Reminder  for Air Conditioning and Variable Refrigerant Flow
Equipment Manufactur ers: R4 Pr ogram Baseline Report
California Air Resources Board sent this bulletin at 06/19/2023 05:00 PM PDT
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June 19, 2023
Reminder for Air Conditioning and V ariable
Refrigerant Flow Equipment Manufacturers: R4
Program Baseline Report
Due by July 1st, 2023
The Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration,
Stationary Air Conditioning, and Other End-Uses Regulation (2020 HFC
Regulation)  requires Air Conditioning (AC) and V ariable Refrigerant Flow (VRF)
equipment manufacturers to submit an Initial Baseline Report to the California Air
Resources Board (CARB), pursuant to Cal. Code Regs., Title 17, § 95376(c), by
July 1, 2023 to meet the requirements of the Refrigerant, Recovery , Reclaim, and
Reuse (R4) program.
The R4 Program requires equipment manufacturers subject to the prohibitions
under the “Other AC” and “VRF” end-uses listed in Section 95374(c), Table 3  of the
regulation to use a specified minimum amount of certified reclaimed refrigerant in
new equipment or in the servicing of existing equipment. This amount is calculated
by determining a baseline using the number of pounds of refrigerant used in
equipment that entered into California in 2018 and 2019. (If no equipment entered
into California in 2018 or 2019, then projected values should be used instead.)
The Initial Baseline Report shall be submitted to CARB by July 1, 2023, and
include the following:
For AC Manufacturers with equipment that entered into California in
2018 and 2019:
The type and quantity (pounds) of refrigerant used with a (Global W arming
Potential (GWP) of 750 or greater for equipment manufactured in 2018 and
2019 for use in California; and the quantity (pounds) of certified reclaimed R-410A  refrigerant required, as calculated using the equations in sections
95376(a)(1) and 95376(a)(2) of the regulation.
For AC Manufacturers with no equipment that entered into California in
2018 and 2019:
The projected type and quantity (pounds) of refrigerant used with a GWP  of
750 or greater for equipment manufactured in 2023 and 2024 for use in
California; and the quantity (pounds) of certified reclaimed R-410A  refrigerant
required, as calculated using the equation in section 95376(a)(3) of the
regulation.
For VRF Manufacturers with equipment that entered into California in
2018 and 2019:
The type and quantity (pounds) of refrigerant used with a GWP  of 750 or
greater for equipment manufactured in 2018 and 2019 for use in California;
and the quantity (pounds) of certified reclaimed R-410A  refrigerant required,
as calculated using the equations in sections 95376(b)(1) and 95376(b)(2) of
the regulation.
For VRF Manufacturers with no equipment that entered into California in
2018 and 2019:
The projected type and quantity (pounds) of refrigerant used with a GWP  of
750 or greater for equipment manufactured in 2023, 2024, and 2025 for use
in California; and the quantity (pounds) of certified reclaimed R-410A
refrigerant required, as calculated using the equations in section 95376(b)(3).
To assist with compliance, CARB has developed a template form  that can be used
to submit the report.
As a reminder , Manufacturers of AC equipment that is subject to the January 1st,
2025 prohibitions in Section 95374(c), Table 3 of the regulation are subject to a 10
percent certified reclaimed refrigerant use requirement for both 2023 and 2024.
Manufacturers of VRF equipment that is subject to the January 1st, 2026
prohibitions in Section 95374(c), Table 3 of the regulation are subject to a 15
percent certified reclaimed refrigerant use requirement for 2023 and 2024, and a
25 percent certified reclaimed refrigerant requirement for 2025. An “Early Action
Credit” option can also be utilized by equipment manufacturers to partly or
completely fulfill requirements on the use of reclaimed refrigerant.
Manufacturers of AC and VRF equipment are also subject to annual reporting
requirements. Annual reports are due by July 1, 2024, and July 1, 2025 for AC
manufacturers; and July 1, 2024, July 1, 2025, and July 1, 2026 for VRF
manufacturers. All reports must be submitted via email to:
HFCReduction@arb.ca.govGeneral information about the R4 program  is available. The information on the
website does not alter or modify the terms of the HFC Regulation, nor does it
constitute legal advice. The full HFC regulation  text is available.
Background
HFCs are among the most harmful greenhouse gases (GHGs) emitted today . While
they remain in the atmosphere for a much shorter time than carbon dioxide, their
relative climate impact can be hundreds to thousands of times greater than carbon
dioxide.
The importance of HFC mitigation was identified in the early 2000s, and several
early action measures were proposed as part of a comprehensive ongoing program
to reduce GHG emissions in California. In 2016, recognizing the importance of
reducing HFCs, the State legislature enacted Senate Bill 1383, requiring a 40
percent reduction of HFC emissions below 2013 levels by 2030.
In 2020, CARB adopted the HFC regulation, which establishes GWP  limits for new
refrigeration and air conditioning equipment, to ensure that industry not only shifts
away from the highest GWP  refrigerants, but swiftly transitions to technologies with
the lowest GWP  that are technologically and commercially feasible.
The HFC Regulation also created the R4 Program, requiring AC and VRF
manufacturers to use a percentage of certified reclaimed refrigerant rather than
continuing to use newly produced refrigerant. The R4 program was created to
incentivize the recovery and reuse of HFC refrigerants from existing sources.
CARB expects benefits from creating a refrigerant recovery , reuse, and reclaim
program. A robust reclaim program can help enhance recovery of refrigerants from
equipment during its lifetime and at end of life and prevent those refrigerants from
leaking into the atmosphere.
Contact
For questions regarding the HFC Regulation and reporting requirements, please
contact the HFC team at HFCreduction@arb.ca.gov .
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CARB is the lead agency for California’ s fight against climate change,
and oversees all air pollution control ef forts in the state to attain and
maintain health-based air quality standards.
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