We are just over two years into the Environmental Protection Agency’s program mandating a reduction in the production and use of hydrofluorocarbon refrigerants for residential and light commercial HVAC systems. The changes in this program, moving from stage 1 to stage 2, along with other recent regulations enacted by the EPA under the authority of the American Innovation and Manufacturing Act of 2020, will make the next few years critical for a smooth transition to the new A2L refrigerants.
EPA Regulations
On Jan. 1, 2022, the EPA mandate phasing down the production and use of HFC refrigerants went into effect with a 10% reduction in the production and use of HFC refrigerants from previous baseline levels. On Jan. 1, 2024, EPA increased the reduction level to 40%. The HFC phasedown will continue at this 40% reduction level over the next five years, at which time the industry will see another 30% reduction in the production and use of HFCs.
The EPA issued another final rule on Oct. 5, 2023, imposing additional regulations in support of the HFC
phasedown. This rule supports the phasedown by creating a Technology Transition Program, forcing a
transition to next-generation equipment for select market segments. In particular, the rule imposes new
regulations restricting the use of higher global warming potential HFCs in new HVAC systems for the
residential and light commercial markets.
These new regulations:
• Prohibit the manufacture and import of HVAC systems with GWPs >700 on or after Jan. 1, 2025; and
• Prohibit the installation of new HVAC systems with GWPs >700 on or after Jan. 1, 2026.
Some of the industry changes required to facilitate the phasedown of HFC refrigerants include changes
to industry codes, such as the International Code Council’s International Building Code, International
Residential Code, International Mechanical Code and International Fire Code. These codes, along with
several industry standards including UL/CSA 60335-2-40 (household heat pumps and air conditioners),
UL/CSA 60335-2-89 (commercial refrigerating appliances), ASHRAE 15 (safety standard for refrigeration
systems) and ASHRAE 34 (designation and safety classification of refrigerants), had to be updated to
cover the use of A2L refrigerants within the built environment. In jurisdictions across the U.S., these
changes have required local code amendments, or legislative actions, to support the safe transition to
the A2L refrigerants.
Codes and standards update
The ASHRAE 15 and 34 standards and UL 60335-2-40 and 60335-2-89 standards, like earlier editions of
the International Codes (I-Codes), didn’t have suitable coverage for A2L refrigerants. They did not allow
A2L refrigerants to be used for human comfort – residential and light commercial HVAC systems.
However, the 2024 I-Codes, and the latest versions of the ASHRAE and UL standards, now address A2Ls
and allow for their use in these applications.
The dilemma the industry faces is that the 2024 I-Codes (that reference the applicable ASHRAE and UL
standards) have not yet been adopted in any jurisdictions. To have a smooth transition to A2Ls,
currently adopted codes must be changed, amended, take on the 2024 A2L I-Code language, or be
replaced with the 2024 I-Codes. Over the past few years, state and local jurisdictions have been
addressing these concerns, as the industry has been preparing for the next stages of the HFC phasedown
and the transition to new low GWP HVAC systems.
Legislation and code adoptions
To facilitate the transition from HFCs to A2Ls, AHRI, trade associations and other HVAC industry groups,
have taken on a grassroots effort to enact legislation in each state that will allow the use of all SNAP
refrigerants, which are primarily A2Ls, according to their conditions of use.
For updated and more detailed state specific adoption and legislative actions pertaining to A2L
refrigerants, view the AHRI Refrigerant Building Code Map online at https://www.ahrinet.org/a2l-refrigerant-building-code-map.
Considerations for contractors and technicians
Comfort conditioning in the residential and light commercial markets is a key area affected by EPA’s HFC
Phasedown Program and its Technology Transition Program. Changes have been made to the most
recent industry codes and standards, facilitating the safe installation and use of HVAC systems utilizing
A2L refrigerants. Contractors and technicians should become familiar with the 2024 IBC, IRC, IFC and
IMC, along with the latest versions of the previously mentioned ASHRAE and UL standards to
understand the steps needed to ensure full compliance with all applicable A2L refrigerant requirements.
Over the coming months, and years, state and local governments will be going through the process of
reviewing and adopting these latest codes and standards. As the new codes and standards make their
way through local legislative and/or code adoption processes, contractors can get involved in and/or
monitor the processes to understand any local changes or amendments that take place in their service
areas. As A2Ls become more widely adopted and used in applications, such as comfort cooling, it is
important for contractors and technicians working with HVAC systems to understand all the new code
and standard requirements.
Since A2L refrigerants have flammable characteristics, there are necessary steps required to ensure safe
use and handling. Contractors and technicians need to make sure they have the proper tools and
equipment for use with A2L refrigerants. Another change to be aware of includes the amount of
refrigerant that can be used for human comfort purposes, which may affect installation plans.
Preparation for this should include training on proper labeling, usage and storage practices, which
should be considered to minimize potential risk and safety concerns with these flammable refrigerants.
To assist industry professionals in efforts to safely transition to A2L refrigerants, the Code Council has
developed the A2L refrigerant “Hot Topics” page at https://www.iccsafe.org/pmg/a2l-refrigerants-
transition/. Titled “Preparing for A2L Refrigerants,” the page offers a collection of videos from the Code
Council and industry partners. These videos cover various aspects of the transition to A2L refrigerants
that are important for contractors, technicians and other industry professionals. Additionally, the page
includes links to other valuable resources related to A2L refrigerants.
Jim Cika is director of plumbing, mechanical and fuel gas technical resources at the International Code
Council.
