On October 11, 2024, the United States Environmental Protection Agency (U.S. EPA) finalized Title 40 of the Code of Regulations Part 84 (40 CFR 84) Subpart C Management of Regulated Substances requirements (more commonly known as
the HFC Management Rule). This rule will require covered appliances to meet certain servicing, repair, disposal and installation requirements in order to minimize the release of HFCs and substitutes with a global warming potential (GWP) greater
than 53. Entities that may be affected by this final rule include those that own, operate, service, repair, recycle, dispose, or install equipment containing HFCs or their substitutes with a GWP > 53, as well as those that recover, recycle,
or reclaim HFCs.
These requirements are in addition to the existing refrigeration requirements that have been in effect for many years now under 40 CFR 82 for Class I/II ozone depleting substances (ODS) and non-exempt substitutes. Going forward, facilities will need to
comply with the refrigeration requirements under BOTH programs. Unfortunately, each program has their own set of requirements with some overlap, but different thresholds apply for determining whether an appliance is covered under the leak repair requirements.
As such, understanding the regulations, reviewing your current refrigeration management program, and updating your current refrigeration management program in 2025 are all essential steps in order to demonstrate compliance with the new requirements
starting in 2026.
What Are HFCs?
HFCs are potent greenhouse gases (GHGs) developed and manufactured as replacements for ODS (e.g., R-11, R-22, R-123) in refrigeration, air conditioning, aerosols, fire suppression, and foam blowing sectors. Examples of HFCs include R-125, R-134a, and R-23 and blends of HFCs, including R-404A, R-410A, and R-407C.
HFC use has been growing worldwide due to the phaseout of ODS and the increasing use of refrigeration and air conditioning equipment globally. These fluorinated chemicals have no known natural sources and have GWPs (a measure of the relative climatic
impact of a GHG) that can be hundreds to thousands of times greater than carbon dioxide (CO2).
Summary of Key Requirements Under the HFC Management Rule
The American Innovation and Manufacturing (AIM) Act authorized the U.S. EPA to address HFCs in three main ways:
- Phasing down their production and consumption
- Promulgating certain regulations for the purposes of maximizing reclamation and minimizing releases of HFCs from equipment and ensuring the safety of technicians and consumers
- Facilitating the transition to next-generation technologies through sector-based restrictions
U.S. EPA already published the final Phase-Down Rule and the final Technology Transitions Rule under the AIM Act that are currently in effect. Publishing the final HFC Management Rule on October 11, 2024 in the Federal Register established the following additional requirements under the
AIM Act:
- Leak repair requirements for appliances with a full charge > 15 lbs containing HFCs or substitutes with a GWP > 53
- Disposable cylinder requirements
- Automatic leak detection system requirements for commercial and industrial systems with a full charge > 1,500 lbs containing HFCs or substitutes with GWP > 53
- Reclamation standards
- Fire suppression system standards
HFC Management Rule Compliance Deadlines
The following figure depicts the key compliance dates associated with the final HFC Management Rule.
Who Is Affected by the HFC Management Rule
Since the full charge threshold in the HFC Management Rule is much lower than the existing leak repair provisions for ODS under 40 CFR 82 (15 lbs vs. 50 lbs), the HFC Management Rule will impact entities that were previously unaffected by the ODS provisions. Following the phase-out of ODS, many larger systems were built with individual circuits containing full charges with less than 50 lbs (but usually still >15 lbs). With this rule, these systems will now be subject to the leak repair provisions when they were previously excluded. In addition, HFC refrigerants developed to replace ODS were installed throughout the U.S. from the 1990s through the 2020s and therefore a significant number of existing refrigerant systems use HFCs. As such, many locations that are not considered “industrial” operations could be pulled into the new rule due to the low threshold and covered refrigerants, including entities like warehouses, airports, apartments/residential facilities (unless the use is considered light commercial or residential), strip mall stores, office buildings, data centers, and universities.
Could the HFC Management Rule be Revised/Reversed?
Because the final HFC Management Rule was finalized in October 2024, it is subject to the Congressional Review Act (CRA) under the Trump Administration. Although the new administration has not listed it as a high priority target, the rule may still be overturned, affecting upcoming compliance deadlines. Trinity is monitoring this situation closely and will publish an updated article if the rule is stayed or reversed.
How Do I Prepare for the HFC Management Rule?
In the meantime, Trinity provides refrigerant training across the country, in both classroom and webinar formats, that can help you understand the refrigeration regulations and requirements under both rules (40 CFR 82 and 40 CFR 84). The following are upcoming refrigerant training courses offered by Trinity in the next few months (see a full list of our training offerings here):
- March 13, 2025 – Webinar
- April 17, 2025 – Oklahoma City, Oklahoma
- June 10, 2025 – Webinar
- August 7, 2025 – California Online
Trinity also provides site-specific services including custom training courses and auditing (see Trinity’s offerings here).
Trinity can customize the training content to be tailored to the specific requirements applicable to your facility and to key program elements required to demonstrate compliance with the requirements. Auditing your refrigeration management program allows Trinity to identify gaps in your current refrigeration management practices and to provide recommendations on how to fill those gaps in order to demonstrate compliance with new HFC Management Rule requirements. If you are interested in a custom course or an audit, please reach out to your local Trinity office.
Should you require additional support with understanding the refrigeration requirements and available compliance management tools, please contact Jennifer Markwardt at 636.256.5652 or Divya Harrison at 240.834.6954
