CARB’s New R4 Program Puts Spotlight on Refrigerant Reclaim
In July of 2020, the California Air Resources Board (CARB) proposed amendments to the California HFC regulation as part of an initiative for environmental sustainability: “Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration, Chillers, Aerosols-Propellants, and Foam End-Uses Regulation.”
These amendments set new emission reduction measures for companies’ environmental footprints including GWP limits for refrigeration and air-conditioning equipment as well as company-wide emissions reduction targets for retail food businesses.
After conducting stakeholder meetings and receiving feedback from the industry and corporate sustainability experts, CARB approved the proposed amendments in December of 2020; albeit, with a few modifications, which include:
- Delayed GWP limit compliance deadlines for certain A/C equipment; &
- A new refrigerant reclaim program.
Delaying the GWP limit deadlines for A/C opened the doors up for compromise between the state and air-conditioning manufacturers to meet emission reduction targets through other means, particularly with a new Refrigerant Recovery, Recycle, and Reuse (R4) Program.
This new program, expected to be developed in 2021, puts a spotlight on refrigerant reclaim and where your refrigerant goes.
Before diving into the details of the new R4 program, let’s first address the air-conditioning compliance deadlines that were pushed to a later date.
Delayed A/C Compliance Deadlines
CARB proposed a 750 GWP limit for the following air-conditioning systems at these specified dates:
- New room air conditioning equipment and dehumidifier: 2023.
- New chillers used for air-conditioning: 2024
- New residential and commercial stationary air-conditioning systems: 2025**
- VRF or VRV systems: 2026**
**Originally, CARB had proposed a 2023 750 GWP limit for most A/C equipment (except chillers).
However, due to significant feedback received and the wait on California fire and building codes to be updated for A2L refrigerants, CARB decided to pushback the 2023 compliance deadline to 2025, as seen above.
The major takeaway here is, change is coming for refrigeration equipment in California as early as 2022 and for air-conditioning equipment as early as 2023.
Having a complete and comprehensive inventory of your HVACR assets will be critical, as you and your team begin to plan for the transition. Even more so when you consider CARB’s new R4 program.
Introducing the New Refrigerant Recovery, Recycle, and Reuse (R4) Program
In 2021, we can expect a new R4 program regulation for refrigerant reclaim. This is a new amendment to the HFC regulation that was not addressed earlier last year.
In my opinion, there is only one way to encourage reclaim, and that’s to identify the source and end-of-life controls from a regulatory perspective. So the concept behind this program is a good first step.
Specifically, CARB is proposing to establish a requirement for a minimum use of reclaimed refrigerant in an amount equal to 10 percent of the amount of R-410A that enters California in new equipment in 2023 and 2024. (Such requirement would not apply to room air-conditioning and dehumidifiers.)
What complicates this is the fact that currently there is no reclaim material type. That is, reclaim is a process NOT a material type.
This material class will need to be defined for the program to be successful and have validity. (This is true at the state and federal level; with the AIM Act, there could be increased emphasis on reclaiming HFC refrigerants at the federal level.)
As you can see, the Refrigerant Geeks are closely monitoring the activity on the R4 program so our followers can incorporate them into their regulatory refrigerant tracking, ESG reporting, and answering sustainability audit questions. Undoubtedly, we are especially interested in how reclaim will be defined and classified in the near-term.
Once this new R4 program goes into place, facilities will need to ensure that a refrigerant tracking program is in place to verify the origin of materials and end-of-life destination.
Learn CARB Compliance from the Refrigerant Geeks
Ultimately, numerous regulatory changes are happening at the federal and state level.
While these changes are fast-moving, you can rest assured that our Refrigerant Geeks are closely monitoring the developments at multi-levels.
As always, thanks for joining us on the Trakref blog.
As always, thanks for joining us. Right here on the Trakref blog.
And if you’re looking to stay on top of the latest compliance initiatives in your own refrigerant tracking, get in touch with Trakref today. We’re a software corporation that has been in the regulatory compliance software and environmental compliance calendar software space for years. As an environmental software provider, we make sure our refrigerant capabilities will keep you in compliance with new regulations. Get in touch with one of our Refrigerant Geeks today.
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