Navigating ODHSAR: Key Requirements for Refrigerants and Halocarbon Management in Canada

Background

Environment and Climate Change Canada (ECCC) administers the Ozone-depleting Substances and Halocarbon Alternatives Regulations (ODSHAR) under the Canadian Environmental Protection Act, 1999 (CEPA). These regulations implement Canada’s commitments under the Montreal Protocol, restricting the manufacture, import, export, and use of ozone-depleting substances (ODS) and specific high-global warming potential (GWP) alternatives.

As the global phaseout of ozone-depleting substances (ODS) continues to accelerate, compliance with ODSHAR requirements is increasingly important for facilities managing refrigerants, fire suppression systems, aerosols, vehicle air-conditioning systems, foams, laboratory chemicals, and other regulated applications.

ODSHAR identifies all controlled substances under Schedule 1, grouped into four major categories:

1. ODS (e.g., CFCs, halons),
2. Methyl bromide,
3. HCFCs, and
4. HFCs (bulk).

Each category carries distinct restrictions and authorization requirements.

Authorization Categories Under ODSHAR

Facilities handling controlled substances may require one or both of the following:

1. Permits

A permit is required for any person or facility intending to:

• Import controlled substances (new, used, recycled, recovered, or reclaimed) when not covered by consumption allowances.
• Export any controlled substance.
• Use methyl bromide for approved emergency or critical uses.
• Export products containing specific ODS, including CFCs, halons, carbon tetrachloride, or methyl chloroform.
• Manufacture or import products containing—or designed to contain—controlled substances for an approved essential purpose.

2. Consumption Allowances

A consumption allowance is a written authorization from ECCC that permits the import or manufacture of specific quantities of HCFCs or HFCs. Allowances are typically allocated annually and are essential for any facility handling bulk quantities of these substances for intended use rather than destruction or reclamation.

Facilities holding either authorization type must file an annual report by January 31 of the following year. ECCC maintains a public list of facilities that currently hold allowances.

Regulatory Requirements by Substance Category

1. CFCs, Halons, HBFCs, Carbon Tetrachloride & Similar ODS

These legacy ODS are mostly prohibited, with narrow exceptions.

• Export: Permit required for destruction, mistaken imports, approved uses, reclamation, or exporting reclaimed substances. No permit needed for foreign ship servicing or certain military fire‑suppression systems.
• Import: Permit required for destruction, essential uses, or reclaimed ODS. Limited exceptions include pre‑1999 vehicles, personal effects, and certain lab CFCs. All other imports are banned.

2. Methyl Bromide

Generally banned from import/export.

• Permit only for destruction, mistaken shipments, or approved emergency/critical uses.
• Primarily limited to QPS and shrinking critical applications.

3. HCFCs

In the final phaseout but not fully prohibited.

• Export: Permit required for destruction, mistaken imports, approved uses, or reclaimed HCFCs.
• Import: Requires permit + consumption allowance; permitted only for destruction, essential uses, or reclaimed HCFCs.
• Key deadlines: Most products banned Jan 1, 2020; HCFC‑123 allowed until Jan 1, 2030.
• Some exceptions for personal effects and certain medical uses.

4. HFCs

Controlled due to high global warming potential.

• Export: Permit required for all bulk HFC exports.
• Import: New bulk HFCs require an allowance; reclaimed HFCs require a permit.
• Product restrictions apply to aerosols, refrigeration/AC, vehicles, and foams based on GWP and implementation dates.
• Exceptions include medical, lab, military, aerospace, and personal‑use items.

5. Essential Purpose Permits

ECCC may authorize imports of certain ODS/HFC‑containing products for up to 36 months when needed for critical applications. (Does not apply to exports.)

Annual Reporting

Facilities holding a permit or consumption allowance must file an annual report by January 31 summarizing all controlled‑substance activities.

What This Means for Regulated Facilities

Facilities handling refrigerants or halocarbon-containing equipment should:

• Review their refrigerant inventories and identify any controlled substances listed in Schedule 1.
• Assess whether current operations require a permit, consumption allowance, or both.
• Evaluate supply-chain impacts, particularly for high-GWP HFCs.
• Plan for product-phaseout timelines,especially if relying on HCFC-123 or high-GWP HFC equipment.
• Prepare annual reporting systems to avoid noncompliance.
• Engage vendors early to ensure imported products meet current ODSHAR restrictions.

Given the increasing regulatory scrutiny of high-GWP refrigerants and the ongoing transition to low-GWP alternatives (e.g., HFOs), facilities may also benefit from evaluating long-term equipment transition strategies.

If you would like to discuss how the ODSHAR requirements may impact your facility, or need support preparing annual reports, please email Varshini Padmanabhan in Trinity’s Toronto office or call 208.472.8837.

For more information or for general assistance, please contact Trinity Consultants at 800.229.6655.