Market Characterization of the U.S. Aerosols 

Industry, U.S. Motor Vehicle Air Conditioning 

Industry, U.S. Commercial Refrigeration

Industry, and U.S. Foams Industry 

P REPARED FOR :

Stratospheric Protection Division 

Office of Air and Radiation 

U.S. Environmental Protection Agency 

Washington, D.C. 20460 

P REPARED BY :

ICF International 

1725 Eye Street, NW 

Washington, DC 20006 

J ULY 201 5
Table of Contents

Acronyms and Abbreviations..............................................................................................................1

Executive Summary............................................................................................................................2

The U.S. Aerosols Industry..................................................................................................................3

1. Introduction ...................................................................................................................................... 3

2. Market Characterization................................................................................................................... 3

Overview of Aerosol Products .................................................................................................. 4

Consumer Aerosols................................................................................................................... 5

Technical Aerosols .................................................................................................................... 7

Medical Aerosols....................................................................................................................... 9

3. Sector Background.......................................................................................................................... 10

Aerosol Propellants................................................................................................................. 12

Aerosol Solvents...................................................................................................................... 13

4. Climate-Friendly Alternatives ......................................................................................................... 14

The U.S. Motor Vehicle Air Conditioning Industry .............................................................................17

1. Introduction .................................................................................................................................... 17

2. Market Characterization for Light-Duty Vehicles ........................................................................... 17

Overview of Light-Duty Vehicles and Trucks........................................................................... 17

Vehicle Manufacturers............................................................................................................ 18

3. Sector Background.......................................................................................................................... 20

Refrigerant Use in Motor Vehicle Air Conditioning ................................................................ 21

4. Climate-Friendly Alternatives ......................................................................................................... 22

HFC-152a................................................................................................................................. 23

HFO-1234yf ............................................................................................................................. 23

Carbon Dioxide........................................................................................................................ 24

Other Alternatives (Not Currently Listed by SNAP) ................................................................ 24

The U.S. Commercial Refrigeration Industry......................................................................................26

1. Introduction .................................................................................................................................... 26

2. Market Characterization................................................................................................................. 26

Overview of Commercial Refrigeration Systems.................................................................... 26

Equipment Manufacturers...................................................................................................... 31

Equipment Owners Performing System Retrofits................................................................... 33

3. Sector Background.......................................................................................................................... 33

Refrigerant Use in Commercial Refrigeration......................................................................... 33

4. Climate-Friendly Alternatives ......................................................................................................... 36

The U.S. Foams Industry...................................................................................................................39

1. Introduction .................................................................................................................................... 39

2. Market Characterization................................................................................................................. 39

Overview of Foam Types and End-Uses.................................................................................. 39

Foam Market........................................................................................................................... 42

Foam Sector Revenue and Employment................................................................................. 43

Foam Applications................................................................................................................... 44

3. Sector Background.......................................................................................................................... 46

4. Climate-Friendly Alternatives ......................................................................................................... 47

References.......................................................................................................................................50

1

Acronyms and Abbreviations

CAA Clean Air Act

CFC chlorofluorocarbon

CG compressed gases

CO2 carbon dioxide

COP coefficient of performance 

CRP Cooperative Research Program 

CSPA Consumer Specialty Products Association 

DOE Department of Energy 

DPI dry powder inhaler

EC European Commission 

EPA Environmental Protection Agency

EU European Union 

FMEA Failure Mode and Effect Analysis 

GHG greenhouse gas

GM General Motors

GVWR gross vehicle weight rating

GWP global warming potential

HC Hydrocarbon

HCFC hydrochlorofluorocarbon

HFC hydrofluorocarbons

HFE hydrofluoroether

HFO hydrofluoroolefin

MDI metered dose inhalers

MT metric ton

MVAC motor vehicle air conditioner 

NHTSA National Highway Traffic Safety Administration

NPRM notice of proposed rulemaking 

OCF one component foams 

ODS ozone-depleting substance

OEM original equipment manufacturer

SAE Society of Automotive Engineers 

SIP State Implementation Plan

SNAP Significant New Alternative Policy

SUV sports utility vehicle

VOC volatile organic compound

XPS extruded polystyrene
2

Executive Summary

This report characterizes the current state of the U.S. market for the industries that are anticipated to be

impacted by EPA’s Final Rule “Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes 

under the Significant New Alternatives Policy Program.” This report includes information on the aerosols 

industry, the light-duty motor vehicle air conditioning industry, portions of the commercial refrigeration 

industry, and the foams industry. Historically, each of these industries has relied on ozone depleting substances

(ODS), which are substances that destroy the stratospheric ozone layer that shields the Earth from the sun’s 

harmful ultraviolet radiation. Each chapter of this document characterizes one of these industries in terms of the 

market size and companies, historical and current use of ODS and alternatives, the availability of climate-friendly 

alternatives, and barriers to transitioning to those alternatives.

In support of the Notice of Proposed Rulemaking (NPRM), EPA made available four individual market 

characterizations: “Market Characterization of the U.S. Aerosols Industry,” “Market Characterization of the 

Motor Vehicle Air Conditioning Industry,” “Market Characterization of the U.S Commercial Refrigeration 

Industry,” and “Market Characterization of the U.S. Foams Industry.” These documents are available at 

regulations.gov in docket EPA-HQ-OAR-2014-0198. This report is a compilation of the four individual market 

characterizations and the content has been updated to reflect information provided to EPA during the public 

comment period.
3

The U.S. Aerosols Industry 

1. Introduction

Aerosols use liquefied or compressed gas to propel active ingredients in liquid, paste, or powder form and many 

also contain a solvent. The propellant is emitted during use. Historically, a variety of propellants and solvents 

have been available to formulators. Hydrocarbons (HCs) (e.g., propane, isobutane, blends) and compressed 

gases (e.g., CO2, N2O, compressed air) have long been used. Prior to 1978, CFCs were predominantly used by the 

aerosol industry. CFCs were excellent propellants because of their ability to produce a fine spray; they are nonflammable, could be stored under low pressure, and, for the most part, do not react with other ingredients.1 In 

1973 chemists Sherwood Rowland and Mario Molina began studying effects of CFCs on the earth’s atmosphere. 

They discovered that CFCs were stable enough to migrate to the stratosphere and that the chlorine atoms 

contained in these molecules could break down large amounts of ozone in the stratosphere. In 1975, a major 

manufacturer of household aerosol products eliminated CFC propellants over concerns for depletion of the 

Earth’s ozone layer. In 1978, the United States banned CFC propellants.

As a result of the ban on CFC propellants, consumer products were reformulated or replaced with a variety of 

not in kind substitutes, such as pump sprays and solid or roll-on deodorants, and alternatives such as HCs, 

compressed gases, oxygenated organic compounds, and HCFCs. However, HCFCs are controlled substances 

under the Montreal Protocol on Substances that Deplete the Ozone Layer, and subject to regulation under the 

CAA including a phaseout of production and import. Sale and distribution of aerosols using HCFCs was banned in 

1994 with few exceptions. 

HCFC propellants have been or are being replaced with a range of alternatives including HFCs (e.g., HFC-134a, 

HFC-152a), HCs, compressed gases, and not-in-kind alternatives. In solvent uses, CFC and HCFCs have been or 

are being replaced by HFC-4310mee, HFC-365mfc, HFC-245fa, HCs, oxygenated organic compounds, and 

hydrofluoroethers (HFEs). Other low-GWP fluorinated compounds are in use or under development, including 

HFOs. HFO-1234ze is being used in the aerosol industry. 

The remainder of this chapter characterizes the U.S. aerosol sector in terms of market size, key market players, 

historical and current propellant and solvent use, and the availability of alternative propellants and solvents.

2. Market Characterization

The U.S. aerosol industry is characterized by many product types and applications involving multiple companies 

and markets. 2 It also can be generally characterized as a North American market rather than a global market.

Finished products are not complex to manufacture and require little labor; therefore, domestic production is 

more affordable than shipping products from overseas (Falcon Safety 2007); however, there has been an 

increasing amount of exports of aerosol products from major export hubs, such as the European Union, 

 1 An exception is CFC-11, which hydrolyzes to produce hydrochloric acid (HCl). In aerosol formulations containing water, CFC-12 or a 

mixture of CFC-12 and CFC-114 was often used (UNC 2014). 

2 NAICS codes were used to the extent possible to determine economic data about the aerosol market; however, the NAICS codes also 

include a large majority of products which are not aerosols. More detailed NAICS codes (8 to 10 digits) were researched when available.
4

Argentina, and China (EC 2001; Midwest Aerosol Association 2014). Additionally, the U.S. aerosol market is 

subject to volatile organic compound (VOC) regulations, and as a result, the United States uses larger volumes of 

HFCs in aerosol propellants than other markets in the world. 

The aerosol market in the United States continues to grow. According to the 2011 Aerosol Pressurized Products 

Survey conducted by the Consumer Specialty Products Association (CSPA), approximately 3.8 billion units were 

filled in 2011 by U.S. producers, which was 36 million units more than the total units filled in 2010 (CSPA 2012). 

Approximately $15 billion in annual revenue is generated from the sale of aerosol products nationwide. As 

shown in Figure 1, household and personal care products constitute about half of the aerosol units filled in 2011.

Figure 1: Number of Aerosol Units Filled in 2011 in the United States (CSPA 2012)

The remainder of this section is organized into the three aerosol product categories—consumer, technical, and 

medical. Information was gathered using a variety of sources, including, market profiles, historical research, and 

information provided by the aerosol and chemical manufacturing industries.

Overview of Aerosol Products

The U.S. aerosol industry is comprised of the following three product categories:

• Consumer Aerosols – this grouping consists of a wide variety of products using aerosol packaging for 

personal and household use. Examples include personal care products such as cosmetics, hairspray, 

body sprays, and deodorants are covered by this category along with a wide variety of other products 

such as tire inflators and other automotive products (e.g., auto lubricants, brake cleaners); noise horns 

and safety horns; animal repellants; spray adhesive with various applications; household and office 

cleaning products; hand-held spray cans; eyeglass and keyboard dusters; consumer freeze sprays (e.g., 

chewing gum or excrement removal); room fresheners; food dispensing products; and novelty aerosols 

(e.g., artificial snow, plastic string, noise makers, and cork poppers). 

• Technical Aerosols – this grouping consists of highly specialized products for sale and use solely in 

commercial and industrial applications that are not for normal day-to-day use. Technical aerosols 

Insect Sprays

6%

Paints and 

Finishes

11%

Household 

Products

28%

Personal Care 

Products

27%

Food

13% Automotive

13%

Animal Products

<1%

Miscellaneous

2%
5

include (but are not limited to) those products exempted from the non-essential products bans under 

EPA regulations at 40 CFR Part 82, Subpart C.3 Products include industrial cleaners (e.g., electronic 

contact cleaners, flux removers, degreasers); pesticides (e.g., certain wasp and hornet sprays, aircraft 

insecticides), mold release agents, and certain dusters (e.g., for photographic negatives, semiconductor 

chip manufacture, specimens for observation under electron microscope); and spinnerette 

lubricant/cleaning sprays. Other miscellaneous products such as industrial spray paints and document 

preservation sprays are also considered in this category.

• Medical Aerosols – this grouping consists of products that are used for healing or medicinal purposes. 

These include, but are not limited to, products regulated by the U.S. Food and Drug Administration. 

Medical aerosols include metered dose inhalers for the treatment of asthma and chronic obstructive 

pulmonary disease, calamine spray, anti-fungals, wart treatments, wound care sprays, freeze or coolant 

spray for pain relief, spray-on “liquid” bandages, and products for removing bandage adhesives.

Although aerosol propellants are used in metered dose inhalers (MDIs), MDIs are not explored in this 

market characterization because they are not affected by this final rule.

4

Some applications may be represented in more than one of the above categories. For example, insect sprayers 

have parallel lines of products with similar end-uses in both technical and consumer applications, one to be used 

by line workers around electrical lines (i.e., a technical aerosol), and another as household insect repellant (i.e., a 

consumer aerosol). Additionally, freeze sprays can be a consumer aerosol (e.g., food freeze sprays, animal waste 

sprays) or a medical aerosol (e.g., wart removers, numbing sprays).

According to the CSPA, around 400 aerosol product-related companies exist in the United States, 12.5% of which 

are in California (AboutAerosols 2013). These companies include those producing aerosol components (e.g., 

valves, cans, propellants, and other ingredients), formulating and marketing products in aerosol form, or filling 

aerosol products (AboutAerosols 2013). An estimated 138 companies have facilities with filling lines in the 

United States (CSPA 2012).

Consumer Aerosols

Demand for consumer aerosols in the United States is most concentrated within household products, which 

continue to rank as the highest production product category, reporting a 2.4% increase from 2010 to 2011 (CSPA 

2012). This trend is also true globally; about 90% of the 6.8 billion metal aerosol cans sold worldwide in 2011 

were in the beauty and household markets with 27% of sales for household care and 69% of sales for 

applications in deodorant sprays, insecticides, air fresheners and styling agents (Downey 2012). A number of 

consumer aerosol products meet niche demands, with overall volume being very small relative to other 

consumer aerosol products (e.g., boat safety horns). Such products may be purchased but not used for a long 

period of time (e.g., years), as they may be stored for emergency uses only. Some of the larger end-uses of 

consumer aerosols are described with further detail in Table 1.

 3 Under the non-essential products ban, all aerosol products, pressurized dispensers and foam products containing, or manufactured 

with, CFCs and HCFCs—except those specifically exempted by the regulations and those that are listed as essential medical devices by the 

Food and Drug Administration, at 21 CFR 2.125(e)—are banned from sale and distribution in interstate commerce in the U.S.

4 CFC-based propellants have historically been used in MDIs for inhalation therapy. A gradual shift toward the use of HFC propellants, 

including HFC-134a and HFC-227ea, began in the early 1990s. Dry powder inhalers (DPIs) are an alternative to MDIs; these delivery 

systems do not require a propellant and have been in use for more than 20 years. Although DPI use is on the rise and accounts for about 

one-third of all inhaled medication, it is recognized that both DPIs and HFC MDIs play important roles in inhalation therapy. 
6

Table 1. Market Characterization for Consumer Aerosols

Product Major Producers Key Market Information Propellants1 Solvents1

Air 

Fresheners

• Henkel AG & Co.

• KGaA

• Procter & Gamble

• Reckitt Benckiser 

Inc.

• SC Johnson & Son

• U.S. market grew by 3.4% in 2011 

(Research and Markets 2012a)

• Value of $1.8 million with total revenue of 

$770 million

• Pump/aerosol air fresheners account for 

44% of market’s total value in 2011 

(Research and Markets 2012a)

• HCs

• HFC-152a

• Not-in-kind

• Compressed 

gases (CGs)

U

Deodorants/

Antiperspirants

• Procter & Gamble

• Unilever

• Colgate Palmolive

• Dial Corporation

• Lever Brothers

• Revlon

• Church and 

Dwight

• Spray deodorants account for 14% of 

North America’s deodorant sales (Downey 

2012).

• U.S. deodorants market generated total 

revenues of $2.5 billion in 2009, at a 

compound annual growth of 4.8% from 

2005-2009 (Research and Markets 2012b)

• HCs

• HFC-152a

• Not-in-kind

•

U

Household 

Cleaners5

• Procter & Gamble

• Chase Products 

Co.

• The Clorox 

Company

• SC Johnson & Son

• Church and 

Dwight

• Reckitt Benckiser 

Inc.

• Household products continue to rank as 

the highest production product per unit of 

aerosol cans filled, reporting a 2.4% 

increase from 2010 to 2011 (CSPA 2012)

• HCs

• CGs

• Dimethyl ether

U

Hair Spray • Alberto-Culver 

Company

• Kao Brands

• Procter & Gamble

• Unilever

• Approximately 303 million aluminum and 

steel containers of hair spray were filled in 

2011 as reported by 97 U.S. company 

facilities (CSPA 2013)

• In 1999, HFC-152a was used in 

approximately 31.7 million hair sprays 

based on a review of 62 products (ICF 

1999)

• Pump sprays account for 44% of the 

market (HHS 2013)

• HCs

• HFC-152a

•

U

Tire Inflators • ITW Global Brands

• Valvoline, Co.

• Radiator Specialty 

Company

• Warren 

Distribution, Inc.

• Hutchinson Tires

U • HCs

• Dimethyl ether

HFC-134a

U

Brake 

Cleaners

• Sprayaway, Inc.

• Trak Auto 

Corporation

U • CO2 • Perchloroethylene

 5 This category in the CSPA survey contains a large number of products, including room deodorants and disinfectants, cleaners for glass, 

oven, rug, fabric, wall, tile etc., laundry products, waxes and polishes, and other household products (e.g., shoe polishes, dyes, leather 

dressings, fuels, drain openers, antistatic sprays, caulking and sealing compounds).
7

Product Major Producers Key Market Information Propellants1 Solvents1

Safety Horns • Falcon Safety • According to Falcon Safety, signal horns do 

not use HFC-152a because of safety 

concerns; HCs are safer for these 

applications than HFC-152a. 

• One manufacturer makes about 100,000 

horns per year and 100,000 refills a year 

(Falcon Safety 2007)

• HCs

• HFC-134a 

• HFO-1234ze

U

Dusters • Falcon Safety

• Sprayaway

• The duster spray market has increased 

steadily with the advent of digitalization in 

the United States, but is now a mature 

market (Falcon Safety 2007)

• One manufacturer makes 500,000 – 1 

million cans (10 ounces) per year charged 

with HFC-134a and 11 million cans per 

year charged with HFC-152a (Falcon Safety 

2007)

• CSPA estimated that in 2008, 

approximately 1,300 metric tons (MT) of 

HFC-134a (14%) and 8,300 MT of HFC-152a 

(86%) were used as propellants in dusters 

(CSPA 2008).

• HFC-134a

• HFC-152a

• HCs

• Dimethyl ether

Not Applicable

U indicates that information is not readily available. 1 Based on production of new units in the United States in 2014

Technical Aerosols

Many of the products within the technical aerosols category, defined above, including aircraft maintenance 

products, wasp and hornet sprays, and spinnerette lubricant sprays, are highly specialized products that fill 

niche market demands. Table 2 below presents a summary of the major producers, historically used propellants 

and solvents, and currently used propellants and solvents for commonly-used technical aerosols. 

Table 2: Market Characterization for Technical Aerosols

Product Major 

Producers

Key Market 

Information

Propellants Solvents

Historical Current 

(2014) Historical Current (2014)

Degreasers • CRC 

Industries

• ITW, Inc.

• Micro-Care

• MillerStephenson

• PriceDriscoll 

Corporation

• SprayOn, 

Inc.

• Zep 

Commercial

U • CFC11/CFC-12 

mixture

• Methyl 

chloroform

• HFC-134a

• HFC-152a

• HCs

• Compressed 

gases

• CFC-11

• CFC-113

• HCFC225ca/cb

• Chlorinated 

solvents

• trans-Dichloroethylene

• HFC-43-10mee

• HFC-365mfc

• HFC-245fa

• HFE-7100

• HFE-7200

• n-Propyl bromide

• Dimethyl ether

• Petroleum 

distillates
8

Product Major 

Producers

Key Market 

Information

Propellants Solvents

Historical Current 

(2014) Historical Current (2014)

• Oxygenated organic 

compounds

Aircraft 

Maintenance 

Products

• 3M 

Company

• GLI Aviation 

Products

• ITW, Inc.

• LHB 

Industries

• Nonflammability is 

a critical 

characteristic 

• HCFC-22

• CO2

• CO2

• Not-inkind

• HCFC-141b • HFE-7100 and 

blends

• HFC-43-10mee

• trans-Dichloroethylene

• Not-in-kind

• Petroleum 

distillates

• Oxygenated organic 

compounds

Wasp and 

Hornet 

Sprays6

• Amrep, Inc.

• LTC Products

U • HCFC-22

• CO2

• HCs

• CO2

• Nitrogen

• Methyl 

chloroform

• Petroleum 

distillates

• Water

Spinnerette 

Lubricant 

Sprays7

• ALFA

• G. D. 

Silicones 

Tania 

Internationa

l

• ITW, Inc.

• PriceDriscoll 

Corporation

• Specialty 

product with 

only four 

manufacturers 

– small 

percentage of 

the product 

line

• In 1998, one 

company was 

selling 20,000 

cans per year 

and another 

manufactured 

100,000 cans 

per year (ICF 

1998).

• CFC-12

• HCFC-22

• HFC-134a • CFC-114 • n-Propyl bromide

• Dimethyl ether

• Methyl siloxanes

Brake 

Cleaners

• Sprayaway, 

Inc.

• Trak Auto 

Corporation

U U • CO2 • Methyl 

chloroform

• Perchloroethylene

 6 Wasp and hornet sprays are often used by industrial users, such as public utility workers, for use on high-tension power lines. 7 Spinnerettes are used for the production of synthetic fibers (e.g., nylon). They are steel structures with many tiny holes through which 

melted resin is passed to form a spun fiber. Lubricants are applied to the spinnerette to facilitate spinning and prevent the fibers from 

sticking to the accumulated resin on the block (ICF 1998).
9

Product Major 

Producers

Key Market 

Information

Propellants Solvents

Historical Current 

(2014) Historical Current (2014)

Flux 

Removers8

• CRC 

Industries

• ITW, Inc.

• Micro-Care

• MillerStephenson

• Petroferm, 

Inc.

U • CFC-12 • HFC-134a • CFC-11

• CFC-113

• Methyl 

chloroform

• HCFC-141b

• HCFC225ca/cb

• HFC-4310mee

• HFC-245fa

• trans-Dichloroethylene

• Chlorinated 

solvents

• n-Propyl bromide

• Oxygenated organic 

solvents

Document 

Preservation 

Sprays9

• Preservation 

Technologie

s

U • CFC-12

• HCFC-22

• CO2

• HCs

• CFC-113

• HCFC-141b 

• Petroleum 

distillates

Dusters10 • CRC 

Industries

• Falcon 

Safety

• MG 

Chemicals

• SprayOn, 

Inc.

U U • HFC-134a Not 

applicable

Not applicable

Lubricant 

Sprays11

• Amrep, Inc.

• PriceDriscoll 

Corporation

U U • HCs

• CO2

• Nitrogen

• HCFC-141b U

Mold Release 

Agents

• Amrep, Inc.

• PriceDriscoll 

Corporation

• Sprayon

U • CFC-12

• HCs

• CO2

• HCs

• CO2

• HFC-134a

• not-inkind

• CFC-11

• CFC-113

• HCFC-141b

• Methylene chloride

• Perchloroethylene

• HCs

• Oxygenated organic 

solvents

• Water

U indicates that information is not readily available. Sources: ICF (1998); CSPA (2008); HHS (2013).

Medical Aerosols

Limited information is available regarding the market size for medical aerosols, including liquid bandages, freeze 

sprays (i.e., wart removers), calamine sprays, anti-fungal sprays, and bandage adhesive and remover. There are 

not-in-kind alternatives currently available for most of these medical aerosols, including lotions and pump 

sprays; however, some medical aerosols rely on the cooling effect of the aerosol propellant evaporating off of 

 8 Flux removers are used to clean excess flux and solder residue from circuit boards and electrical components.

9 Document preservation sprays are deacidification sprays that neutralize the acid in paper that causes paper to weaken and become 

brittle over time.

10 Dusters that fall under the technical aerosols category include more specialized dusters used for applications such as photographic 

negatives, semiconductor chip manufacture, and specimens for observation under electron microscope. 11 Lubricants reduce friction, heat, and wear when applied to the surfaces between moving parts. They are mainly used to repair and 

maintain electronic equipment and reduce friction between mechanical parts. Cleaner lubricants remove dirt and dust while 

simultaneously applying a protective layer of grease on a given surface (ICF 1998). Examples of applications include aircraft maintenance 

and electrical, electronic or photographic equipment.
10

skin (e.g., freeze sprays). Table 3 provides a summary of the major producers and gases historically and currently 

used as propellants and solvents in medical aerosols, as available.

Table 3: Market Characterization Summary for Medical Aerosols

Product Major Producers Key Market 

Information

Propellants Solvents

Historical Current Historical Current

Liquid 

Bandages

• Amerisource 

Bergen 

Corporation

• Johnson & 

Johnson 

Consumer 

Companies, Inc.

• NMS 

Technologies

• Prestige 

Brands, Inc.

U Not 

applicable

• HCs

• not-in-kind

U • Oxygenated 

organic 

solvents

Freeze 

Sprays12

• Merck & Co., 

Inc.

• Prestige 

Brands, Inc.

U • CFCs • HCs

• Liquefied 

petroleum 

gas

• Dimethyl 

ether

• not-in-kind

U • Oxygenated 

organic 

solvents

Calamine 

Spray

• Johnson & 

Johnson 

Consumer 

Companies, Inc.

U • CFC-11/12 

mixture

• CFC-12

• HCFC-22

• HCs

• Dimethyl 

ether

• not-in-kind

• Methylene 

chloride

• HCFC-141b

• Oxygenated 

organic 

solvents

Anti-fungal 

Sprays

• MSD Consumer 

Care, Inc.

U • CFC-11/12 

mixture

• CFC-12

• HCFC-22

• HCs

• Dimethyl 

ether

• not-in-kind

• Methylene 

chloride

• HCFC-141b

• Oxygenated 

organic 

solvents

Bandage 

Adhesive 

and 

Remover

• ARI

• Medline 

Industries, Inc.

• Pac-Kit Safety 

Equipment

U • CFCs • HCs

• DME

• not-in-kind

• CFC-113 • Oxygenated 

organic 

solvents

Sources: HHS (2013); Good Guide (2013); EPA (2013a); Proctor & Gamble (1973); EPA (1990); Gertrude Fisher (1978)

U indicates that information is unavailable.

3. Sector Background

Historically, a variety of propellants and solvents have been available to aerosol formulators. While HCs (e.g., 

propane, isobutane, blends) and CGs (e.g., CO2, N2O, compressed air) have always had a market presence, 

before 1978, CFCs and other ODS were the predominant propellants and solvents used by the aerosol industry 

because of their excellent mixing, solvating, and dispersing properties. CFC-12 was the most popular propellant 

while other CFCs (e.g., CFC-11 and -113) and methyl chloroform were often used as solvents in aerosols. CFCs 

were excellent as propellants because of their ability to produce a fine spray; they were non-flammable, could 

 12 Freeze sprays include both wart removing freeze sprays and topical coolant sprays for pain alleviation.
11

be stored under low pressure, did not react with other ingredients, and were safe to use. CFCs were also 

excellent solvents because they were effective at dissolving active ingredients used in aerosol products. 

In response to the 1978 ban, many consumer products previously using CFCs were reformulated successfully to 

use non-ODS propellants and solvents or were replaced by not-in-kind alternatives, such as pump sprays or solid 

and roll-on deodorants. The market trended toward the use of these not-in-kind products, which make up an 

important share of the market in household and industrial products; however, not-in-kind products often 

present “trade-offs” to manufacturers in terms of cost, effectiveness, safety, and environmental properties (IPCC 

2005), and the number of aerosol products used in the United States continues to grow. In-kind aerosol 

propellant alternatives also emerged into the market in response to the 1978 ban including HCFCs—notably 

HCFC-22 as a propellant, and HCFC-141b and HCFC-225ca/cb as solvents—in addition to HCs, compressed gases, 

and oxygenated organic compounds (e.g., alcohols, ketones, esters).

Section 610 of the 1990 CAA Amendments established the nonessential product bans which addressed most of 

the remaining uses of CFCs and HCFCs in aerosols and pressurized dispensers.

13 The Nonessential Product Bans 

in 1993 and 1994 prohibited the sale, distribution, or offer for sale or distribution of all CFC-containing and 

HCFC-containing aerosols except those specifically exempted. In establishing these bans, the EPA considered the 

purpose or intended use of the product, the technological availability of alternatives, issues of safety and health, 

and other relevant factors14. Some uses of CFCs in aerosols (such as solvents, active ingredients, or sole 

ingredients) and certain uses of CFC-based aerosol propellants were exempted from the ban given the lack of 

alternatives available at the time.

In the 1990s, HCFC propellants began to be replaced with high-GWP HFCs—including HFC-134a—as well as a 

variety of lower or no global warming potential alternatives, such as HCs, compressed gases, not-in-kind 

alternatives, and HFC-152a. Similarly, HCFC solvents also began to be replaced by HFC-4310mee, HFC-365mfc, 

HFC-245fa, HCs, oxygenated organic compounds, and HFEs. The industry overcame technical hurdles with HFCs 

and HFEs by blending these compounds with substances such as trans-1,2-dichloroethylene to increase 

solvency. Trans-1,2-dichloroethylene, commonly referred to as “trans,” is an aggressive solvent. Because of this 

characteristic, and because of its flammability, trans is usually combined with other solvents, such as HFCs and 

HFEs, to form effective azeotropes that are less flammable and less aggressive on precision metal and 

electronics parts.

Additionally, the U.S. aerosol market is using a larger volume of HFCs in aerosol products relative to aerosol 

markets globally due to continuously evolving state and federal regulations for VOCs that require manufacturers 

to limit the amount of VOC (e.g., HCs) in their formulations for various locations of the country. HFCs, such as 

 13 Products still using CFCs at the time included plastic party streamers, noise horns (e.g., marine safety noise horns, sporting event noise 

horns, personal safety noise horns), and cleaning fluids for noncommercial electronic and photographic equipment (e.g., solvent wipes, 

keyboard dusters, flux removers, and tape and computer disk head cleaners).

14 EPA exempted the following products from the nonessential product bans: Aircraft pesticides; Medical devices listed in 21 CFR 

2.125(e); Lubricants, coatings, or cleaning fluids for aircraft maintenance containing CFCs or HCFCs as solvents; Lubricants, coatings, or 

cleaning fluids for electrical, electronic or photographic equipment containing CFCs or HCFCs as solvents; Mold release agents containing 

CFCs and HCFCs as solvents and mold release agents containing HCFC-22 as a propellant; Spinnerette lubricant/cleaning sprays containing 

CFCs or HCFCs as solvents and/or propellants; Document preservation sprays containing CFCs and HCFCs as solvents; Document 

preservation sprays containing CFCS or HCFCs as propellants for use on thick books with coated or dense paper, and tightly bound 

documents, only; Wasp and hornet sprays containing CFCs or HCFCs for use near high-tension power lines only; Lubricants for 

pharmaceutical and tablet manufacture; Gauze bandage adhesives and adhesive removers; and Red pepper bear repellent sprays which 

contain CFC-113 as the solvent but which contain no other CFCs.
12

HFC-152a, are exempt from the definition of VOC in regulations under the CAA addressing the development of 

State Implementation Plans (SIPs) to attain and maintain the national ambient air quality standard for ozone (40 

CFR 51.100(s)), and therefore, can be suitable alternatives to VOCs in states (or municipalities) with VOC 

restrictions.

VOC regulations often drive propellant and solvent formulation choices in aerosol products. States that regulate 

the VOC content in consumer products include California, the Ozone Transport Commission or “OTC” states 

(Virginia to Maine), and the Lake Michigan Air Directors Consortium, or “LADCO” states (Illinois, Indiana, 

Michigan, Ohio, and Wisconsin) (Geer 2011; ISSA 2012; Beaver 2011). Individual states such as Texas and 

Georgia and counties within certain states (e.g., Atlanta metro area and Phoenix) also have VOC regulations 

(Beaver 2011). VOC regulations can affect the entire aerosol formulation—the solvent system must match the 

propellant formulation, and if one component changes, the entire formulation is affected. 

Different products have different VOC limits, which can vary based on local regulations. For example the VOC 

limit for hairspray cannot exceed 80 percent (on a weight percent basis) according to EPA regulation. However, 

in California and other states with VOC regulations, the limit cannot exceed 55 percent; for aerosol deodorants, 

EPA has a 20 percent VOC limit, but California and other states only allow a 0-10 percent limit (ISSA 2012). 

Although on occasion differing formulations have been designed for the same product in different locales, it is 

often not practical for an aerosol manufacturer to change the aerosol formulation of the same product to 

address varying VOC regulations (i.e., no-VOC, low-VOC, and high-VOC formulations). Therefore, to comply with 

VOC regulations in one state or area (e.g., if HFC-152a is the only option in California), a manufacturer may use 

the same VOC exempt substitute in all formulations of one product across the United States, which increases the 

use of HFCs nationally for some products. 

Aerosol Propellants

The U.S. aerosol industry has already made significant progress in adopting a variety of propellants and not-inkind alternatives to ODS propellants; however, high-GWP HFC propellants continue to occupy a portion of 

aerosol products on the market, particularly in personal consumer products and auto products. Table 4

illustrates a sample of household aerosol products containing propellants queried from the U.S. Department of 

Health and Human Services Household Product Database (HHS, 2013). Based on this sampling, personal care 

(which are also the largest continued user of HFC propellants) and household and home office products make up 

the majority of aerosol products currently manufactured. 
13

Table 4: Sample of Propellants in Aerosol Products from the U.S. HHS Household Products Databasea

Category (Total Sample Size) Propellant Type Percentage of Products in Sample by Propellant Type

Arts and Crafts (74)

HFC-134a 1%

Hydrocarbons 96%

Dimethyl ether 3%

Auto Products (130)

HFC-134a 12%

HFC-152a 3%

Hydrocarbons 72%

Carbon dioxide 2%

Dimethyl ether 11%

Home Maintenance (154)

HFC-134a 6%

Hydrocarbons 76%

Dimethyl ether 16%

Household and Home Office (364)

HFC-134a 1%

HFC-152a 3%

Hydrocarbons 86%

Compressed Gas 6%

Dimethyl ether 3%

Personal Care (285)

HFC-134a <1%

HFC-152a 35%

Dimethyl ether 18%

Hydrocarbons 46%

Pesticides (92) HFC-152a 1%

Hydrocarbons 99%

Pet Care (16) Hydrocarbons 70%

Dimethyl ether 30% a Source: HHS (2013).

Note: A query was performed in March 2013 on the aerosol products listed in the U.S. HHS Household Products Database to provide 

the sampling shown in this table. Products were identified through searches of products containing known aerosol propellants. This 

table and the U.S. HHS Household Products Database does not provide a comprehensive compilation of all products on the market that 

utilize aerosol propellants. Rather, this sampling is intended to demonstrate the various aerosol propellants used in 2013 among 

categories tracked in this database. Different variations of the same product (i.e. air fresheners with different scents or spray paints of 

different colors) are counted as separate products.

In the early to mid-1990s, ODS propellants in use continued to include CFC-12, CFC-114, HCFC-22, and HCFC142b because their market presence was in exempted products only. HCFC-22 was the most widely used HCFC 

propellant in the 1990s with the transition from CFC-12 to HCFC-22 taking place during 1990 and 1991. 

Beginning in the 1990s the aerosol industry also became far more dependent on HFCs with the introduction of 

VOC regulations in the 1990s, despite the widespread use of HCs--known VOCs--in aerosol products.

CSPA estimated that in 2008, the majority of products using HFC-152a were consumer products (e.g., hairsprays, 

dusters, deodorant body sprays, antiperspirants, and deodorants) with total use equal to 21,417 metric tons 

(MT), and the majority of products using HFC-134a being technical products (e.g., tire sealant/inflators and 

degreasers) with total use of 3,242 MT (CSPA 2008).

Aerosol Solvents

Table 5 illustrates a sample of household aerosol products containing solvents queried from the U.S. 

Department of Health and Human Services Household Product Database (HHS 2013). As shown, most types of 
14

aerosol products require solvents such as alcohols and hydrocarbons. Water is also a commonly used solvent; 

however, those products are not reflected in the table below due to it being difficult to isolate aerosol products 

using water as a solvent from those containing water for other purposes.

Table 5: Sample of Solvents in Aerosol Products from the U.S. HHS Household Products Database

Category (Total Sample Size) Solvent Type Percentage of Product in Sample by Solvent Type

Arts and Crafts (111)

Hydrocarbons 47%

Oxygenated Organic Solvents 50%

Chlorinated Organic Solvents 4%

Auto Products (163)

Hydrocarbons 37%

Oxygenated Organic Solvents 45%

Chlorinated Organic Solvents 17%

Home Maintenance (72)

Hydrocarbons 44%

Oxygenated Organic Solvents 35%

Chlorinated Organic Solvents 19%

Household and Home Office (97)

Hydrocarbons 71%

Oxygenated Organic Solvents 24%

Chlorinated Organic Solvents 5%

Personal Care (3) Hydrocarbons 100%

Pesticides (19) Hydrocarbons 100%

Pet Care (2) Hydrocarbons 100%

Source: HHS (2013).

Note: A query was performed in March 2013 on the aerosol products listed in the U.S. HHS Household Products Database to provide the 

sampling shown in this table. Products were identified through searches of products containing known aerosol solvents. This table and 

the U.S. HHS Household Products Database do not provide a comprehensive compilation of all products on the market that utilize 

aerosol solvents. Rather, this sampling is intended to demonstrate the various aerosol solvents used in 2013 among categories tracked 

in this database. Different variations of the same product (i.e. air fresheners with different scents or spray paints of different colors) are 

counted as separate products.

Aerosol solvent applications historically used CFC-11, CFC-113, methyl chloroform, and HCFC-141b. CFC-11 was 

used in precision and general mold release agents exclusively as a diluent,15 not as an active ingredient in 

solvent applications. CFC-113 served as both a diluent and active ingredient (i.e., in electronics solvent cleaners 

and as a diluent in mold release agents and lubricants). Methyl chloroform was more widespread in its use (i.e., 

as a diluent in applications such as water and oil repellants, tire shiners, insecticides, and mold release agents 

and as a solvent in electric motor cleaners, spot removers, and brake cleaners). Information on the use of HFCs, 

such as HFC-43-10mee and HFC-365mfc, in the aerosol solvent market is not readily available; however, it is 

expected to be minimal (IPCC 2005). 

4. Climate-Friendly Alternatives

A variety of alternatives are available to replace HCFC, HFC-134a and HFC-152a propellants and HCFCs, HFC4310mee, HFC-365mfc, and HFC-245fa solvents used in aerosols. Many alternatives have an established market 

presence because of the direct transition from CFCs and HCFCs to hydrocarbons, oxygenated organic 

compounds, and not-in-kind alternatives. Lower-GWP fluorinated compounds are also in use or under 

development, including HFOs. Table 6 below summarizes the status of several climate-friendly alternatives for 

aerosol propellants and aerosol solvents under SNAP and available information on use in the United States.

 15 A diluent is a type of solvent used to weaken the strength of a particularly aggressive solvent.
15

Table 6: Overview of Climate-friendly Alternatives

Alternative Overview

Aerosol Propellants

C3-C6 Hydrocarbons (propane, n-butane, 

isobutane)

• Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

Dimethyl Ether • Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

Not-in-kind devices • Acceptable under SNAP

• Widely used alternative to aerosolized products in consumer, 

technical, and medical aerosols 

Compressed Gases (carbon dioxide, air, 

nitrogen, nitrous oxide)

• Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

HFO-1234ze(E) • Acceptable under SNAP

• Available in the U.S. market as of 2012

Aerosol Solvents

C5-C20 Hydrocarbons (pentane, hexane, 

heptane)

• Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

HFE-7000, HFE-7100, HFE-7200, HFE347pcf2

• Acceptable under SNAP

• Widely used in the U.S. market (HFE-347pcf2 still emerging in the 

U.S. market) in technical aerosols

SolsticeTM-1233zd(E) (also known as trans1-chloro-3,3,3-trifluoroprop-1-ene)

• Acceptable under SNAP

• Available in the U.S. market as of 2013

MPHE • Acceptable under SNAP

Oxygenated Organic Compounds (esters, 

ethers, alcohols, and ketones)

• Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

Water • Acceptable under SNAP

• Widely used in consumer, technical, and medical aerosols in the 

United States

Many companies have already transitioned to non-HFC propellants and solvents; however, technical, financial, 

and practical barriers have existed for some products that have prevented the complete transition away from 

HFCs in aerosols. The European aerosol industry has adopted a Code of Practice against using HFCs whenever 

feasible with only a small number of technical aerosols that do not have safe, practical, economic or 

environmentally acceptable alternatives using HFCs. These include products used in maintenance, repair, 

cleaning, testing, disinfecting, manufacturing, installation and other applications where a non-flammable 

formulation is required for safety reasons (EAF 2013).

In the United States, HFCs are often the propellant and/or solvent of choice to address product-related 

performance and flammability concerns when VOCs are restricted, although water is also a widely-used solvent 

in such cases. Replacements to HFCs are typically not drop-in replacements since the entire formulation must be 

evaluated and potentially changed. Safety considerations are another factor for this industry when evaluating 
16

alternative formulations. In undergoing a transition to certain replacements (e.g., flammable or more toxic 

compounds), workplace environmental controls may be a large expense for a company if they do not already 

have them in place. Liability insurance and associated plant safety requirements will increase if transitioning to 

the use of a flammable propellant or solvent. Several additional factors must be examined when reformulating 

including safety hazards (e.g., toxicity, corrosiveness, irritants, cancer/reproductive harm, flammability), 

container corrosion, properties of the propellant (e.g., vapor pressure, flash point, solubility in water, boiling 

point), efficacy, and cost (Geer 2011). 

The use of HFCs is considered by the U.S. aerosol industry to be flat to declining, and compared to other sectors 

where HFCs are used (e.g., refrigeration, AC, foams) total use is on a smaller scale. 
17

The U.S. Motor Vehicle Air Conditioning Industry

1. Introduction

Motor vehicle air conditioners (MVACs) cool the passenger compartment of light-duty vehicles (i.e., passenger 

cars), light-duty trucks, heavy-duty vehicles, off-road vehicles, buses, and passenger rail vehicles. The MVAC 

sector historically relied on CFC-12, and to a more limited extent, HCFC-22 in passenger rail and buses, both of 

which are ODS. In advance of the 1996 phaseout of CFC-12 and the continued phaseout of HCFCs, the U.S. MVAC 

industry largely transitioned away from ODS by 1994, relying most heavily on the high-GWP HFC refrigerant, 

HFC-134a. While HFC-134a remains the most predominant refrigerant used in new cars today, lower-GWP 

alternatives are entering the U.S. market in newly manufactured light-duty vehicles. This is facilitated by EPA 

approval of alternatives under the SNAP program and the availability of air conditioning credits to enable 

companies to meet the U.S. fuel economy standards for light-duty vehicles and trucks. 

The remainder of this chapter characterizes the MVAC sector for light-duty vehicles and trucks manufactured 

and sold in the United States in terms of market size, key market players, historical and current refrigerant use, 

the availability of alternative refrigerants, and barriers to transitioning to alternative refrigerants. Light-duty 

vehicles and trucks are the most numerous of the vehicle types, and the only types of vehicles affected by this 

rulemaking. 

2. Market Characterization for Light-Duty Vehicles

This section presents available market data on automobile and MVAC manufacturers. The majority of vehicle 

manufacturers assemble and install their own MVAC systems, while a limited number may purchase assembled 

MVAC systems. Because almost all cars sold in the United States are equipped with an air conditioning system, 

vehicle production, import and export, and sales data are used to characterize the light-duty MVAC market in 

the United States.

Overview of Light-Duty Vehicles and Trucks

Definitions and fleet estimates of light-duty vehicles and trucks are provided below. 

• Light-duty vehicles include standard and large passenger cars, which meet the criteria outlined in 40 

CFR 86.1803-01, which defines light-duty vehicles as a passenger car or passenger car derivative capable 

of seating 12 passengers or less, and categorized as Class 1 vehicles with gross vehicle weight rating less 

than 6,000 lbs (EPA 2010a). Typical light-duty vehicles include passenger cars, minivans, sports utility 

vehicles (SUVs), pick-up trucks, and utility vans (EPA 2011a). These vehicles represent the largest use of 

MVAC. 

• Light-duty trucks are defined as vehicles with gross vehicle weight rating less than 8,500 lbs, or between 

8,500 and 10,000 lbs that meet the criteria outlined in 40 CFR 86.1803-01, which defines a light-duty 

truck as any motor vehicle rated at 8,500 pounds gross vehicle weight rating (GVWR) or less which has a 

vehicle curb weight of 6,000 pounds or less, a basic vehicle frontal area of 45 square feet or less, and

which is: (1) Designed primarily for purposes of transportation of property or is a derivation of such a 

vehicle, (2) Designed primarily for transportation of persons and has a capacity of more than 12 persons, 

or (3) Available with special features enabling off-street or off-highway operation and use. Vehicles in 
18

this category are categorized as Class 2A vehicles and include truck-based station wagons, minivans, full 

size pick-up trucks, and full-size SUVs (EPA 2011a; DOT 2013a). 

Fleet estimates (i.e., the number of vehicles in use) within the United States are summarized in Table 7 below, 

based on readily available literature. 

Table 7. Light-Duty Vehicle and Truck Fleet Size Estimates

Year Number of Light-Duty Vehicles and Trucks Source

2010 239,812,000a Ward’s (2011)

2010 237,129,000 ICCT (2012)

2011 233,841,000b DOT (2013a)

a Includes 118,946,744 cars and 120,865,240 commercial vehicles.

b Includes light-duty vehicles (192,513,278 short wheel base and 41,328,144 long wheel base).

Vehicle Manufacturers

Available 2011 U.S. Census data on the U.S. vehicle manufacturing industry is provided in Table 8, including 

information on total shipment values, number of employees, number of establishments, and number of 

companies/firms. 

Table 8. 2007 Census Data on the Vehicle Manufacturing Industry

Industry NAICS code

Total Value of 

Shipments* ($1,000)

Number of 

Employees

Number of 

Establishments

Number of 

Companies/Firms

Automobile and Light-Duty 

Motor Vehicle Manufacturing

336111 84,727,558 65,436 188 174

Light Truck and Utility Vehicle 

Manufacturing

336112 154,035,538 84,806 90 66

*Value of shipments is defined as received or receivable net selling values, free on board plant (exclusive of freight and taxes), of 

all products shipped as well as all miscellaneous receipts, such as receipts for contract work performed for others, installation 

and repair, sales of scrap, and sales of products bought and sold without further processing.

Known light-duty vehicle and truck manufacturers within the United States are listed below. The companies 

listed were identified during literature review while developing this report, and do not necessarily represent an 

inclusive list of all companies manufacturing within the United States. (Lowe et al. 2010; Nielsen et al. 2010; EPA 

2011a)

• BMW • Hyundai • Nissan

• Fiat Chrysler Automobile (FCA) • Kia • Subaru

• Ford • Mazda • Toyota

• General Motors (GM) • Mercedes-Benz • Volkswagen

• Honda • Mitsubishi Volvo

The largest light-duty vehicle and truck manufacturers in the United States are GM, Ford, and FCA. The “Detroit 

Three” are headquartered in the Detroit, Michigan area, with the majority of their U.S. plants located in the 

Great Lakes region, and the remainder primarily located in southern states (International Trade Administration 

2010). 
19

2.2.1. Vehicle Production

Production estimates for the U.S. vehicle manufacturing industry by vehicle type are presented in Table 9.

Table 9. Estimated Number of Light-Duty Vehicles and Trucks Produced Annually in the United States

Year

Production

Light-Duty Vehicles Light-Duty Trucks Total

2005 4,284,391 7,249,964 11,534,355

2006 4,340,673 6,525,355 10,866,028

2007 3,895,684 6,583,451 10,479,134

2008 3,755,039 4,701,500 8,456,539

2009 2,229,656 3,333,408 5,563,064

2010 2,781,947 4,776,365 7,558,312

2011 3,019,848 5,388,169 8,408,017

2012 4,106,991 5,937,229 10,044,220

2013 4,357,929 6,446,965 10,804,894

Sources: OICA (2014), BEA (2014), Automotive News (2008, 2009, 2011, 2012), DOT (2014)

2.2.2. Imports and Exports Market

The U.S. import and export markets for light-duty vehicles and trucks are significant. Foreign markets accounted 

for nearly 70% of Ford vehicles sold in 2007 and 64% of GM’s total sales in 2008. Canada was the top export 

destination, with exports of $17 billion, followed by Germany ($3.6 billion), Saudi Arabia ($2.95 billion), China 

($2.91 billion), and Mexico ($2.8 billion) (International Trade Administration 2011). In 2013, over 20% of the 

vehicles produced in the United States were exported to approximately 180 countries, representing over $52 

billion (Association of Global Automakers 2014a). International automakers, which contribute to approximately 

45% of all U.S. vehicle production, exported nearly 800,000 vehicles to more than 60 countries in 2013 (AGA and 

AIADA 2014). Exports vary broadly among the major manufacturers in the United States. GM, Ford, and FCA 

have traditionally exported most successfully to the Middle East and Central and South America while BMW and 

Mercedes-Benz use their U.S. facilities to satisfy the full global demand for their SUVs. Japanese manufacturers 

are increasingly exporting vehicles from the United States to Central and South America (Alliance of Automobile 

Manufacturers 2014). 

The United States imports more vehicles by volume and value than any other country. In 2010, Mexico, Canada, 

Germany, Japan, and Korea accounted for 93% of all U.S. light-duty vehicle imports; Mexico and Canada alone 

accounted for 48% of U.S. light-duty vehicle imports (International Trade Administration 2011). 

Vehicle import and export estimates for the U.S. industry by vehicle type are presented in Table 10. The 

International Trade Administration (2014) provided both import and export data of light-duty vehicles and 

trucks; however, the data combined light-duty vehicles and trucks. To disaggregate the data into light-duty 

vehicles and trucks, the annual ratio of light-duty vehicles to trucks that are produced based on the production 

data (Table 9) was applied to the total, which is roughly 40 percent light-duty vehicles and 60 percent light-duty 

trucks each year.
20

Table 10. Estimated Number of Vehicles Imported and Exported by the United States

Year

Imports Exports

Light-duty 

Vehicles

Light-duty 

Trucks

Total Light-duty 

Vehicles

Light-duty 

Trucks

Total

2005 2,453,820 4,143,277 6,597,097 471,291 795,774 1,267,065

2006 2,940,203 4,409,859 7,350,062 578,822 868,144 1,446,966

2007 2,656,448 4,478,232 7,134,680 614,905 1,036,606 1,651,511

2008 2,883,764 3,603,015 6,486,779 703,188 878,572 1,581,760

2009 1,746,438 2,598,200 4,344,638 405,610 603,432 1,009,042

2010 2,142,100 3,656,289 5,798,389 513,368 876,254 1,389,622

2011 2,165,210 3,845,539 6,010,749 571,669 1,015,316 1,586,985

2012 2,838,986 4,105,171 6,944,157 738,183 1,067,412 1,805,595

2013 2,879,909 4,271,187 7,151,096 781,700 1,159,338 1,941,038

Source: International Trade Administration (2014)

2.2.3. Vehicle Sales

Estimates of U.S. light-duty vehicle and light-duty truck sales are presented in Table 11. In 2010, sales by foreign 

manufacturers accounted for approximately 54% of the U.S. market of light-duty vehicle sales; Japanese 

manufacturers decreased their market share to 38.8% in 2010, from 40.5% in 2009 while German manufacturers 

increased their market share from 7.3% to 7.6% and Korean manufacturers’ market share grew from 7.1% to 

7.7% (International Trade Administration 2011). In 2013, foreign manufacturers’ share of U.S. vehicle sales 

accounted for more than 59% of the U.S. market (Association of Global Automakers 2014b). 

Table 11. U.S. Sales of Light-Duty Vehicles and Trucks

Year

Sales

Light-duty Vehicles Light-duty Trucks Total

2005 7,667,066 9,288,400 16,955,466

2006 7,820,854 8,766,721 16,587,575

2007 7,618,413 8,399,807 16,018,220

2008 6,813,369 6,345,806 13,159,175

2009 5,400,890 4,940,454 10,341,344

2010 5,635,433 5,829,948 11,465,381

2011 6,089,422 6,603,650 12,693,072

2012 7,241,900 7,166,834 14,408,734

2013 7,585,800 7,946,200 15,532,000

Source: Ward’s Automotive Group (2011 & 2013), BEA (2014)

3. Sector Background

MVAC systems have been in widespread production in the United States since the 1960s. As of 2012, more than 

98% of passenger vehicles sold in the United States were estimated to contain MVAC systems (ICCT 2012). This 

section provides an overview of MVAC use in light-duty vehicles and trucks, including a description of the vehicle 

types and fleet estimates, and their historical refrigerant use. 
21

Refrigerant Use in Motor Vehicle Air Conditioning

Historically, the light-duty MVAC sector relied on the ODS refrigerant CFC-12. Automobile manufacturers 

transitioned to the non-ozone depleting alternative HFC-134a in the mid-1990s. HFC-134a, like its predecessor, 

is a potent greenhouse gas that contributes to climate change. HFC-134a, which has a GWP of 1,430 (IPCC 2007),

is the predominant refrigerant used today, as illustrated in Figure 2. 

Figure 2: U.S. Light-Duty Vehicle and Truck MVAC Refrigerant Use Over Time*

* “Other” includes <1% of the market consisting of a variety of blends. 

Source: EPA Vintaging Model 2014. 

The overall decrease in consumption shown in Figure 2 has been driven by several factors: EPA’s Vintaging 

Model is based on actual stock and sales of cars/trucks through 2013, and there was a fairly significant drop in 

sales around 2008-2009 due to the U.S. and global recession. That coupled with modeled decreases in the HFC134a MVAC light-duty vehicle charge size in 2002 and again in 2007 contribute to the decreases in refrigerant 

use seen in the figure. Charge size decreases also occurred for light-duty trucks in 2003 and 2006. Estimates of 

conventional (ODS or HFC) MVAC charge sizes from various sources are shown in Table 12. The average lifetime 

of light-duty vehicles and trucks in the United States is currently estimated to be 11.5 years (Auto Care 

Association 2015).

Table 12. Average Light-Duty Vehicle and Truck MVAC Charge Sizes for Conventional (ODS/HFC) Systems 

Refrigerant Charge Size (kg) Sources

0.6 - 0.8 ICCT (2012)

0.4 - 1.2 RTOC (2010)

0.4 – 0.8 EIA (2012a)

0.77- 0.95 EPA (2011a)

 -

 10,000

 20,000

 30,000

 40,000

 50,000

 60,000

 70,000

 80,000

 90,000

 100,000

1985 1990 1995 2000 2005 2010 2015

Refrigerant Use (MT)

CFC-12 HFC-134a HFO-1234yf Other
22

Under the SNAP program EPA has found acceptable, subject to use conditions, three MVAC refrigerants with 

lower GWPs: HFC-152a, hydrofluoroolefin (HFO)-1234yf, and carbon dioxide (CO2) (R-744). None of these 

alternatives deplete the ozone layer and all have significantly lower GWPs than CFC-12 or HFC-134a. Table 13

shows the relative GWPs of these MVAC refrigerants and whether or not they are ozone depleting. Today, there 

are cars on the road in the United States using CFC-12, HFC-134a, and HFO-1234yf.

Table 13. Environmental impacts of MVAC refrigerants

MVAC refrigerant GWP Ozone depleting?

CFC-12 10,900 Yes

HFC-134a 1,430 No

HFC-152a 124 No

HFO-1234yf 4 No

CO2 (R-744) 1 No

Source: IPCC (2007)

Transition away from HFC-134a to these climate-friendly alternatives is likely being enhanced by the joint 

regulations promulgated by the EPA and Department of Transportation’s National Highway Traffic Safety 

Administration (NHTSA), which established GHG and fuel economy standards for light-duty vehicles and trucks. 

As established by EPA’s Final Rulemaking for 2017-2025 Light-Duty Vehicle Greenhouse Gas Emission Standards, 

vehicle manufacturers may earn credits toward meeting the GHG standards by improving air conditioning 

systems. Both direct and indirect credits are available. Credits can be earned directly by reducing emissions 

through improved leak control and/or use of a lower-GWP refrigerant. Indirect credits can be earned through 

improvements to technologies that increase efficiency and result in decreased consumption of fuel to provide 

mechanical power to the MVAC system. The EPA regulations allows vehicle manufacturers to generate direct 

leakage credits of up to 13.8 and 17.2 g/mi CO2eq and indirect efficiency credits of up to 5.0 and 7.2 g/mi CO2eq 

for cars and trucks, respectively, towards compliance with the industry fleet-wide average standard projected to 

be 163 g/mi CO2eq in model year 2025 (77 FR 62,624).

Transition to climate-friendly alternatives has already begun in the United States based on these credits. 

Transition is also occurring widely in the European Union (EU), prompted by the EU Directive on Mobile Air 

Conditioning (MAC Directive) (2006/40/EC). The EU MAC Directive requires that, as of January 1, 2013,16 all new 

model type vehicles be sold with an MVAC refrigerant with a GWP no greater than 150; beginning January 1, 

2017 this requirement will apply to all new vehicle sales. 

4. Climate-Friendly Alternatives 

This section summarizes information on climate-friendly refrigerant alternatives for MVAC that have been found 

acceptable subject to use conditions under EPA’s SNAP program. This section also provides limited information 

on other alternatives under development in the United States and globally.

 16 Originally, the EU MAC Directive requiring MVACs in all newly type-approved vehicles to use a refrigerant with a GWP no greater than 

150 was to be effective in 2011; however, this date was postponed to January 1, 2013.
23

Table 14. Overview of Climate-Friendly Alternatives Approved by SNAP

Alternative SNAP Listing Status Global Use Status

HFC-152a • Acceptable subject to use 

conditions in 2008

• Prototype vehicles have been tested

• Under evaluation in secondary loop systems in 

demonstration project in India

• No known use in light-duty vehicles

HFO-1234yf • Acceptable subject to use 

conditions in 2011

• Used in several light-duty vehicle models in the 

United States, Canada, and Europe

• Market share increasing annually in the United 

States

• Under evaluation in secondary loop systems in 

demonstration project in India

CO2 • Acceptable subject to use 

conditions in 2012

• Used outside the United States in buses

• No known use in light-duty vehicles; under 

evaluation by several European car manufacturers

HFC-152a

While prototype vehicles have been tested with HFC-152a, and there was on-going development as of 2010, no 

automobile manufacturers have adopted this refrigerant to date. According to ICCT (2012), however, at least 

one manufacturer reported that good engineering design could address technical barriers, though cost and 

efficiency would still present challenges to bringing it to the market. According to the same report, other sources 

have indicated that HFC-152a exhibits good cooling performance and cost, especially when incorporating the 

latest technological advancements; still, the system would require significant space in the engine compartment 

which would pose a challenge in many vehicle models today. HFC-152a is currently under evaluation for use in a 

secondary loop system in a demonstration project in India funded by the Climate and Clean Air Coalition. The 

project will focus on evaluating the use of refrigerants in secondary loop systems in climates with long, hot, and 

frequently humid cooling seasons with high fuel prices (Andersen et al. 2015).

HFC-152a exhibits moderate flammability and is characterized as an A2 refrigerant by ASHRAE. Under the 2008 

SNAP listing, EPA established the following conditions for use: (1) Engineering strategies and/or devices shall be 

incorporated into the system such that foreseeable leaks into the passenger compartment do not result in R152a concentrations of 3.7% v/v or above in any part of the free space inside the passenger compartment for 

more than 15 seconds when the car ignition is on, and (2) manufacturers must adhere to all the safety 

requirements listed in the Society of Automotive Engineers (SAE) Standard J639, including unique fittings and a 

flammable refrigerant warning label as well as SAE Standard J2773, “Refrigerant Guidelines for Safety and Risk 

Analysis for Use in Mobile Air Conditioning Systems.”

HFO-1234yf

The number of cars using HFO-1234yf globally is expected to exceed 2 million by the end of 2014 (Automotive 

World 2014). DuPont, a producer of HFO-1234yf, has stated that 7 million vehicles are estimated to be on the 

road by year end 2015 (DuPont 2014). Approximately 60 different light-duty vehicle models designed to use 

HFO-1234yf in the United States and Europe are manufactured by 28 different vehicle brands (Honeywell 2014). 

In the United States, a number of vehicle models are sold with HFO-1234yf or will be within the 2015 model 

year, including the Cadillac XTS, Chevrolet Spark EV, BMW i3 and i8, Chrysler 200, Chrysler 300, Dodge 

Challenger, Dodge Charger, Dodge Dart, Dodge Durango, Jeep Cherokee, Jeep Wrangler, Ram 1500, Fiat 500 and 

500L, Alfa Romeo 4C, Honda Fit EV, Tesla Model S, Range Rover, Range Rover Sport (Crowell 2015; FCA 2015). 
24

In 2014, Honeywell announced a supply agreement with Asahi Glass Company (AGC) Ltd. to increase production 

of HFO-1234yf in mid-2015, and they plan to construct a new production plant in Geismar, Louisiana 

(Automotive World 2014). In 2013, Arkema announced its construction of a new HFO-1234yf production plant, 

which is anticipated to begin production in 2016 (Arkema 2013). HFO-1234yf is currently distributed in 40 

counties, including the EU member states, the United States, Saudi Arabia, Turkey, Israel, and the United Arab 

Emirates (DuPont 2014). 

HFO-1234yf is mildly flammable, and is classified by ASHRAE as an A2L refrigerant. Under the 2011 SNAP 

decision and a March 2012 subsequent rule, EPA established two required use conditions for HFO-1234yf used 

in a newly manufactured MVAC system for passenger cars and light-duty trucks: (1) HFO-1234yf MVAC systems 

must adhere to all of the safety requirements of SAE J639 (adopted 2011), including requirements for a 

flammable refrigerant warning label, high-pressure compressor cutoff switch and pressure relief devices, and 

unique fittings. For connections with refrigerant containers for use in professional servicing, use fittings must be 

consistent with SAE J2844 (revised October 2011). And (2) manufacturers must conduct Failure Mode and Effect 

Analysis (FMEA) as provided in SAE J1739 (adopted 2009). Manufacturers must keep the FMEA on file for at least 

three years from the date of creation. Under its Cooperative Research Program (CRP), SAE International found 

the risk of fire to be “very small compared to the risks of a vehicle fire from all causes and well below risks that 

are commonly viewed as acceptable by the general public.”

Carbon Dioxide

In March 2013, several German car manufacturers announced plans to develop MVACs using CO2 (R-744) 

refrigerant, though light-duty vehicles using CO2 are not in production today (AMN 2013). CO2 is in use in MVAC

systems in buses outside of the United States (EIA 2014). The use of CO2 as a refrigerant in MVAC systems poses 

challenges due to its high operating pressure. The peak pressure of CO2 operating systems is approximately 

2,000 psi compared to 450 psi in HFC-134a systems (EPA & NHTSA 2012). The refrigerant’s energy performance 

has been questioned, with some studies claiming performance to be similar if not better than HFC-134a, and 

others reporting poorer performance at high ambient temperatures (EIA 2012a, CARB 2011, ICCT 2012). 

When EPA listed CO2 as acceptable for use in 2012, the SNAP program established the following conditions of 

use: (1) engineering strategies and/or mitigation devices shall be incorporated such that in the event of 

refrigerant leaks the resulting CO2 concentrations do not exceed the STEL of 30,000 ppm averaged over 15 

minutes in the passenger free space and the ceiling limit of 40,000 ppm in the passenger breathing zone; (2) 

OEMs must keep records of the tests performed for a minimum period of three years demonstrating that CO2

refrigerant levels do not exceed the STEL of 30,000 ppm averaged over 15 minutes in the passenger free space, 

and the ceiling limit of 40,000 ppm in the breathing zone; and (3) the use of CO2 in MVAC systems must adhere 

to the standard conditions identified in SAE Standard J639 (EPA 2012b).

Other Alternatives (Not Currently Listed by SNAP)

Additional alternatives are under development and/or in use outside of the United States; however, these 

alternatives have not, to date, been listed as acceptable by the SNAP program. Many of these are flammable. 

The SNAP program prohibits the use of flammable refrigerants in MVAC unless a particular refrigerant is 

specifically listed as acceptable subject to use conditions. HFC-152a and HFO-1234yf are the only flammable 

refrigerants EPA has listed as acceptable subject to use conditions for use in MVAC systems (Appendix B to 

subpart G of 40 CFR part 82). 
25

A range of unsaturated fluorocarbon blends have recently emerged as potential alternatives for refrigerants 

used in MVAC systems. While the majority of these are still under development, unsaturated fluorocarbons have 

exhibited promising results thus far; the use of blending may offer flexibility in overcoming technical and 

financial barriers. Two blends in particular, AC5 and AC6 (also classified as R-444A and R-445A, respectively) are 

under development. AC5 is a blend of 12% HFC-32, 5% HFC-152a, and 83% HFO-1234ze (by weight); AC6 is a 

blend of 6% CO2, 9% HFC-134a and 85% HFO-1234ze. The GWPs of AC5 and AC6 are 92 and 130, respectively 

(SAE undated). 

AC5 is expected to have similar performance to R-134a and similar flammability characteristics to HFO-1234yf, 

whereas AC6 is expected to have a somewhat higher refrigeration capacity than HFC-134a and reduced 

flammability compared to HFO-1234yf (SAE undated). That said, both AC5 and AC6 have an A2L flammability 

rating under ASHRAE. To date, research has been conducted on the design and manufacture of prototype 

charging equipment using AC6 (PRWeb 2013); however, concerns exist with the servicing and recovery of such 

zeotropic refrigerant blends because the blend composition varies with temperature and pressure during the 

refrigeration cycle (SAE 2013). Additional concerns include selective leakage of the CO2 component of AC6 due 

to its high pressure. A leakage model from SAE’s Cooperative Research Program shows there would be just a 5%

performance loss if the CO2 level dropped from 6% to 2% (SAE 2013). 

The potential for use of hydrocarbons in MVAC systems is still being researched, and there is not yet agreement 

on its suitability. According to TEAP (2013), due to safety (flammability) concerns, use of hydrocarbons for 

MVACs in light-duty vehicles and trucks is not anticipated to receive support from any car company and would 

remain marginal. Hydrocarbons have the highest flammability rating given by ASHRAE, A3. Some sources report 

that certain hydrocarbon refrigerants could have benefits due to their relatively low charge size (e.g., 200-300 

g), higher cooling performance, and higher coefficient of performance (COP) than HFC-134a and HFO-1234yf 

(Obrist Engineering 2011; Greenpeace 2012). According to Expert Group (2013), a consulting firm in Australia, 

hydrocarbons are currently used in about 8% of MVAC systems in passenger and light commercial vehicles in 

Australia. As previously mentioned, the SNAP program has listed all flammable refrigerants as unacceptable for 

use in MVAC systems, unless specifically exempted. To date, EPA has not yet received sufficient information on 

any hydrocarbon refrigerant to find their use acceptable in MVAC.
26

The U.S. Commercial Refrigeration Industry

1. Introduction

Commercial refrigeration systems historically relied on synthetic ODS refrigerants—CFCs and HCFCs—both of 

which deplete the stratospheric ozone layer and contribute to climate change. The U.S. commercial refrigeration 

market transitioned away from ODS in response to the 1996 phaseout of CFCs and the on-going phaseout of 

HCFCs. The transition was primarily to HFCs, which are not ODS but typically have high GWPs. Today, lower-GWP 

alternatives, discussed below, have entered or are expected to enter the U.S. market, facilitated by acceptability 

listings under EPA’s SNAP program. 

The remainder of this chapter characterizes the portions of the U.S. commercial refrigeration sector affected by 

this final rule in terms of equipment types and manufacturers, market size, historical and current refrigerant 

use, and the availability of climate-friendly alternative refrigerants. 

2. Market Characterization

It is estimated that in 2013 over 6 million commercial refrigeration systems17 were in use in the United States. In 

addition, it is estimated that roughly 600,000 new systems were sold into the market (DOE 2009). Since the 

purpose of this document is to characterize refrigerant use in commercial refrigeration applications affected by 

this rulemaking, only systems and/or components that directly contain refrigerant are discussed, and only the 

manufacturers of such equipment are identified.18 Also, only end-users of systems that are most likely to be 

retrofitted with a different refrigerant at some point during the lifetime of the equipment are included.

19

Overview of Commercial Refrigeration Systems

Commercial refrigeration systems include reach-in refrigerators and freezers, beverage coolers, food service 

equipment, packaged walk-in food storage equipment, refrigerated vending machines, ice makers, water 

coolers, soda fountains/beer dispensers, remote condensing units, and supermarket (i.e., rack) systems, and an 

overview of each of these systems is provided in the sections that follow. Because ice makers, very low 

temperature refrigerators and freezers, water coolers, and soda fountains/beer dispensers are not affected by 

this rulemaking, they are not characterized in this document.

Commercial refrigeration systems generally can be categorized into two groups: stand-alone (i.e., selfcontained)20 and remote refrigeration systems. Self-contained systems integrate all components within their 

structure, while remote refrigeration systems consist of various components that are linked through a 

refrigerant piping network, such as supermarket rack systems and remote condensing units.

 17 Excludes ice machines and refrigerated vending machines.

18 Manufacturers of display cases and walk-ins that are connected to a rack system are excluded from this discussion since the choice of 

the refrigerant used in such equipment is determined by the rack system owner or operator.

19 Systems that are more likely to be retrofitted include remote condensing unit systems and rack systems.

20 The terms stand-alone and self-contained are used interchangeably in this document.
27

2.1.1. Reach-In Refrigerators/Freezers and Beverage Coolers

Reach-in refrigerators and freezers and beverage coolers are self-contained systems with the refrigeration 

system located within the unit. These systems are commonly used in convenience stores, small markets, 

specialty stores, bars, and restaurants as well as in large supermarkets in spaces that are not easily accessible to 

the rack system refrigerant lines or when movability of the system is desired. These systems are often 

characterized by their operating temperature (e.g., medium vs. low), door type (e.g., transparent, solid, 

without), and orientation (e.g., horizontal, semivertical, vertical). Example images of these systems are provided 

in Figure 3 below.

Figure 3. Example Images of Reach-In and Beverage Coolers (DOE 2009)

2.1.2. Food Service Equipment

Refrigerated food service equipment is a type of self-contained system used to maintain the temperature of 

food products prior to and while serving them in foodservice settings (DOE 2009). Such equipment is 

predominantly found in restaurants, hotels, convenience stores, supermarkets, schools, and other facilities 

where food is served. Common categories of equipment include preparation tables, worktop tables, and buffet 

tables. Example images of food service equipment are provided in Figure 4.

Figure 4. Example Images of Food Service Equipment (DOE 2009)

2.1.3. Packaged Walk-In Food Storage Equipment

Walk-in food storage equipment (i.e., packaged walk-in refrigerators and freezers) are another type of selfcontained unit that is commonly used in convenience stores, cafeterias, florists, restaurants, and bars. Larger in 

both size and capacity than reach-in coolers, such units are generally located outside of the sales area and only 

accessible to equipment owners and store employees via an access door. These units generally consist of a large, 

heavily insulated box with a dedicated refrigeration system that is mounted either on the roof or wall of the 
28

insulated room and is configured such that the condenser has access to the outside of the room and the 

evaporator has access to the inside of the room (DOE 2009). These units are classified as self-contained (standalone) because they are pre-charged, shipped as a single package, and are ready to operate upon connection to 

a power supply. In 2008 there were approximately 755,000 walk-in coolers and freezers in use in the United 

States, including both packaged units and built-up systems that use a remote condensing unit (as discussed in 

Section 2.1.5) (DOE 2009). Example images of packaged walk-in coolers and freezers are provided in Figure 5.

Figure 5. Example Images of a Packaged Walk-in with a Mounted Refrigeration System (DOE 2009)

 

2.1.4. Refrigerated Vending Machines

Refrigerated vending machines are another type of self-contained system used to sell a variety of products,

including cold drinks in cans or bottles, ice cream, milk, cold drinks in cups, and perishable food items (e.g., 

prepared sandwiches). Hot beverages may also be provided via a heat-pump or through recycled waste heat 

from the refrigeration cycle, particularly for dual hot/cold beverage vending machines (Fuji Electric 2003; CocaCola 2015). Vending machines are predominantly located in offices, numerous types of public locations, and 

plants and factories (DOE 2009). In 2008 there were approximately 3.8 million vending machines in use in the 

United States (DOE 2009). Example images of refrigerated vending machines are shown in Figure 6 below. 

Figure 6. Example Images of Refrigerated Vending Machines (DOE 2009; AMS 2015)

 

2.1.5. Remote Condensing Units

Remote condensing units are a type of remote commercial refrigeration system that are commonly used in 

convenience stores, drug stores, hotels, cafeterias, specialty food stores, restaurants, and bars to cool a walk-in 

or row of reach-ins. They may also be used in supermarkets to cool walk-ins that are not otherwise connected to 

the rack system. They consist of one or two compressors and a condenser assembled into a modular system, 

which is then connected to a unit cooler located inside a walk-in or to a row of reach-ins. In most cases, the 

remote condensing unit is located on the building rooftop or outside at ground level (DOE 2009). While similar in 

size and function to packaged (i.e., self-contained) walk-in food storage equipment (see Section 2.1.3 above), 
29

remote condensing units are assembled and charged on-site before going into operation. In 2008 there were 

approximately 755,000 walk-in coolers and freezers in use in the United States, including both packaged units 

(as discussed in Section 2.1.3) and built-up systems that are cooled by a remote condensing unit (DOE 2009).

Example images of remote condensing units are provided below in Figure 7. An example image of a unit cooler 

that might be placed inside a walk-in room is provided in Figure 8.

Figure 7. Example Image of an Outside Remote Condensing Unit (DOE 2009; Master-Bilt 2014)

Figure 8. Example Image of a Typical Walk-In Unit Cooler (DOE 2009)

2.1.6. Supermarket Rack Systems

Supermarket (i.e., rack) systems are a type of remote commercial refrigeration systems that are most commonly 

used in large retail food operations (hence the name “supermarket systems”) including warehouse clubs and 

superstores. They are custom designed and complex to install, and consist of racks of multiple compressors and 

other components that are connected to a remote condenser and linked to display cases, reach-ins, and walk-ins 

through a piping network. They come in a variety of designs including centralized, distributed, indirect, and 

cascade.21 These systems can also be designed to additionally provide air conditioning, for example, in offices 

and break rooms located in a supermarket. About 37,500 supermarkets in the United States in 2013 (FMI 2014) 

plus an additional 11,000 supercenters, warehouses, and other retail food stores are assumed to use one or 

more rack systems to meet their cooling needs (EPA Vintaging Model 2014). The key components of a rack 

system—which include compressor racks, condensers, display cases, and walk-ins—are discussed in more detail 

below.

Condensers

Typically located outside, the condenser is a part of the refrigeration system that transfers heat from the 

refrigerant to the surrounding air or a water supply. Air-cooled condensers are more commonly used in 

supermarket rack systems, although water-cooled condensers and evaporative condensers may also be applied. 

 21 See http://www2.epa.gov/greenchill/advanced-refrigeration for descriptions of commonly used system designs.
30

According to the DOE (2009), a typical supermarket has one condenser per refrigeration circuit, or four 

condensers per supermarket. An example of an air-cooled condenser is shown below in Figure 9.

Figure 9: Example Image of a Condenser (Heatcraft 2013)

Compressor Racks

Compressor racks are configurations of paralleled-connected compressors commonly located in a machinery 

room. It is estimated that supermarkets use on average four compressor racks with three to five compressors 

per rack (DOE 2009). Example images of compressor racks are provided below in Figure 10.

Figure 10: Example Images of a Compressor Rack (DOE 2009; Hillphoenix 2013)

 

Display Cases

Display cases that are part of a rack system are used in supermarkets and other retail food establishments to 

attractively display food or beverages to consumers. Similar to reach-in refrigerators and freezers, display cases 

vary by temperature and orientation. Example images of display cases are provided below in Figure 11.

Figure 11. Example Images of Display Cases (DOE 2009)

Walk-In Coolers and Freezers

Walk-in coolers and freezers are large, insulated refrigerated spaces with access doors large enough for people 

to enter. Walk-ins are used for food storage and merchandising in the food service and food sales applications. 

While some walk-ins are cooled by a remote condensing unit, either mounted on the unit or located outside (as 
31

discussed in sections 2.1.3 and 2.1.5, respectively), walk-ins that are found in supermarkets are generally 

connected to and cooled by the rack system. A report developed for the DOE (2009) estimates that in 2008 

there were 245,000 walk-in coolers and freezers in use in the United States that are cooled by a supermarket 

rack system. With annual sales estimated at 10,000 and accounting for systems reaching end-of-life, it is 

estimated that in 2013 there were 250,000 systems in use. An example image of merchandising doors open to 

the sales floor that would be placed on one side of the walk-in room, is provided in Figure 12. An example image 

of a unit cooler that might be placed inside a walk-in room is provided above in Figure 8.

Figure 12. Example Image of a Walk-In with Merchandising Doors (DOE 2009)

Equipment Manufacturers

Leading manufacturers of self-contained systems and remote refrigeration systems are summarized in Table 15

below.22 Since remote systems are installed on-site and are made up of numerous components that are often 

manufactured separately, the manufacturers of remote systems that are specified in the table may actually only 

manufacturer one or more component of such systems. In contrast, since self-contained systems are preassembled, only manufacturers that sell fully assembled self-contained systems are specified in the table; 

companies that manufacture only components of self-contained systems are not included.

Manufacturers were identified based mainly on information gathered by DOE (2013a; 2013b; 2009) and 

comments received on the NPRM. Since a different set of companies manufacture vending machines than other 

self-contained systems, vending machine manufacturers are designated separately in Table 15.

Table 15: Manufacturers of Commercial Refrigeration Systems by Type 

Company Namea

Self-Contained Systems

Remote 

Systemsb Reach-Ins, Beverage Coolers, Food 

Service Equipment, Packaged WalkIn Food Storage Equipment

Vending 

Machines

Aladdin Temp-Rite X

Arctic Air X

Arctic Star X

Arneg USA X

Automated Merchandising Systems, Inc. X

Bally Refrigerated Boxes X

Beverage-Air X

 
32

Company Namea

Self-Contained Systems

Remote 

Systemsb Reach-Ins, Beverage Coolers, Food 

Service Equipment, Packaged WalkIn Food Storage Equipment

Vending 

Machines

Bitzer X

Carlyle X

Century Refrigeration X

Continental Refrigerator X

Copeland X

Crown Tonka X

Cubigel X

Danfoss X

Delfield X

Dixie-Narco X

Duke Manufacturing X

Edina Technical Products X

Federal Industries X

Heat Transfer Products Group DBA Russell X

Hillphoenix X X

Howard/McCray X

Howe Corporation X

Hoshizaki America X X

Hussmann X X

InterMetro Industries X

KeepRite X

Kelvinator X

Killion Industries X

Kolpak X

Krack X

Kysor/Warren X

McCall Refrigeration X

Master-Bilt Products X X

Multi-Max Vending X

Northland Refrigeration X

Parker-Hannifan X

Peerless of America, Inc. X

Randell X

RPI Industries, Inc. X

Royal Vendors X

SandenVendo America X X

Sanyo X

Scotsman X

Seaga Manufacturing X X

Secop X

Silver King X 

So-Low X
33

Company Namea

Self-Contained Systems

Remote 

Systemsb Reach-Ins, Beverage Coolers, Food 

Service Equipment, Packaged WalkIn Food Storage Equipment

Vending 

Machines

Southern Case Arts X

Structural Concepts Corp. X

Sub-Zero X

Tecumseh X

Thermal-Rite/International Cold Storage X X

Tor Rey Refrigeration X

Traulsen X

Trenton Refrigeration Products X

True Manufacturing X

Turbo Air X

Unilever X

Victory Refrigeration X

Wittern Group X

Zero Zone X X

a The companies listed do not necessarily represent an inclusive list of all manufacturers of commercial refrigeration systems in the 

United States. Parent companies are not listed due to frequent consolidations and other acquisitions. b Includes manufacturers of components of remote systems, such as compressors, compressor racks, condensers and condensing units.

Sources: DOE (2013a); DOE (2013b); DOE (2009); comments on NPRM available at regulations.gov in docket EPA-HQ-OAR-2014-0198

Equipment Owners Performing System Retrofits

As previously mentioned, some commercial refrigeration systems—including remote condensing unit systems 

and rack systems—have the potential to be retrofitted with a different refrigerant mid-way through their

lifetime. The decision to retrofit a system is generally made by the owner or operator of the equipment.

Refrigerant retrofits do not typically take place unless at least one component of the system (e.g., a remote 

display case or condenser) needs to be replaced or upgraded. Due to the cost of retrofitting relative to 

purchasing a new self-contained system or vending machine, it is assumed that retrofits are not performed on 

those systems. While remote condensing unit systems are more likely to be retrofitted, they are only commonly 

retrofitted if there is an economic incentive to do so. Similarly, supermarkets are most likely to retrofit their rack 

systems if there is a financial benefit for doing so. Such retrofits are common today as the industry phases out 

HCFCs, particularly HCFC-22. Recovered HCFC-22 from retrofitted or retired systems is commonly used by 

supermarkets to service their other HCFC-22 equipment. As the availability of HCFC-22 decreases, the incentive 

to retrofit or replace HCFC-22 systems will increase for some companies. However, the actual impact of future 

HCFC-22 supplies on retrofit activity is uncertain due to variation in the refrigerant use profiles and specific 

circumstances of individual companies. 

3. Sector Background

Refrigerant Use in Commercial Refrigeration

Commercial refrigeration systems have historically relied on synthetic refrigerants including CFCs, HCFCs, HFCs, 

and blends of these chemicals sometimes mixed with small portions of hydrocarbons. Today, although less 

common, non-fluorinated alternatives are additionally in use in the commercial refrigeration sector (e.g., 
34

ammonia, carbon dioxide, and hydrocarbons). Unsaturated HFCs (i.e., HFOs as well as HFOs blended with other 

refrigerants) are also being tested and are expected to enter the market soon. 

A summary of the commonly used, non-ODS refrigerants listed as acceptable under SNAP for commercial 

refrigeration systems characterized in this document is provided below in Table 16, presented in order from 

largest to smallest GWP. Some refrigerants are generally used only in new equipment (denoted by “N” in the 

table), while other refrigerants are generally used only as a retrofit refrigerant (i.e., a refrigerant used to replace 

a different refrigerant in existing equipment) (denoted by “R” in the table). As shown, some refrigerants are 

used in both new equipment and as a retrofit in existing equipment.

Table 16: Non-ODS Refrigerants Commonly Used in Commercial Refrigeration by Equipment Type

Refrigerant GWP*

Equipment Category**

Stand-Alone Remote 

Condensing Units

Supermarket Rack 

Systems

R-507A 3,985 N N N, R

R-404A 3,922 N N N, R

R-422A 3,143 R R

R-422D 2,729 R R

R-422B 2,526 R R

R-438A 2,264 R R

R-427A 2,138 R R

R-407A 2,107 N, R N, R

R-407F 1,825 N, R N, R

R-407C 1,774 N, R N, R

HFC-134a 1,430 N N N

R-290 3.3 N

R-744 1 N N N

*GWPs from IPCC (2007)

** R = used as a retrofit; N = used in new equipment. These designations are based on common use, not SNAP listing status.

Source: Based on RTOC (2011) and GreenChill Partnership Data (2013).

Although there are significantly fewer remote refrigeration systems (i.e., condensing units and rack systems) in 

the market relative to self-contained systems, the majority of refrigerant consumed in the United States in 

commercial refrigeration is used to charge or refill remote refrigeration systems.

3.1.1. Stand-Alone Systems

As previously discussed, the types of stand-alone (self-contained) systems characterized in this report include 

reach-in refrigerators and freezers, beverage coolers, food service equipment, packaged walk-in food storage 

equipment, and refrigerated vending machines. These systems historically used refrigerants CFC-12 and HCFC22. Today, HFC-134a is the most commonly used refrigerant in self-contained systems, with R-404A also 

commonly used in low temperature applications (e.g., freezers, ice machines) and some high-capacity systems. 

Propane (R-290) and to a lesser extent isobutane (R-600a) have recently started to be used in retail food selfcontained refrigerators and freezers (e.g., reach-in refrigerators and freezers, and beverage coolers), following 

listing by SNAP as being acceptable subject to use conditions in December 2011 and April 2015. R-744 (carbon 

dioxide, CO2), which was listed as acceptable under SNAP for use in retail food refrigeration in September 2009, 

is currently used in beverage coolers. More recently, R-744 has started to be used in vending machines, 
35

following SNAP listing in 2012. A summary of the ODS substitute refrigerants commonly used today in selfcontained systems, along with their corresponding estimated charge size, is provided below in Table 17.

Table 17: Non-ODS Refrigerants Typically Used in Self-Contained Systems by System Type

System Type Refrigerants Typical Charge Size Range 

(kg)a

Reach-In Refrigerators and Freezers HFC-134a, R-404A, R-290 0.2 – 3.0

Beverage Coolers HFC-134a, R-290, R-744 0.2 – 3.0

Food Service Equipment HFC-134a, R-404A, R-290 0.2 – 3.0

Packaged Walk-In Food Storage Equipment R-404A 0.8 – 1.3

Vending Machines HFC-134a, R-404A, R-744 0.2 – 3.0

a Charge size is influenced by both the system capacity and the refrigerant type. 

Source: RTOC (2011); EPA (2010d); Heatcraft (2004).

Due to their small charge size, the amount of refrigerant used to fill new self-contained equipment represents a 

small portion of total refrigerant consumed by the commercial refrigeration sector.

Although HFCs continue to dominate the market, this trend is starting to change for equipment types that may 

now use R-290 (e.g., reach-in refrigerators and freezers, beverage coolers, and food service equipment) and R744 (e.g., beverage coolers and vending machines). For example, Unilever and Ben & Jerry’s installed R-290 ice 

cream freezers (i.e., reach-in freezers) in 21 stores in the United States in 2009 and announced plans to install 

700 more units in 2012. As of 2012, PepsiCo had also installed 35 R-290 beverage coolers across North America.

Additionally, many supermarket chains, including Fresh & Easy and H-E-B, have deployed self-contained R-290 

units. Coca-Cola has committed to installing only HFC-free equipment beginning in 2015 and as of 2014 had 

already installed over one million HFC-free units globally (including beverage coolers and vending machines)—

the majority of which use R-744. 

3.1.2. Remote Refrigeration Systems

As previously discussed, remote commercial refrigeration systems can be categorized into remote condensing 

unit systems and supermarket rack systems. Similar to self-contained systems, remote refrigeration systems 

historically used CFC-12, HCFC-22, and some ODS blends (e.g., R-502, R-401A, R-402A, and R-408A). Today, new 

remote systems largely rely on HFCs although both HFCs and many ODS refrigerants still remain in use in existing 

equipment. Ammonia (R-717) and carbon dioxide (R-744), both of which are acceptable under SNAP for use in 

large retail food equipment, are also used and gaining market share. A summary of non-ODS refrigerants 

currently used in remote condensing unit and supermarket rack systems is provided below in Table 18. A more 

detailed description of refrigerant use by system type is provided in the sections that follow.

Table 18: Non-ODS Substitute Refrigerants Used in Remote Refrigeration Systems by System Type

System Type Refrigerants in Use Typical Charge Size Range 

(kg) a

Remote Condensing Unit 

Systems

HFC-134a, R-404A, R-407A, R-407C, R-407F, R-422A, R422B, R-422D, R-427A, R-438A, R-507A 0.5 – 20

Supermarket Rack Systems HFC-134a, R-404A, R-407A, R-407C, R-407F, R-422A, R422B, R-422D, R-427A, R-438A, R-507A, R-717, R-744 300 – 1,800

a Charge size is influenced by the system capacity, system design, and the refrigerant type. 

Sources: RTOC (2011); EPA (2010d); GreenChill Partnership Data (2013).
36

Remote Condensing Units

Remote condensing units historically used HCFC-22. While many HCFC-22 systems still remain in use today, 

newly manufactured systems primarily use R-404A or HFC-134a. Other HFC blends—including R-407A, R-407C, 

R-407F, and R-507A—are also available. Remote condensing units may be retrofitted but retrofits are generally 

only done if the system is experiencing high leakage and the cost of replacing the leaked refrigerant is high. In 

such cases, an R-407 series or R-422 series refrigerant is most commonly used, although other retrofit 

refrigerants (e.g., R-427A, R-438A) are also available.

Supermarket Rack Systems

Supermarket rack systems historically used CFC-12, R-502, HCFC-22, and other HCFC blends in a centralized 

design. While many of these systems remain in use today, some have been retrofitted to replace the ODS 

refrigerant with an HFC blend (e.g., R-404A, R-422A, R-422B, R-422D, R-427A, R-438A, R-507A). For newly 

manufactured systems, HFC refrigerants (e.g., R-404A, R-507A, R-407A, R-407C, R-407F) dominate the market.

Many of the newly manufactured systems additionally employ alternative designs such as secondary loop 

systems, which use secondary fluids, such as R-744 or glycol to indirectly cool the refrigerated space, allowing 

for a relatively low HFC charge size. Another alternative design is a cascade system, which consists of two 

independent rack systems that share a common cascade heat exchanger which allows for the use of R-744 on 

the low temperature side. While an HFC is most commonly used as the refrigerant on the high temperature side, 

it is also feasible to use other refrigerants, e.g. R-717, on the high temperature side, thereby eliminating the use 

of the HFC.

In 2012, the first R-717/R-744 cascade system was installed in the United States in an Albertsons supermarket in 

Carpinteria, California. This milestone was followed in 2013 by the installation of the first 100% CO2 (R-744)-

based rack system in a Hannaford supermarket in Turner, Maine. This system is a transcritical CO2 system, in 

which CO2 is used as the primary refrigerant and operates at a high pressure to accommodate the low critical 

temperature of CO2. Additional transcritical CO2 systems have been installed in a Walgreens store in South 

Evanston, Illinois; a Whole Foods Market in Brooklyn, New York; a Whole Foods Market in Berkeley, California; a 

Whole Foods Market in San Jose, California; a Kroger in Holland, Ohio; a Sprouts store in Dunwoody, Georgia; 

and a Pick ‘n Save supermarket in Menomonee Falls, Wisconsin. Installation of new supermarket rack systems 

that use R-744 and possibly R-717 as the primary refrigerant are expected to continue to grow in the United 

States. For example, the Lackland Air Force Base Commissary in San Antonio, Texas is currently in the process of 

replacing its old refrigeration system with an R-717/R-744 cascade system. This system is expected to go into 

operation in the summer of 2015.

4. Climate-Friendly Alternatives

Although not a significant portion of the market today, a variety of climate-friendly refrigerant alternatives (e.g., 

hydrocarbons, CO2, ammonia, and HFOs (often blended with HFCs)) are available for use or expected to be 

available for use in the near-term in each of the commercial refrigeration system types described in this 

document. Table 19 below summarizes the status of lower-GWP alternatives in the United States by system 

type.
37

Table 19: Overview of Status of Climate-Friendly Alternatives by System Type

System Type Hydrocarbons CO2 Ammonia HFOs and HFC/HFO 

Blends

Stand-Alone (i.e., 

Self-Contained)

Units: Reach-In 

Refrigerators and 

Freezers, Beverage 

Coolers, Food 

Service Equipment, 

and Packaged 

Walk-In Food 

Storage Equipment

• Acceptable under 

SNAP subject to 

use conditions

(2011; 2015)

• Gaining market 

share in the United 

States

• Commonly used 

outside the United 

States

• Acceptable under 

SNAP (2009)

• Used in glass-door 

beverage coolers

• Acceptable under 

SNAP (1996) with a 

secondary loop; no 

known use

• R-450A acceptable 

under SNAP (2014)

• R-513A acceptable 

under SNAP 

(2015)

• R-448A acceptable 

under SNAP for lowtemperature 

equipment

(2015)

• R-449A acceptable 

under SNAP for lowtemperature 

equipment

(2015) 

Vending Machines • Acceptable under 

SNAP (2015)

• Used outside the 

United States; 

limited testing in 

the United States

• Acceptable under 

SNAP (2012)

• Gaining market 

share in the United 

States

• Not acceptable under 

SNAP; no known use

• R-450A acceptable 

under SNAP as 

retrofit (2014) and 

for new equipment 

(2015)

• R-513A acceptable 

under SNAP

(2015)

Remote Condensing 

Units

• Not acceptable 

under SNAP; no 

known use

• Acceptable under 

SNAP (2009)

• Used outside the 

United States

• Acceptable under 

SNAP (1996) with a 

secondary loop

• Used historically in 

industrial applications 

but not currently 

used commercially

• R-450A acceptable 

under SNAP (2014)

• R-513A acceptable 

under SNAP

(2015)

• R-448A acceptable 

under SNAP

(2015)

• R-449A acceptable 

under SNAP

(2015)
38

System Type Hydrocarbons CO2 Ammonia HFOs and HFC/HFO 

Blends

Supermarket Rack 

Systems

• Not acceptable 

under SNAP: no 

known use

• Acceptable under 

SNAP (2009)

• First 100% CO2

system installed in 

the United States in 

2013 

• Commonly used 

outside the United 

States

• Also used in 

secondary loop 

systems or cascade 

designs in the 

United States

• Acceptable under 

SNAP (1996) with a 

secondary loop

• First system installed 

in the United States

in 2012

• R-450A acceptable 

under SNAP (2014)

• R-450A in use in a 

supermarket in 

Spain

• R-513A acceptable 

under SNAP

(2015)

• R-448A acceptable 

under SNAP

(2015)

• R-449A acceptable 

under SNAP

(2015)
39

The U.S. Foams Industry

1. Introduction

Foams are plastics (such as polyurethane or polystyrene) that are manufactured using blowing agents to create 

bubbles or cells in the material's structure. The foam plastics manufacturing industries, the markets they serve, 

and the blowing agents used are extremely varied. Foams are used as insulation in a range of equipment and 

products, including refrigerated appliances (e.g., household refrigerators and freezers, laboratory and medical 

equipment, commercial refrigeration equipment), refrigerated trucks (“reefers”) and other refrigerated 

transport systems, buildings (e.g., walls, roofs, floors), and pipes. Foams are also used to provide buoyancy (e.g., 

flotation devices, boat frames), and as cushioning in products, (e.g., steering wheels, furniture, shoes). 

Historically, a variety of CFCs and HCFCs have been used as foam blowing agents because of their favorable 

chemical properties. Used in the production of foam, certain blowing agents may lead to environmental damage 

when released to the atmosphere at the time of foam manufacture, during product use, and/or at product 

disposal. In particular, CFC and HCFC blowing agents deplete the ozone and have very high GWPs. HFCs, which 

have more recently been adopted in the U.S. market to replace CFCs and HCFCs, also have high GWPs but do not 

damage the ozone layer. Other blowing agents that are both ozone- and climate-friendly have also been used 

and are increasingly being adopted.

The remainder of this chapter characterizes the U.S. foams sector in terms of market size and companies, 

historical and current blowing agent use, and the availability of climate-friendly alternatives. 

2. Market Characterization

This section provides an overview of foam types and end-uses, and the foams market today. Additional general 

sector information on the market size, sales, and employment is also provided, as available. 

Overview of Foam Types and End-Uses

Foams are characterized as “closed-cell” or “open-cell.” Closed-cell foams have completely enclosed/discrete 

cells which encase the blowing agent used to create the cells during the foam production process; as a result, 

the blowing agent remains intact in the foam product (with only small amounts emitted during the production 

process) and is slowly emitted over the product lifetime and at or after (i.e., post-life emissions) disposal (if not 

properly recovered and destroyed). Conversely, in open-cell foams, each cell is connected to another cell and is 

not completely enclosed; thus, most or all blowing agent is emitted during the manufacture/production of the 

foam-containing product. Closed-cell foams are generally used in insulating and buoyancy applications, whereas 

open-cell foams are most often used in cushioning applications.

Foams can also be classified by the primary polymer used in production. Specifically, there are four foam types 

that have traditionally relied upon ODS, as described below. 

• Polystyrene foam is the largest foam market in the United States, based on revenue. This foam type is 

estimated to represent approximately 52% of the revenue generated from all foam manufacture.23 In 

 23 Based on the 2012 data presented in IBIS (2012a) and IBIS (2012b). See details in Section 2.2.2.
40

terms of quantity of foam generated, however, polystyrene is second to polyurethane, and represents 

approximately 30% of all foam (BCC Research 2010). Polystyrene foam is categorized as either “extruded” 

or “expanded,” based on how it is manufactured. Extruded polystyrene (XPS) foam is manufactured by an 

extrusion process at elevated temperatures, which offers improved thermal properties. XPS includes 

boardstock (or ‘board’), billet, and sheet foam; board and billet foam is often manufactured for 

construction applications, although XPS billet is also manufactured for buoyancy and insulating pipe 

applications. Sheet foam is typically manufactured for packaging purposes with thermal requirements. 

Expanded polystyrene is blown from beads of polystyrene which contain a blowing agent (typically a 

hydrocarbon such as pentane for extruded sheet foam, and a hydrocarbon or a hydrofluorocarbon for 

extruded boardstock). The beads are blown into hot moulds to create blocks and moulded shapes, 

typically for packaging applications. 

• Polyurethane generates less revenue than polystyrene foam but represents 52% of the total quantity of 

foam generated by weight (BCC Research 2010). The technology was developed in the early 1930s and 

has since been the predominant foam type due to its versatility. Polyurethane foams can be formulated 

to achieve a range of properties (e.g., density, resilience) for different applications; it can be flexible or 

rigid. Rigid polyurethane foam is most often used in insulating applications, which represents the most 

significant use of this foam type. Rigid polyurethane spray foam used in construction insulation 

applications can be further characterized into three distinct categories: (1) high-pressure two component 

foam, (2) low-pressure two-component foam, and (3) one component foam (OCF). Flexible foams are 

most often used in non-insulating applications, specifically in the furniture industry and the automotive 

industry. Polyisocyanurate is chemically similar to polyurethane and is used in some of the same rigid 

thermal applications, and thus is often grouped with polyurethane foam. While it is less resilient than 

polyurethane, polyisocyanurate does offer improved fire performance and greater rigidity. 

• Polyolefin foam represents less than 10% of the foam manufactured in the United States by weight (BCC 

Research 2010). Polyolefin foam is a polymer produced from a simple olefin. The two most common 

polyolefin foams are polyethylene and polypropylene, taken from the name of the olefin used to produce 

them: ethylene or propylene. Polyolefin foams have similar properties to XPS foam and are generally 

used in similar applications. This foam type, however, offers additional resilience which often makes it 

the foam type of choice in packaging applications. 

• Phenolic foam accounts for less than 10% of all foam manufactured in the United States by weight (BCC 

Research 2010). This type of foam is very rigid, typically more so than polyurethane or polyisocyanurate.

This foam type includes insulation board and bunstock, or ‘blocks.’ The rigidity characteristic of phenolic 

foams has historically made them unacceptable where vibration or thermal shock is a consideration. 

However, more recent developments have led to improved resilience, fire performance, as well as the 

best thermal performance of all foam types. This foam type is commonly used in insulating applications, 

specifically pipe sections, walls, roofs, and cold stores.

Table 20 summarizes the foam types and common application.
41

Table 20: Foam Types and Applications

Foam Type Product Type

Open 

or 

Closed 

Cell

Insulating Applications Non-insulating Applications

Domestic AppliancesCommercial Appliances

Pipe SectionWall and Door/ Window FramesFloorRoof

TransportationCold StoresTransportationFurniturePackagingBuoyancyShoe Soles

Polyurethane Boardstock (includes 

polyisocyanurate) 

(rigid)

closed √ √ √

Appliance(rigid) closed √ √

Spray (rigid) closed √ √ √ √ √ √

Slabstock (rigid) closed √ √ √ √ √ √ √

Continuous and 

Discontinuous Block 

(rigid)

closed √ √a √ √ √b √a

Injected / Pipe-inPipe (rigid) closed √

Continuous and 

Discontinuous 

Sandwich Panel 

(rigid)

closed √ √ √ √

One Component 

Foam (OCF) open √

Slabstock and 

Moulded (flexible) open √c √ √ √ √

Integral Skin 

(flexible) open √ √ √ √

Polystyrene Extruded Sheet closed √

Extruded Boardstock 

and Billet

closed √ √ √ √ √ √ √

Expanded closed √ √ √ √

Phenolic Boardstock closed √ √

Panel closed √ √ √

Disk Block closed √ √

Polyolefin 

(polyethylene, 

polypropylene)

Board closed √ √

Pipe closed √

Source: UNEP (2010a), Jeffs (2013).

a For continuous blocks only.

b For discontinuous blocks only. 

c Acoustic insulation.
42

Foam Market 

For the purposes of this characterization, the foams market supply chain is divided into two separate groups: 

suppliers and systems houses. Suppliers produce the chemicals used in the manufacture of foams, which 

includes blowing agents and polyols,24 while systems houses manufacture the foam. Large systems houses may 

purchase these chemicals from suppliers and then formulate their own blend of polyol and blowing agent 

and/or use additives, such as fire retardants, catalysts, and surfactants to produce foam that meets their 

product specifications. In contrast, small systems houses may purchase pre-blended or “fully formulated” 

polyols from suppliers to produce foam in favor of simpler operating conditions. Spray foam, on the other hand, 

is created on a jobsite by combining equal volumes of two chemicals, commonly referred to as A-side and Bside. A-side is the isocyanate component of the foam while B-side is a mixture of polyols, fire retardants, 

blowing agents, catalysts, and other additives. These two chemicals react and expand at the point of application. 

A-side is manufactured by suppliers, or chemical manufacturing companies, while the B-side formulation is 

developed by systems houses (SPFA 2013). In addition, depending on the application and the market, twocomponent spray foam can be applied either in a high-pressure two-component system using a liquid blowing 

agent and a high-pressure pump, or in a low-pressure two-component system using a gaseous blowing agent 

that provides propulsion in place of a pump.

2.2.1. Blowing Agent and Polyol Suppliers

Companies known to supply blowing agents25 in the United States include: 

• Albemarle • Foam Supplies Inc.

• Arkema • Great Lakes

• Chevron Phillips • Honeywell 

• Dow Chemical • Lambiotte & Cie

• Chemours • Mexichem

• Dyplast Products

• ExxonMobil

• Plenco

• Solvay

Companies known to supply polyols to the foam manufacturing industry include Invista (formerly Kosa), 

Huntsman, and Dow Chemicals (ICF 2003b, UNEP 2010a). 

2.2.2. System Houses

Some of the major system houses for polyurethane, polystyrene, and phenolic foams are summarized in Table 

21 by foam type and market share. Information on major foam system houses in the polyolefin market was not 

readily available. 

 24 A compound containing multiple alcoholic hydroxyl groups.

25 Foam blowing agents can be either chemical or physical blowing agents. The blowing agent suppliers listed here are for physical blowing 

agents. SNAP program listings are for substitutes in types of foam that historically have used CFCs or HCFCs as physical blowing agents.
43

Table 21. Major Foam System Houses

Market Major Foam System Houses (% Market Share in 2012)

Polyurethane Carpenter Co. (25.6%); Johnson Controls Inc. (25%); FXI Foamex Innovations (13.4%); 

Vitafoam Inc. (1.9%)

Polystyrene Reynolds Group Ltd. (26.2%); Dart Container Corporation (18.8%); Solo Cup Company 

(5.9%); The Dow Chemical Company (4.8%)

Phenolic Plenco (Plastics Engineering Company), Dyplast Products, Ashland, Borden Chemical, H.D. 

Fuller, Georgia Pacific, Resinoir, Sumitomo America, Triquest, and Vantico

Source: IBIS (2012a), IBIS (2012b), and ICF internet research. 

Polyurethane system houses include, but are not necessarily limited to, the following. The types of foam 

produced at these system houses include flexible, rigid and spray, with different systems houses specializing in 

some or all types of polyurethane foam. 26

• Bayer (formerly PSI) • Iso Tech

• BASF

• Carpenter Co.

• Elliot Company

• Foam Supply Inc.

• FXI Foamex Innovations

• Gaco

• General Coatings

• Huntsman

• Hydroseal

• Johnson Control Inc. 

• NCFI

• SWD Urethane

• UCSC

• Utah Foam Products

• Vitafoam Inc.

Source: ICF International (2003), Bayer (Undated), BASF (2010).

Manufacturers of XPS boardstock and billet include:

• BASF

• Dow

• Owens Corning

• Kingspan (formerly Pactiv Building 

Products)

Foam Sector Revenue and Employment

Several market reports were reviewed to assess the foams industry by end-use. According to the data available 

in these market reports, in 2012, the foam market was estimated to gross between $12.0 and $17.3 billion (IBIS 

[2012a, 2012b] and Barnes [2013a, 2013b]). 27 Of this, the polystyrene sector represented more than 50% of the 

industry, based on gross revenue. The same year, the industries for polyurethane and other types of foams 

employed between 25,700 and 27,300 people and grossed between $6.4 and $8.6 billion (IBIS 2012a, Barnes 

2013b); the polystyrene industry employed about 25,000 people and grossed between $5.7 and $8.7 billion (IBIS 

2012b, Barnes 2013a). Notably, these 2012 estimates of the number of employees and businesses are 

significantly lower than those provided for 2007 by the U.S. Census; the reason for this discrepancy is unclear. 

 26 Parallel information on phenolic, polyolefin, and polystyrene (besides XPS boardstock and billet) system houses was not available, although 

it is known that Dow serves as a major system house for polystyrene foams. Companies listed do not necessarily represent an inclusive list of 

all polyurethane system houses in the United States.

27 2012 is the most recent year for which market data is available. This estimate is based on the highest gross revenues cited for each 

foam type across the available reports; the lower bound is estimated at $12.0 billion, based on Barnes (2010) and Barnes (2012).
44

Annual foam production estimates by polymeric foam type (which include PU, polyolefins, polystyrene, and 

other foam types) are illustrated in Figure 13. The data are based on two different reports, BCC Research (2010) 

and ACC (2012) but show consistent estimates for polyurethane production in 2010 at slightly less than four 

billion pounds. 

Figure 13: Polymeric Foam U.S. Market Estimate by Resin Family, 2009-2005 (million pounds)

Source: BCC Research (2010).

Additional market information was available for the polyurethane industry from the American Chemistry 

Council. In 2010, the polyurethane industry directly created 37,700 jobs, paying $2.0 billion in wages to its 

employees, and generated $19.7 billion in revenues. Indirectly, this industry created and supported 164,900 

additional jobs and generated $40.1 billion in output. Overall, the polyurethane industry supports 202,600 jobs 

through various activities including raw materials purchasing, equipment and services. Based on these figures, 

more than four jobs are created upstream or indirectly for each job in the polyurethanes industry, totaling five 

jobs in the economy for each job in polyurethanes (ACC 2012). 

Foam Applications

More detailed information on foam product segmentation/application is shown below. Figure 14 illustrates the 

product segmentation of the polystyrene market as a percentage of the overall revenue, followed by Figure 15, 

which illustrates the product segmentation of polyurethane as well as polyolefin, phenolic, and other foam 

products. In contrast, Table 22 provides segmentation of polyurethane product by product weight. The inclusion 

of other foam types may explain the significant differences in the product/end-use categories, notably furniture 

and transportation, between Figure 14 and Figure 15. 
45

Figure 14: 2012 Polystyrene Product Segmentation*

Source: IBIS (2012b).

*Consumer and institutional products include polystyrene foam cups, plates, bowls and cutlery for household and commercial use.

Figure 15: 2012 Polyurethane and Other Product Segmentation

Source: IBIS (2012a).

Table 22: 2010 Polyurethane Production by Application/Product Type*

Million Pounds % of Total

Building and Construction 1,432 38%

Transportation and Marine 770 20%

Furniture and Bedding 730 19%

Appliances 230 6%

Packaging 172 5%

Footwear 19 1%

Other End-Use** 428 11%

Total 3,781 100%

Source: ACC (2012).

*Includes minor production of non-foam products, such as adhesives and coatings. 

**Includes marine, tank, and pipe uses.
46

3. Sector Background

Most foam types were historically produced in the United States with CFC blowing agent, due to their relative 

abundance and favorable chemical properties. CFC-11 was the predominant blowing agent, followed by CFC-12, 

and CFC-113 in niche applications. One exception to this is expanded polystyrene, which has never used ODS 

blowing agents (ICA 2014). 

Historically, a variety of CFCs and HCFCs have been used as foam blowing agents because of their favorable 

chemical properties. The Nonessential Product Bans in 1993 and 1994 under section 610 prohibited the sale, 

distribution, or offer for sale or distribution of all foam products containing or manufactured with CFCs and 

HCFCs, except insulating foams.28 This ban included open-cell foams, often used for non-insulating purposes, 

because they emit most or all of the blowing agent at the time the foam is blown or within the first year. Flexible 

slabstock and moulded polyurethane foam, which represent the greatest blowing agent use of all flexible foam 

types, transitioned from CFCs to HCs. Integral skin polyurethane foams, however, transitioned briefly to HCFC141b, and then to CO2 and HFC-134a. One component foams (OCF) also transitioned briefly to HCFCs, namely 

HCFC-22 and HCFC-141b, before fully transitioning to HFC-134a, HFC-152a, and HCs.

In the early 1990s many closed-cell foams transitioned largely to HCFCs—particularly HCFC-141b and HCFC142b, and to a lesser extent, HCFC-22. Nearly a decade later, in 2003, the United States phased out production 

and import of HCFC-141b and in November 2004, the use of HCFC-141b was listed as unacceptable under the 

SNAP Program. In addition, EPA proposed an unacceptability determination in November 2005 and issued a final 

unacceptability determination in March 2007, which specified that existing users of HCFC-22 and HCFC-142b

must transition by March 1, 2008, for most uses. EPA provided an additional 18 months for this transition for 

marine flotation foam, allowing its use until September 1, 2009 and EPA allowed until January 1, 2010 for the 

transition for extruded polystyrene boardstock and billet. Following the phaseout of HCFCs, these applications 

transitioned largely to HFCs—primarily HFC-134a, HFC-152a, and HFC-245fa, and more recently HFC-365mfc and 

blends of HFC-227ea and HFC-365mfc. A number of closed cell foam applications also transitioned from CFCs 

directly to non-fluorinated alternatives that are both non-ozone depleting and low-GWP—namely to HCs (cyclopentane and n-pentane) and CO2 (with water). The United States’ transition away from the use of ODS to other 

blowing agents is illustrated in Figure 16.

 28 40 CFR 82.62 defines foam insulation products as those “containing closed cell rigid polyurethane; closed cell rigid polystyrene boardstock 

foam; closed cell rigid phenolic foam; or closed cell rigid polyethylene foam when such foam is suitable in shape, thickness, and design to be 

used as a product that provides thermal insulation around pipes used in heating, plumbing, refrigeration, or industrial process systems.” 
47

Figure 16: United States Blowing Agent Use from 1985 to 2013 (MT)

Source: EPA Vintaging Model 2014.

4. Climate-Friendly Alternatives

A range of climate-friendly alternatives have been found to be acceptable under the SNAP program for use as 

foam blowing agents including hydrocarbons29, carbon dioxide, water, and methyl formate. Other acceptable 

lower-GWP fluorinated compounds in use include HFO-1234ze and trans-1-chloro-3,3,3-trifluoroprop-1-ene 

(Solstice 1233zd(E)). Additional alternatives are also under development, such as HFO-1336mzz(Z) (Formacel1100) and methylal. 

The U.S. foam industry has made significant progress in adopting climate-friendly alternatives. HCs and to a 

lesser extent carbon dioxide, have been almost fully adopted in many foam end-uses. However, there are some 

foam applications, such as spray foam, where transition has been slower due to specific concerns such as safety 

considerations related to the particular application.

Over 65% of the U.S. market today already uses climate-friendly blowing agent alternatives. Additional climatefriendly options are expected to be available in the near-term for end-uses which have thus far encountered 

barriers to transition (e.g., flammability, insulation performance). Table 23 summarizes available information on 

the status of use and SNAP listing of several climate-friendly alternative blowing agents by end-use. Onecomponent foam is not recognized as a distinct end-use under the SNAP program; thus, it is not included 

separately in the table.

 29 Specifically, light saturated hydrocarbons with three to six carbons (C3-C6) including propane, butane, isobutane, n-pentane, cyclopentane, 

isopentane, and hexane and its isomers.
48

Table 23: Overview of Climate-Friendly Alternatives and SNAP Listing Status by Foam Type1

Foam End-use HCs CO2 Water Unsaturated HFCs 

and HCFCs Methylal

Methyl 

Formate/

ecomateTM

Flexible 

Polyurethane: 

Slabstock and 

Moulded 

• SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved 

(1994)

• SNAPapproved

(1999)

• Widely in use

• Solstice 

1233zd(E) SNAPapproved (2014)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000) 

• Under 

industry 

evaluation; 

trials in 

progress

Rigid 

Polyurethane 

and 

Polyisocyanurat: 

Boardstock 

• SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved 

(1994)

• SNAPapproved

(1999)

• Solstice 

1233zd(E) SNAPapproved (2012)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• Under regulatory 

and/or industry 

evaluation; trials 

in progress

• SNAPapproved 

(2014)

• SNAPapproved 

(2000) 

Rigid 

Polyurethane: 

Appliance 

• SNAPapproved 

(1994)

• Widely in use

• SNAPapproved 

(1994)

• SNAPapproved

(1999)

• Solstice 

1233zd(E) SNAPapproved (2012); 

gaining market 

share

• HFO-1234ze 

SNAP- approved 

(2009); no 

known use

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000)

• No known use

Extruded 

Polystyrene: 

Sheet 

• SNAPapproved 

(1994)

• Widely in use

• SNAPapproved 

(1994)

• Some use

• SNAPapproved

(1999)

• NA • NA • SNAPapproved 

(2006)2

Rigid 

Polyurethane: 

Spray 

• NA3 • SNAPapproved 

(1994)

• Some use

• SNAPapproved

(1999)

• Solstice 

1233zd(E) SNAPapproved (2012); 

gaining market 

share

• HFO-1336mzz(Z) 

SNAP-approved 

(2015) 4

• HFO-1234ze 

SNAP- approved 

(2009); no 

known use; 

development 

ongoing for lowpressure 

formulation

• NA • SNAPapproved 

(2006)2
49

Foam End-use HCs CO2 Water Unsaturated HFCs 

and HCFCs Methylal

Methyl 

Formate/

ecomateTM

Polyolefin • SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved 

(1994)

• SNAPapproved

(1999)

• HFO-1234ze 

SNAP- approved 

(2010)

• NA • SNAPapproved 

(2006)2

Extruded 

Polystyrene: 

Boardstock and 

Billet 

• SNAPapproved 

(1994) 

• SNAPapproved 

(1994)

• Some use

• SNAPapproved

(1999)

• HFO-1234ze 

SNAP-approved 

(2009)

• NA • SNAPapproved 

(2006)2

Rigid 

Polyurethane: 

Slabstock and 

Other

• SNAPapproved 

(1994)

• SNAPapproved 

(1994)

• Some use

• SNAPapproved

(1999)

• HFO-1234ze 

SNAP-approved 

(2010)

• Solstice 

1233zd(E) SNAPapproved (2012)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000) 

Rigid 

Polyurethane: 

Commercial 

Refrigeration 

• SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved 

(1994)

• Some use

• SNAPapproved

(1999)

• HFO-1234ze 

SNAP-approved 

(2009)

• Solstice 

1233zd(E) SNAPapproved (2012)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000)

• Some use

Phenolic 

Insulation Board 

and Bunstock

• SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved 

(1994)

• SNAPapproved

(1999)

• HFO-1234ze

SNAP-approved 

(2009)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• NA • SNAPapproved 

(2006)2

Polyurethane: 

Integral Skin

• SNAPapproved 

(1994)

• No known use

• SNAPapproved 

(1994) 

• Widely in use

• SNAPapproved

(1999)

• HFO-1234ze 

SNAP-approved 

(2010)

• Solstice 

1233zd(E) SNAPapproved (2012)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000)

Rigid 

Polyurethane: 

Sandwich Panels 

(Continuous and 

Discontinuous)

• SNAPapproved 

(1994)

• Widely in use

• SNAPapproved 

(1999)

• Some use

• SNAPapproved

(1999)

• Solstice 

1233zd(E) SNAPapproved (2012)

• HFO-1234ze 

SNAP-approved 

(2009)

• HFO-1336mzz(Z) 

SNAP-approved 

(2014)

• SNAPapproved 

(2014)

• SNAPapproved 

(2000)

NA = Not applicable. The SNAP program has not received a submission and/or made a determination for the specified end-use. 1Earliest SNAP listing dates are indicated in this table. 2 Listed as acceptable under the brand name ecomateTM and not listed for methyl formate. 3 Listed as acceptable under the brand name Exxsol blowing agents, and not listed for light saturated C3-C6 hydrocarbons. 4Listed as acceptable for use in high-pressure two-part spray foam only.
50

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