Date: May 6, 2015

By: Joe Sanders

SNAP — Rule 20

Proposal to prohibit certain

high-GWP HFC alternatives

Implications for small and 

large CRE manufacturers

Topics

 Terms and Definitions

 Summary - Rule 20

 Refrigerant Options

 System Component Availability

 Agency Certification

 Energy Implications

 Recommendations

 Contact Information
Implications

SNAP Rule 20 Page 2

Terms and Definitions

Stand-Alone or Self-Contained Refrigeration Systems (1)(2)

Integrate all refrigerating components within their structures 

Low charge sizes 0.150 - 0.750 kg (5 - 30 oz) 

Most often containing HFC-134a, or R-404A 

Remote Refrigeration Systems

Condensing Unit Systems (1)(3)

Consist of one or two compressors, one condenser, and one receiver assembled into the 

condensing unit system; linked to one or more 

display case(s) in the sales area through a piping network.

Most often containing R-134a, or R-404A 

Refrigerant charges from 0.5 - 20 kg (1 - 40 lb)

Multiplex Rack Systems 

Remote refrigeration systems consisting of racks of multiple compressors contained 

typically in a machinery room; linked to multiple display cases in the sales area through 

extensive piping. Condensers are usually remotely located, such as on the roof above 

the machinery room.

End Use Applications

New Equipment 

Commercial refrigeration equipment (CRE) designed and assembled by an original 

equipment manufacturer (OEM) and offered for sale as “new”. The end product generally conforms to applicable safety (UL471), sanitation (NSF-7) and energy conservation 10 

CFR Part 431, Subpart C standards.

Retrofit 

Used and currently in-service commercial refrigeration equipment where 

the original refrigerant as designed has been replaced by an EPA SNAP 

approved acceptable alternative. The retrofit may be initiated based on 

economical or service (down or inoperable equipment) needs.

Note: 

(1) Scope of analysis is limited to Stand-Alone and “simple” Remote Condensing Unit Systems only.

(2) DOE Equipment Class, “condensing unit configuration” - (SC).

(3) DOE Equipment Class, “condensing unit configuration” - (RC).

Stand-Alone Equipment

R-134a
Page 3

Proposal to prohibit certain 

high-GWP HFC alternatives

Summary — Rule 20

This action proposes to change the status of a number of substitutes that were previously 

listed as acceptable, based on information showing that other substitutes are available 

for the same uses that pose lower risk overall to human health and/or the environment. 

Specifically, this action proposes to modify the listings for certain hydrofluorocarbons 

refrigerants (R-134a and R-404A) in various end-uses including refrigeration. The current 

proposal has the following implementation schedule:

 R-404A New & Retrofit Equipment Stand-Alone & Remote 1/1/2016

 R-134a New Equipment Only Stand-Alone Only 1/1/2016

Refrigerant Options — Current

ASHRAE 34-2014 A1 A1 A2L A3

Refrigerant

Designation

NonFlammable

Non-Toxic

NonFlammable

Non-Toxic

MildlyFlammable

Non-Toxic

HighlyFlammable

Non-Toxic

Refrigerator

Designation: HFC, R-134a HFO, R-450A HFO, R-1234yf HC, R-600a HC, R-290

GWP: 1430 approx. 604 4 3 3

SNAP Status: Final Rule

4/18/1994

Notice 29

10/21/2014 In Process ? Rule 19

4/10/2015

Rule 17

12/20/2011

Freezer

Designation: HFC, R-404A HFO, R-448A HFO, HDR110 HC, R-290

GWP: 3922 approx. 1300 <150 3

SNAP Status: Final Rule

4/18/1994 In Process ? ASHRAE #?SNAP?

Rule 17

12/20/2011

Design Restrictions

Charge Limit: None None 500 grams

(17.64 oz) 150 grams (5.29 oz)

Enhanced

Component Safety

Requirements:

None None

Switches

Compressor

Heaters

Controls

Switches

Compressor

Heaters

Controls

Extra Safety Testing: None None UL471-SB UL471-SB

Service Technicians

Training:

No Special

Training

No Special

Training

Requires

Special Training

Requires

Special Training
Implications

SNAP Rule 20 Page 4

System Component Availability

Basic Stand-Alone System

Compressor:

 Three primary US manufacturers / private labels.

 Limited R-290 model selection above 1/2 HP.

 No compressor availability 

for “HFO” blends.

 No documentation available for R&D of systems 

using a HFO refrigerant.

Evaporator:

 Evaporator coils require redesign for each CRE model 

using a HFO blend refrigerant in order to maintain optimum energy efficiency. Reconfiguration is complex.

Expansion Valves and Capillary Tubes, etc...:

 Expansion valves and capillary tubes require resizing for 

all alternative refrigerants to maintain energy efficiency, 

Sizing and configuration are complex.

 Valve and other related part manufacturers lack documentation for sizing components for use with HFO blends. 

 Limited R-290 selections, no HFO availability, 

 Currently limited or no application help available. 

Condenser:

 Condenser coils may require redesign for each CRE 

model using R-290 as refrigerant to deal with a limited 

maximum refrigerant charge of 150 grams (5.29 oz).

Remote Refrigeration Systems

Condensing Unit Systems

 Design and component availability are typical of the stand-alone system from above.

Note: 

Vendors to commercial refrigeration equipment OEMs appear to be ill-prepared for 

any transition from current HFC refrigerants to approved alternatives. (i.e. HFO 

blends, R-450A & R-448A) Most have indicated that they will lack commercially 

available product into much of the 2016 year and will also lack significant R&D support for most of 2015. Vendors appear willing to only service their larger customers.

Evaporator Condenser

Compressor

TXV or Cap. Tube

Drier
Page 5

Proposal to prohibit certain 

high-GWP HFC alternatives

Agency Certification

All new or revised (major design change) cabinet 

models must be evaluated for conformance to the 

applicable safety, performance, sanitations and 

energy conservation standards for the authority 

having jurisdiction. All Basic Models must be tested 

under the direct supervision of the certifying agency.

Test Standards for Evaluating

Commercial Refrigerators and Freezers

ANSI/UL471 - 2014, Standard for Safety

ANSI/NSF 7 - 2014, Performance / Sanitation

ASHRAE 72 - 2014, Energy

In addition to the standard tests listed above, 

refrigerators and freezers should be evaluated for 

satisfactory customer performance in end use 

applications. This includes the following:

1) Life Testing of both Cabinets and Components

2) Suitability of Equipment for Application

3) Agency Approval of Vendor Components

Testing is a long and complex operation and 

requires four to eight weeks per Basic Model. For 

companies without an accredited laboratory, the task 

can become costly 

and time consuming 

with limited industry 

recourses.
Implications

SNAP Rule 20 Page 6

Energy Implications

Impact Analysis of DOE’s March 28, 2017 Final Rule

All refrigerant changes affect the operating efficiency of the systems using the 

new gas. Some systems require engineering time to bring those efficiencies 

back to par or better, but all require work as there is no such thing as a true 

“drop-in”.

Because of the possibility for DOE Enforcement Testing and the margin of error being so small to attain compliance, all products transitioning from HFC 

refrigerants to an approved alternative will require validation testing to ensure 

compliance to applicable energy efficiency specifications.

Some Affected

Equipment Classes

2010 - 2017

VCT.SC.M VCT.RC.M

VCT.SC.L VCT.RC.L

VCS.SC.M VCS.RC.M

VCS.SC.L VCS.RC.L

Refrigerator / Freezer

How do the proposed and final federal regulations affect CRE manufacturers:

 SNAP Rule 20 affects nearly 100% of the models comprising the available 

products for sale by the CRE industry. Of the affected products, All StandAlone models using HFC R-134a and R-404A will require redesign and 

testing. Nothing is a given despite claims of interested parties.

 DOE 2017 affects a subset of the models available for distribution and sale 

in commerce from the CRE industry. This subset is derived from the fact 

that not all models are regulated by DOE, but that nearly all models using 

a HFC refrigerant will require redesign.

The sheer magnitude of a project scope;1) to conform to Department of Energy 

efficiency specifications by 3/28/2017 and 2) effect a refrigerant change compliant to the proposed SNAP rule by 1/1/2016, are beyond the available resource 

levels of companies both small and large. More time is needed for compliance. 

DOE’s regulations are final, EPA’s SNAP Rule 20 is currently only a proposal.

Energy (KWH/Day)

Cabinet Volume (cu-ft)

Ind ustry

DOE-2010

DOE-2017

E*-V2.1

E*-V3.0
Page 7

Proposal to prohibit certain 

high-GWP HFC alternatives

Recommendations

REFRIGERATION

1) R-404A New & Retrofit Equipment

Stand-Alone & Remote 1/1/2020

2) R-134a New Equipment Only

Stand-Alone Only 1/1/2022

3) Define “Lower GWP Limit” and hold for 10 

years past HFC phase out date.

a) Refrigerators Set at 650 GWP

Hold till 2032.

b) Freezers Set at 1350 GWP

Hold till 2030.

4) Provide SNAP Approval “Acceptable” for

a) “HFO” Blends R-448A and R449A. 

b) “HFO” Blend R-1234yf.

The CRE Industry is Not Ready for this Transition
Traulsen - ITW Food Equipment Group, LLC

4401 Blue Mound Road

Fort Worth, TX 76106

Mary Dane Joe Sanders

Agency Approval Engineer Principal Engineer

(800) 825-8220 x6741 (817) 625-9671 x6537

Cell: (817) 458-2165 Cell: (817) 528-3762

mdane@traulsen.com jsanders@traulsen.com