US Refrigerants Outlook
December 2022

AIM ACTEPA SNAP
UL 60335-2-89
ASHRAE 15
Building Codes
PFAS0

F-GAS Phase Down Steps – Kigali Amendment% CO2 eqvemissions forrefrigerants
placed on themarket vs2015 baseline

139* Countries Ratified Kigali Agreement , EU is Leading In F-Gas Regulations
1 2022* As of October 31,

AIM Act

2

Timeline

Dec 27th, 2020

Sep 23rd, 2021

Oct 27th, 2021

August 2022

July 2023 (?)

2024 (?)

AIM Act
EPA has autority
to regulate HFC’s

EPA RuleAllowance
Allocation andTrading Program

UL publishes the newstandard
UL 60335-2-89

new Addendum lincorporated into
ASHRAE 15

SNAP list update

State building code
adoption of the highercharge limits.

3Refrigerants scenario: A3 - A2L charge increase & HFC phasedown
The new UL 60335-2-89 (2nd Ed) standard raises the charge limit in commercial plug-in
It will also include dispensing units

EPA would need to follow suit in its SNAP (Significant New
Alternatives Program) before the new limits could be
implemented in the U.S.
Timing: SNAP approval expected in July 2023

ASHRAE SSPC15 committee has approved
the proposal to incorporate the new UL
standard in ASHRAE 15

Addendum l was published August 2022

On September 23, 2021, EPA issued a final rule “Phasedown ofHydrofluorocarbons: Establishing the Allowance Allocation and Trading
Program under the American Innovation and Manufacturing (AIM) Act.”
The AIM Act directs EPA to phase down production and consumptionof HFCs to 15% of their baseline levels in a stepwise manner by 2036
through an allowance allocation and trading program.

State building code adoption of the higher charge limits inplug-in cases.
Question: should plug-in cases fall under the building code
jurisdiction?
Our understanding:● Yes, for both new and existing buildings you cannot place
the equipment with higher charge until Building Codes
are updated
The building model code should be updated in 2024 (to beconfirmed).
4

AIM Act

5US/Canada Product Safety Standards Status- UL 60335-2-89 and CSA C22.2 60335-2-89 update was prepared by CANENA
Working Group 12- 2nd Edition of both standards will replace:
UL 1995 / CAN/CSA-C22.2 No. 236 Heating and Cooling Equipment
CSA C22.2 No.120 Refrigeration Equipment
UL 471 Commercial Refrigeration and Freezers
UL 427 Refrigerating UnitsUL 412 Refrigeration Unit Coolers- New UL -89 Standard edition was published on Oct,27 2021
- Addendum l of Ashrae 15 was published in Aug,31 2022
- New UL standard, to enter in force, it has to be declared accetable by EPA(SNAP) and Building Codes.

NEW UL 60335-2-89 CHARGE LIMIT FOR FLAMMABLES• Max refrigerant charge for each circuit 13*LFL
for open cabinets and 8*LFL for cabinets withdoors or drawers

Refrigerant

LFL [kg/m3]

13*LFL

8*LFL

R290 (A3)

0.038

0.494 kg

0.304 kg

R454C (A2L)

0.293

3.809 kg

2.344 kg>>> Additional requirements must be fulfilled.
>>> Surrounding concentration test of Annex CC mandatory.

• Requirements for systems below 150g are not changing• Commercial Ice Makers are now part of the standard scope• Remote Systems with more than 150g of flammables are allowed only with A2L refrigerants

Charge Limits For Class A2L and A3 (UL ed.2 vs IEC ed.3)

LTRegulatory Landscape: Refrigerants Charge Increase
Current limit

Proposed limit forcases with doors[300g]Proposed limit forcases with no doors[500g]

Proposed limits may enable us to cover most of the potential self-contained applications with fractional Hp9EQUIPMENTS COVERED BY UL 60335-2-89

BOTTLE
COOLERS

BLAST
FREEZERSICE-CREAM
FREEZERSGONDOLACABINETS

RECH-INCABINETSICE
MAKERS

PREPARATIONCOUNTERSSERVE-OVER
CABINETSMULTI-DECKCABINETSGELATOCOUNTERSICE-CREAM
MARKERSLAB EQUIPMENTNEWDISPLAY CABINETSUL 621

UL 61010-2-011

WATER
DISPENSERUL 399VENDING
MACHINESUL 541

WALK-IN COLDROOMSFLAMMABLES LIMITS IN UL STANDARDSASHRAE 15 - Addendum l
ASHRAE 15 Addendum l● Addendum l is incorporating requirements for commercial refrigeration
applications using A3 refrigerants.

The US Code Adoption Process

New or Revised
Product Safety
Standard
Updated Model
Code (triennal)
UpdatedApplication
Safety Standard

States To Adopt
Model CodeUS Standard/Code Status For Flammables (A2L, A2, A3)
SNAP Rules
20 and 21(2015, 2016)

Rules
Vacated(2017)

ProductSafety
Standards

UL 471 etc(2019)

Application
SafetyStandards

SNAPRule 23(2021)

AIM Act(2020)

add. dadd. hAshrae
15(2019)

UL/CSA
60335-2-89
ed.2 (2021)
addendumc,d,e,g,l,m,p,q,s

Model
Building
Codes

Ashrae15(2022)2021
ModelCodeState
BuildingCodes

2024
Model
Code

State and Local Codes

2016

2017

2018

2019

2020

2021

2022

2023

State andLocal Codes

2024

Mechanical and Residential Code Adoption

State Code Adoption Will Cover Both AC and Commercial Systems

US Climate Alliance Actions

EU REACH DIRECTIVE UPDATEPROPOSED PFAS BAN

17News About EU REACH Directive
In 2020, Germany, the Netherlands, Norway, Sweden and Denmark agreed to preparea joint REACH (Registration, Evaluation, Authorization and Restriction of Chemicals)
proposal restricting the use of PFAS. PFAS—Per- and Polyfluoroalkylsubstances—are a complex group of more than 5000 chemicals that have been linked
to environmental contamination and negative health effects in humans.

Aim to restrict all PFAS in non-essential uses

Process schedule:

2021
Stakeholder
inquiry

2022
2023
Submission ofrestrictions
dossier

2023

2024

2025

Final
recommendations

Final draft

Entry in force
Ban dates TBD

18

PFAS Definition*
F

Examples:

HCPFAS = Per-and polyfluoroalkyl substances
All substances with at least one fully fluorinated –CF2or –CF3 group (without any H/Br/Cl/I-atom bound to it)C

H*In US the EPA definition is much narrower and excludes
refrigerants and trifluoroacetic acid (TFA)

F

H

F

C

C

C
R1234yf

F

H

C

H

F

F

R134a

5,000 – 10,000 different PFAS

F

F

F

H

F
R32Not PFAS

Most Of HFC Refrigerants (A1, A2L) Can Be Affected By PFAS Ban19