In December 2024, the New York State Department of Environmental Conservation (NYSDEC) adopted an amendment to Hydrofluorocarbon (HFC) Standards and Reporting rule under Part 494 of the Codes, Rules and Regulations of the State of New York (6 CRR-NY). The amendment introduced strict prohibitions, usage restrictions, and reporting requirements for HFC refrigerants. While some prohibitions and inspection requirements took effect with the release of the rule, June 1, 2025 is major compliance deadline for systems with charge capacity of 1,500 pounds or greater (“large” equipment).
To meet the registration and labeling requirements in 6 CRR-NY 494-2.2, owners or operators of large equipment subject to the rule installed prior to June 1 of 2025 must register the equipment through the NYSDEC
nForm portal. This registration requires standard facility information as well as equipment information such as identification number, model and manufacturer, charged substance, and a copy of the equipment label. The required label must be clearly visible and specify the refrigerant currently contained in the equipment, date the equipment was manufactured or charged, and refrigerant capacity.
Since the adoption of the rule, all large equipment has required monthly leak inspection following the protocol prescribed in §494-2.3. For large equipment used in “refrigeration” as defined in the rule, as opposed to “air conditioning”, installation of automatic leak detection systems (ALDS) is also required prior to the June 1 2025 deadline. New equipment installed after June 1 2025 requires ALDS installation within 30 days of equipment installation. Due to the limits of current technology and supply chains, NYSDEC published an
enforcement discretion letter on April 23, 2025 which states that the deadline may be extended to December 31, 2027 if ALDS is not technically feasible for the entirety of the system. In such cases, monthly inspections should continue until ALDS technology becomes feasible. Following the detection of a leak by ALDS or inspection, owners or operators should follow the leak repair protocol stated in Subpart 494-2.4.
For more information on the amended
Part 494, Trinity is offering a
complimentary webinar presented by experts in New York and Federal refrigerant regulations. Trinity has also published analysis of the amendment
proposal and
adoption, and NYSDEC has released a
recorded presentation containing more information on the new refrigerant management and nForm reporting.
The amendments to Part 494 are part of the regulatory changes resulting from the passing of the Climate Leadership and Community Protection Act (CLCPA). Trinity has previously written about the pre-proposal outline of the
New York Cap-and-Invest (NYCI) program and the recently proposed
New York State Greenhouse Gas Reporting Program. Trinity’s Albany office continues to track new developments from the CLCPA and is offering
complimentary luncheons across New York to assist clients in navigating the applicability and impacts of these regulations on their facilities.
