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Understanding that the United States needed to move to a next-generation refrigerant, bipartisan legislation was signed into law in late 2020: the American Innovation and Manufacturing (AIM) Act. The legislation grants the U.S. Environmental Protection Agency (EPA) the authority to regulate the transition, mirroring the Kigali Amendment phasedown. The Senate’s analysis estimated the AIM Act would create $38.8 billion in economic benefits annually by 2027. 1


EPA SNAP Program

The EPA’s Significant New Alternative Policy (SNAP) Program identifies approved and disallowed refrigerants for various applications. Manufacturers, refrigerant producers, and users can submit a proposed substitute for consideration, and the Program evaluates overall risks to the environment and human health.

SNAP Rules 20 and 21 limited the use of high-GWP HFCs and HFC-containing blends in various applications. The EPA’s authority was challenged, and the DC Circuit Court of Appeals held that the Clean Air Act only authorized the EPA to regulate replacements for ozone-depleting substances (ODSs) and could not regulate the general use of HFCs that were not substitutes for ODSs.

Part of the AIM Act addresses the court’s ruling, codifying the EPA’s authority to help regulate the transition to low-GWP refrigerants.

SNAP Rule 19, which went into effect in 2015, listed R-32 as acceptable with use conditions for self-contained room air conditioning.2 In October, the US EPA issued Allowance Allocations for 2022 and 2023 to phase down high-GWP refrigerants. The US EPA also granted or partially granted 11 petitions from stakeholders requesting EPA to (1) re-establish SNAP Rules 20 and 21, and (2) establish sector-specific GWP limits for residential and light commercial air conditioning and commercial air conditioning equipment, consistent with the CARB HFC proposal. EPA will initiate rulemakings to address the petitions and issue final rules by October 2023.


Updated excerpt from: Legislation Driving the Next Generation of Refrigerants

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