Comment on EPA's proposed rule on Refrigerant Managment

The latest proposed rule from the EPA has many concerning requirements that will impact distributors, contractors, and HVACR manufacturers and suppliers. HARDI is very concerned about this proposed rule and encourages distributors to submit comments to oppose portions of the rule. This rule will: 

• Expand Leak Repair for systems between 15 and 50 pounds
  • HARDI supports this proposal
• Require Automatic Leak Detectors for very large charge sizes
  • HARDI supports this proposal
• Require the use of reclaimed refrigerant for factory charges in several R/AC/HP sectors in 2028
  • EPA's own Technology Transition Rule requires OEMs to move to new low-GWP refrigerants that are not currently on the market, there will not be enough reclaimed low-GWP refrigerant to meet even a fraction of factory charged demand
• Require the use reclaimed refrigerant for repair and servicing of several refrigeration subsectors
  • Many refrigeration sector refrigerants are patented and cannot be reclaimed until the patents expire making it impossible to supply the necessary refrigerants for this proposal, HARDI supports increasing the use of reclaimed refrigerant in sectors where reclaimed refrigerant is available
• Send all disposable cylinders to reclaimers to capture heel charges
  • This propsal will put a massive burden on the industry to move empty cylinders to reclaimer facilities, the cost of which will reduce the viabiltiy of reclaimed refrigerants
• Re-propose the QR code tracking requirements overturned in HARDI v. EPA
  • The courts have already struck down QR code tracking requirements as beyond the authority of the AIM Act, the EPA cannot re-propose the this requirement under a different subsection