinctions that our industry needs to understand.
What an HFC phasedown is NOT
An HFC “phasedown” is not the same as the “phaseout” that our industry experienced for CFCs and HCFCs as countries implemented regulations to comply with one of the world’s most successful international treaties — the Montreal Protocol, signed in 1987. In the case of a phaseout, there is a mandated complete elimination of the production and import of any single CFC or HCFC substance.
The phasedown of HFCs will not be managed in this way, based on regulations currently in place and proposed. Contrary to misinformation circulating in the industry and among other interested stakeholders, there are no HFC production bans mandated in an HFC phasedown.
So, then what exactly IS an HFC phasedown?
The Kigali Amendment to the Montreal Protocol, agreed to in October 2016 by more than 170 countries around the world and currently ratified by over 100 countries, aims to reduce the total carbon emissions from the entire class of HFC compounds down to approximately 15% of each country’s baseline.
This phasedown approach enables each country or regulating entity to determine the best method to achieve these emission reductions across all applications that use HFCs. Application-specific targets can be set based on the needs of that market sector, as there is no prescribed requirement in the Kigali Amendment on how to get to 15% of the baseline.
Countries that have implemented or proposed HFC regulations to date are not setting them based on the volume of product placed on the market. Instead, they are based on the GWP-weighted size of the market. This GWP-weighting of volume is often described as “Carbon Equivalent Tons” or “CO2eqT”. In an HFC phasedown, countries can reduce their CO2eqT use in a variety of ways to achieve the target step-downs, including: setting quotas that can be reduced overtime to limit the amount of CO2eqT that enters the market each year; establishing GWP limits on certain end use applications; and applying service bans or restrictions to encourage transition to lower GWP solutions in existing installed equipment when and where lower GWP solutions exist with comparable performance, pressure rating, and safety classification.
But why aren’t HFC phasedowns applied uniformly across all sectors and applications?
In all countries where HFC phasedown regulations are in place, there is a keen recognition that different substances are needed to meet the specific application, and that the limits that can be achieved in new equipment and new buildings might be different than what can be achieved in existing infrastructure or existing systems. In some sectors outside of the stationary HVACR industry, such as foam blowing agents and automotive, solutions are being implemented today that eliminate a significant amount of carbon emissions by transitioning to alternatives with negligible global warming potential (GWP). These transitions make a significant contribution towards a country’s HFC phase-down goals, enabling other segments using HFCs — like commercial refrigeration or air conditioning — greater flexibility in fluid choice given the demands and complexity of equipment and need to balance factors such as cost, performance, energy efficiency, and safety.
The bottom line is that HFC phasedown regulations are not the same as the previous CFC and HCFC phaseout. The industry has choices for new and existing infrastructure and across applications. Any suggestion that a product will be eliminated, regardless of GWP, just because it has an HFC component in it, or the suggestion that all applications and industries can or should achieve the same GWP target is simply a scare tactic not based in regulatory realities of an HFC phasedown. It’s critical to stay informed of regulations to avoid being influenced by those who use misinformation and fear to limit technology options.