1

Climate Benefits of the SNAP Program 

Status Change Rule

March 2016

U.S. Environmental Protection Agency

Stratospheric Protection Division

Office of Atmospheric Programs

Office of Air and Radiation
2

Climate Benefits of the SNAP Program Status Change Rule

March 2016

Executive Summary

The U.S. Environmental Protection Agency (EPA) is issuing a proposed rule that would change the status of 

certain alternatives1 previously found acceptable under the Significant New Alternatives Policy (SNAP) 

program and would find certain other alternatives acceptable. The EPA is modifying the listings from 

acceptable to unacceptable for certain hydrofluorocarbons (HFCs) and HFC blends in foam blowing, 

refrigeration and air conditioning, and fire suppression end-uses where other alternatives are available or 

potentially available that pose overall lower risk to human health and the environment. The emissions 

avoided associated with the proposed rule are estimated to be 6 to 7 million metric tons (i.e., teragrams) 

of carbon dioxide equivalent (MMTCO2eq) in 2025 and 10 to 11 MMTCO2eq in 2030.

Background

In June 2013, the President announced the Climate Action Plan (CAP) stating that “while no single step can 

reverse the effects of climate change, we have a moral obligation to future generations to leave them a 

planet that is not polluted and damaged. Through steady, responsible action to cut carbon pollution, we 

can protect our children’s health and begin to slow the effects of climate change so that we leave behind a 

cleaner, more stable environment.”2 Among the many actions called for, the CAP outlined a set of 

measures to address hydrofluorocarbons (HFCs). In the United States, emissions of HFCs are expected to 

double from current levels of 1.5 percent of greenhouse gas (GHG) emissions to 3 percent by 2020 and 

nearly triple by 2030.3 HFCs are rapidly accumulating in the atmosphere. For example, the atmospheric 

concentration of HFC-134a, the most abundant HFC, has increased by about 10% per year from 2006 to 

2012, and the concentrations of HFC-143a and HFC-125 rose over 13% and 16% per year, respectively,

from 2007 to 2011.4,5

The President directed the executive branch of the United States government to lead through both 

international diplomacy and domestic action in addressing HFCs. In particular, he directed the EPA to use 

its authority through the Significant New Alternatives Policy (SNAP) Program to “encourage private sector 

investment in low-emissions technology by identifying and approving climate-friendly chemicals while 

prohibiting certain uses of the most harmful chemical alternatives.”

6

 

1 For purposes of this document, the terms “substitutes” and “alternatives” are used interchangeably.

2 The President’s Climate Action Plan, Executive Office of the President, June 2013. Available at 

http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf

3

Ibid.

4 Montzka, S.A.: HFCs in the Atmosphere: Concentrations, Emissions and Impacts, ASHRAE/NIST Conference 2012

5 NOAA data at ftp://ftp.cmdl.noaa.gov/hats/hfcs/

6 The President’s Climate Action Plan, Executive Office of the President, June 2013, page 10. Available at 

http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf
3

Under the authority of Section 612 of the Clean Air Act (CAA), the EPA is both expanding the list of 

acceptable alternatives and also changing the status of certain alternatives from acceptable to 

unacceptable. The analysis presented here concerns the EPA’s proposed action to modify the listings from 

acceptable to unacceptable for certain HFCs and HFC blends foam blowing, refrigeration and air 

conditioning, and fire suppression end-uses where other alternatives are available or potentially available 

that pose less overall risk to human health and the environment. The agency considers the intersection 

between the specific HFC or HFC blend and the particular end-use. In this action, the EPA is not listing any 

specific HFCs as unacceptable across all sectors and end-uses, nor is the EPA determining, for any specific 

sector, that no HFCs are acceptable substitutes. The EPA recognizes that both fluorinated substitutes (e.g., 

HFCs, hydrofluoroolefins (HFOs)) and non-fluorinated substitutes (e.g., hydrocarbons (HCs), carbon dioxide 

(CO2)) can be used. Thus, consistent with CAA Section 612, the existing SNAP regulations, and historical 

practice under the SNAP program, the EPA has considered the intersection among each substitute being 

evaluated, the particular end-use, the SNAP criteria for evaluation, and the current suite of other available 

and potentially available substitutes in each particular end-use. 

Analysis of Climate Benefits

The EPA’s SNAP Program, pursuant to CAA Section 612, evaluates whether substitutes are safer overall for 

human health and the environment than other available substitutes. For each end-use, SNAP lists

substitutes as either acceptable, acceptable subject to use conditions, acceptable subject to narrowed use 

limits, or unacceptable. SNAP’s evaluation of the overall safety of a substitute considers its toxicity, 

flammability, ozone depletion potential, and global warming potential (GWP), among other factors. The 

CAP directs the EPA to use the SNAP Program to encourage private sector investment in low-emissions 

technology by identifying and approving climate-friendly chemicals while prohibiting certain uses of the 

most harmful chemical alternatives. To this end, SNAP’s Status Change Rule changes the listing of certain 

alternatives in the foams, refrigeration and air conditioning, and fire suppression sectors from acceptable 

to unacceptable, from acceptable to acceptable subject to use conditions, or from acceptable to 

acceptable subject to narrowed use limits. The specific listing changes for each end-use can be found in 

Appendix A.

Methodology

To estimate the climate benefits of the rule, the EPA compared a business-as-usual (BAU) forecast of HFC 

emissions with those derived under various scenarios conforming to the rule. In developing both the BAU 

forecast and the scenarios, the EPA used its Vintaging Model,7 an emission estimation tool used to derive 

HFC emission inventories for reporting to the Intergovernmental Panel on Climate Change (IPCC) as part of 

the United States’ obligations under the United Nations Framework Convention on Climate Change 

(UNFCCC). 

 

7 VM IO file_v4.4_12.16.09_GER_IMAC_Domestic_2013 Options Update_AR4_11-21-13.xlsm
4

The Vintaging Model was developed as a tool for estimating the annual chemical emissions from industrial

sectors that have historically used ozone depleting substances (ODS) in their products. Under the terms of 

The Montreal Protocol on Substances that Deplete the Ozone Layer and the Clean Air Act, the production 

and import of ODS have been greatly reduced, motivating these industrial sectors to transition to more 

ozone-friendly chemicals. As these industries have moved toward ODS alternatives, including HFCs, the 

Vintaging Model has evolved into a tool for estimating the rise in emissions of these alternatives and the 

decline of ODS emissions.

The Vintaging Model estimates emissions from five ODS and ODS-substitute sectors: air-conditioning and 

refrigeration, foams, aerosols, solvents, and fire suppression. Within these sectors, there are 60 

independently modeled end-uses. The model requires information on the market growth for each of the 

end-uses, a history of the market transition from ODS to alternatives, and the characteristics of each enduse such as market size or charge sizes and loss rates. As ODS are phased out, a percentage of the market 

share originally filled by the ODS is allocated to each of its substitutes.

The model, named for its method of tracking the emissions of annual “vintages” of new equipment that 

enter into service, is a “bottom-up” model. It models the emissions of ODS and ODS substitutes based on 

estimates of the quantity of equipment or products sold, serviced, and retired each year; the amount of 

the chemical required to manufacture and/or maintain the equipment; and the amount emitted during 

specific time periods. The Vintaging Model makes use of this market information to build an inventory of 

the in-use stocks of the equipment and ODS and ODS substitute(s) in each of the end-uses. The simulation 

is considered to be a BAU baseline case, and it does not incorporate measures to reduce or eliminate the 

emissions of these gases other than those currently required by statute or regulation, or otherwise 

common in the industry. Emissions are estimated by applying annual leak rates, service emission rates, 

and disposal emission rates to each population of equipment. By aggregating the emission output from 

the different end-uses, the model produces estimates of total annual emissions of each chemical. 

The Vintaging Model synthesizes data from a variety of sources, including data from the ODS Tracking 

System maintained by the EPA’s Stratospheric Protection Division and information from submissions to 

the EPA under the SNAP program. Published sources include documents prepared by the United Nations 

Environment Programme (UNEP) Technical Options Committees, reports from the Alternative 

Fluorocarbons Environmental Acceptability Study (AFEAS), and conference proceedings from the 

International Conferences on Ozone Protection Technologies and Earth Technologies Forums. The EPA 

also coordinates extensively with numerous trade associations and individual companies. For example, the 

Alliance for Responsible Atmospheric Policy; the Air-Conditioning, Heating and Refrigeration Institute; the 

Association of Home Appliance Manufacturers; the American Automobile Manufacturers Association; and 

many of their member companies have provided valuable information over the years.

Because the Vintaging Model follows a bottom-up approach, scenarios of alternate pathways may be 

developed by changing transition timing, chemical(s) chosen, and emission patterns. For example, because 

the proposed rule does not allow certain HFCs to be used in certain end-uses, a scenario can be run in the 

Vintaging Model that assumes that a particular end-use transitions to an alternative that would remain 

acceptable. As a specific example, the scenario may assume that all household refrigerators utilizing HFC134a switch to using R-600a. That scenario could vary in timing; for instance, by assuming this transition 
5

only begins in 2021 or by assuming it starts earlier, with some new refrigerators using R-600a in 2020 and 

the rest in 2021. Either such transition would be in compliance with the proposed rule assuming the 

transition is complete by the required date. Likewise, a scenario could assume transition of some 

refrigerators to R-450A instead of R-600a.

To analyze the potential emissions reductions of the proposed rule, scenarios were developed to estimate 

the rate at which transition away from higher-GWP HFCs would progress and what would be used in place 

of the higher-GWP HFCs. The analysis includes three scenarios for comparison: the most likely transition 

scenario; a higher, more aggressive transition scenario; and a lower, less aggressive transition scenario.

8

The scenarios differ in their assumptions on transition away from higher-GWP HFCs in four ways: 

 earlier/later start of transitions, 

 faster/slower rise to saturation, 

 higher/lower saturation level, and 

 higher/lower preference for lower GWPs in end-uses where the options analyzed vary. 

The specific transitions assumed for each scenario are detailed in Table 1.

Table 1: Transition Scenarios

End-Use Option Lower Option 

Description

Most Likely Option 

Description

Higher Option 

Description

Centrifugal Chillers

HFC-134a to 

R-450A/R-513Aa

Overnight transition 

to 90% in 2024

0% in 2019, Linear

increase to 90% by 

2024

0% in 2019, Linear 

increase to 45% by 

2024

HFC-134a to 

HFO-1234yf NA NA Overnight transition to 45% in 2024

HFC-245fa to SolsticeTM-

1233zd(E)

a

Overnight transition 

to 90% in 2024

0% in 2019, Linear 

increase to 90% by

2024

0% in 2017, Linear 

increase to 90% by 

2024

Positive Displacement 

Chillers

R-410A/R-407C to 

R-450A/R-513Aa

Overnight transition 

to 90% in 2024

0% in 2019, Linear 

increase to 90% by 

2024

Linear 0% in 2019, 

Linear increase to 45% 

by 2024

R-410A/R-407C to 

HFO-1234yf NA NA Overnight transition to 45% in 2024

HFC-134a to 

R-450A/R-513Ab NA NA NA

Cold Storage

R-404A/R-507A to 

R-407F

Overnight transition 

to 100% in 2023

0% in 2016, Linear 

increase to 50% by 

2023

NA

R-404A/R-507A to 

R-448A/R-449A NA 

0% in 2017, Linear 

increase to 50% by 

2023

0% in 2017, Linear 

increase to 100% by 

2023

Household 

Refrigerators and 

Freezersc

HFC-134a to R-450A/ 

R-513A

Overnight transition 

to 28% in 2021

Overnight transition to 

14% in 2021 NA

HFC-134a to R-600a Overnight transition 

to 72% in 2021 

Overnight transition to 

86% in 2021

Overnight transition to 

100% in 2021

 

8 The scenarios analyzed here reflect possible transitions for compliance based on considerations of the market and activity 

towards lower-GWP solutions. A separate technical support document analyzes the cost of complying with the proposed rule.
6

End-Use Option Lower Option 

Description

Most Likely Option 

Description

Higher Option 

Description

Refrigerated Food 

Processing and 

Dispensing Equipmentd

R-404A/R-507A to 

R-450A NA NA NA

Polyurethane Rigid 

Spray Foam

(High-pressure, twocomponent)

HFC-245fa and HFC245fa/CO2 to SolsticeTM-

1233zd(E)

Overnight transition 

to 70% in 2020

0% in 2017, Linear 

increase to 70% by 

2020

0% in 2015, Linear 

increase to 70% by 

2020

(Low-pressure, twocomponent)

HFC-134a to 

HFO-1234ze(E)

e

Overnight transition 

to 30% in 2021

0% in 2017, Linear 

increase to 30% by 

2021

0% in 2015, Linear 

increase to 30% by 

2021

Polyurethane Rigid One 

Component Foam

HFC-134a to HFO1234ze(E)Overnight transition 

to 100% in 2020

0% in 2017, Linear 

increase to 100% by 

2020

0% in 2015, Linear 

increase to 100% by 

2020

Flexible PU Foam: 

Slabstock Foam, 

Moulded Foam

Methylene Chloride to 

HCsb NA NA NA

Flexible PU Foam: 

Integral Skin Foam

Methylene Chloride to 

HCs or CO2

b NA NA NA

Polyolefin Foam Methylene Chloride to 

HCsb NA NA NA

Fire Suppression: 

Total Flooding

Perfluorocarbons 

(C3F8 and C4F10) to 

fluoroketone, CO2, or 

water mistb

NA NA NA

a In the absence of this proposed rulemaking, by 2022 it is assumed that 10% of the positive displacement and centrifugal chillers 

markets will have already transitioned away from HFCs or would remain in HFCs under a narrowed use limit. This transition is not 

reflected in the baseline. This assumption is based on the current commercial availability of R-513A and SolsticeTM-1233zd(E) 

chillers as well as commitments from chiller manufacturers to introduce lower-GWP refrigerants in their product lines 

(https://www.whitehouse.gov/the-press-office/2015/10/15/fact-sheet-obama-administration-and-private-sector-leadersannounce)

b Zero penetration for original fluorinated or chlorinated compound currently assumed in Vintaging Model; Option not applied.

c This analysis assumes that in the lower option transition scenario small manufacturers of household refrigerators and freezers 

will transition from HFC-134a to either R-450A or R-513A and large business manufacturers will transition to isobutane (R-600a). 

The market penetration assumptions are based on the market share of new sales of household refrigerators and freezers by 

manufacturer developed for the Draft Economic Impact Screening Analysis for Regulatory Changes to the Listing Status of HighGWP Alternatives used in Refrigeration and Air Conditioning, Foams, and Fire Suppression for this proposed rulemaking.

d Refrigerated food processing and dispensing equipment options were not analyzed, as this end-use was not modeled in this 

version of the Vintaging Model. 

e The Vintaging Model spray foam end-use, which assumes the use of HFC-245fa and HFC-245fa co-blown with CO2 blowing 

agents, does not disaggregate spray foam into high-pressure, two-component and low-pressure, two-component foam 

applications. Low-pressure, two-component foam primarily uses HFC-134a as the blowing agent; however, the model does not 

model any use of HFC-134a in the spray foam end-use. As a proxy, this analysis assumes a portion of the currently modeled 

blowing agent market (i.e., HFC-245fa and HFC-245fa/CO2) represents low-pressure, two-component spray foam that would 

transition to HFO-1234ze. Because this portion of the market would actually be transitioning from HFC-134a, this analysis 

underestimates potential reductions from this transition by approximately 50% per year due to the GWP differential between 

HFC-245fa and HFC-245fa co-blown with CO2 and HFC-134a (i.e., GWPs of 1,030, 550, and 1,430, respectively) and the assumed 

market share of these blowing agents (i.e., 33% HFC-245fa and 67% HFC-245fa co-blown with CO2).
7

The U.S. emissions of HFCs from each end-use were estimated for these scenarios and the baseline 

scenario (i.e., BAU scenario without the rule) using the EPA’s Vintaging Model, and the total GWPweighted emissions were calculated in MMTCO2eq as shown below in Table 2 and Figures 1 and 2.

9 The

version of the Vintaging Model used is consistent with previous EPA analyses of non-CO2 GHG abatement 

options.

10

Climate Benefits

As shown in Table 2, implementation of the Status Change Rule is estimated to reduce net HFC emissions 

in 2025 by 6 to 7 MMTCO2eq and 10 to 11 MMTCO2eq in 2030, relative to the baseline. Note that this 

baseline assumes some reductions due to the July 2015 Climate Benefits of the SNAP Program Status 

Change Rule [EPA-HQ-OAR-2014-0198-0239]. For this reason the projected trend of HFC emissions from 

modeling performed in 2014 for that earlier rule is also shown for comparison. The most likely transition 

scenario was developed based on EPA experience in the sectors and knowledge of the available, SNAPacceptable alternatives that are currently being tested and implemented. 

Table 2. Emissions Profile of Affected Sectors/Applications in Transition Scenarios and Baseline

Year 2015 2020 2025 2030 2035 2040 2045 2050

Pre-2014 emissions 

trend 215 285 373 420 463 500 531 556

United States 

baseline including 

July 2015 rule

212 255 311 324 351 379 403 422

Lower Scenario 

Emissions 212 253 306 314 337 361 380 395

Lower Scenario 

Percent Reduction 0% -1% -2% -3% -4% -5% -6% -6%

Most Likely Scenario 

Emissions 212 252 305 313 335 359 379 394

Most Likely Scenario 

Percent Reduction 0% -1% -2% -3% -4% -5% -6% -7%

Higher Scenario 

Emissions 212 252 304 313 334 358 377 393

Higher Scenario 

Percent Reduction 0% -1% -2% -3% -5% -6% -6% -7%

 

9 GWPs used are direct, 100-year values from IPCC, 2007: Climate Change 2007: The Physical Science Basis. Contribution of 

Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. 

Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United 

Kingdom and New York, NY, USA. Where GWPs are not available from that source, values are taken from the literature as 

referenced in the SNAP decisions first listing such substances as acceptable.

10 Global Mitigation of Non-CO2 Greenhouse Gases: 2010–2030 (EPA Report 430-R-13-011, September 2013)
8

As seen in 2020, under the “most likely” transition scenario, emissions are projected to be reduced to 252

MMTCO2eq out of baseline emissions of 255 MMTCO2eq This represents a 1% reduction in emissions. 

After 2020, emission reductions steadily increase to 7% of baseline through 2050 with some growth in 

emissions due to continued market growth with all options fully implemented. Figure 1 below shows the 

potential range in emissions following the adoption of either the lower, most likely, or higher scenario. In 

addition, the emissions trend as calculated before the 2015 Status Change Rule is shown for comparison. 

Figure 1. United States Emissions and Potential Reductions through 2050

The growth in emissions reductions can be seen in Figure 2. A short period of transition, during which the 

implementation of lower-GWP alternatives is increasing, is complete in all end-uses by 2023. After 2023, 

emission reductions steadily increase to 5% of baseline through 2050 with some growth in emissions due 

to continued market growth with all options fully implemented.

200

250

300

350

400

450

500

550

600

2015 2020 2025 2030 2035 2040 2045 2050

HFC emissions (MMTCO2eq)

United States pre-2014 emissions

trend

United States baseline including July

2015 rule

Range of potential emissions based

on scenarios
9

By 2023, most of the provisions in the proposed rule would be in effect. The differences in the three 

scenarios in 2025 and other years are significant mostly because of the lag between when alternatives are 

introduced in new equipment and foams, and when the emission reductions are realized. The later and 

slower transitions in the lower scenario have not yet accrued emissions reductions by 2025 to the extent 

of those accrued under the most likely scenario, which in turn has not yet reached the levels seen in the 

higher scenario.

Figure 2. Emissions Reductions by Sector in 2025 (MMTCO2eq), Most Likely Scenario

Conclusion

The EPA anticipates that 6 to 7 MMTCO2eq is the most likely estimate for the climate benefits associated 

with avoided emissions for the SNAP Status Change Rule in 2025 and 10 to 11 MMTCO2eq in 2030. Three 

scenarios the EPA considered were developed and compared with a business-as-usual scenario. If the EPA 

were to consider the emissions reductions in 2035 or another later date, the climate benefits would be 

greater. 

Chillers 0.3 Refrigerated 

Appliances 0.1

Cold Storage 0.8

PU Foam 5.1
10

Appendix A

Proposed Listing Changes in the Status Change Rule by Sector

Option Description of Regulatory Change

Refrigeration and Air-Conditioning

1*

For new centrifugal chillers, list unacceptable FOR12A, FOR12B, HFC-134a, HFC-227ea, HFC-236fa, HFC245fa, R-125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R410A, R-410B, R-417A, R-421A, R-422B, R-422C, R-422D, R-423A, R-424A, R-434A, R-438A, R-507A, RS-44 

(2003 composition), and THR-03 in 2024.

2

For retrofit centrifugal chillers, list unacceptable FOR12A, FOR12B, HFC-134a, HFC-236fa, HFC-245fa, R125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-417A, R417C, R-421A, R-422B, R-422C, R-422D, R-423A, R-424A, R-434A, R-438A, R-507A, RS-44 (2003 

composition), and THR-03 in 2024.

3*

For new positive displacement chillers, list unacceptable FOR12A, FOR12B, HFC-134a, HFC-227ea, KDD6, 

R-125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-410A, R410B, R-417A, R-421A, R-422B, R-422C, R-422D, R-424A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 

composition), SP34E, and THR-03 in 2024.

4

For retrofit positive displacement chillers, list unacceptable FOR12A, FOR12B, HFC-134a, KDD6, R125/134a/600a (28.1/70/1.9), R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-417A, R417C, R-421A, R-422B, R-422C, R-422D, R-424A, R-427A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 

composition), SP34E, and THR-03 in 2024.

5*

For new retail food refrigeration (refrigerated food processing and dispensing equipment), list 

unacceptable HFC-227ea, KDD6, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R407C, R-407F, R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R428A, R-434A, R-437A, R-438A, R-507A, and RS-44 (2003 formulation) in 2021.

6

For retrofit retail food refrigeration (refrigerated food processing and dispensing equipment), list 

unacceptable R-404A and R-507A one year after publication of a final rule.

7a*

For new household refrigerators and freezers, list unacceptable FOR12A, FOR12B, HFC-134a, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-507A, RS-24 

(2002 formulation), RS-44 (2003 formulation), SP34E, and THR-03 in 2021.

7b

For new household refrigerators and freezers, list unacceptable FOR12A, FOR12B, HFC-134a, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-450A, R-438A, R507A, R-513A, RS-24 (2002 formulation), RS-44 (2003 formulation), SP34E, and THR-03 in 2021.

7c

For new household refrigerators and freezers, list unacceptable FOR12A, FOR12B, HFC-134a, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-428A, R-434A, R-437A, R-438A, R-450A, R507A, R-513A, RS-24 (2002 formulation), RS-44 (2003 formulation), SP34E, and THR-03 in 2025. 

8

For retrofit household refrigerators and freezers, list unacceptable FOR12A, FOR12B, HFC-134a, KDD6, 

R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407C, R-407F, R-417A, R-421A, R-421B, R-422A, R422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, RS-24 (2002 

formulation), RS-44 (2003 formulation), and SP34E in 2021.

9a*

For new cold storage warehouses, list unacceptable HFC-227ea, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, 

R-422C, R-422D, R-423A, R-424A, R-428A, R-434A, R-438A, R-507A, and RS-44 (2003 composition) in 

2021.
11

Option Description of Regulatory Change

9b

For new cold storage warehouses, list unacceptable HFC-227ea, KDD6, R-125/290/134a/600a 

(55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R-421B, 

R-422A, R-422B, R-422C, R-422D, R-423A, R-424A, R-428A, R-434A, R-437A, R-438A, R-507A, and RS-44 

(2003 composition) in 2021.

10

For retrofit cold storage warehouses, list unacceptable R-125/290/134a/600a (55.0/1.0/42.5/1.5), R404A, R-407A, R-407B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-423A, R-424A, R428A, R-434A, R-438A, R-507A, and RS-44 (2003 composition) in 2021.

Foam Blowing

11a

For rigid polyurethane high-pressure two-component spray foam, list unacceptable HFC-134a, HFC245fa, and blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of 

HFC-365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI, in 2019, except 

as allowed under a narrowed use limit for military or space-and aeronautics–related applications.

11b*

For rigid polyurethane high-pressure two-component spray foam, list unacceptable HFC-134a, HFC245fa, and blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of 

HFC-365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI in 2020, except 

as allowed under a narrowed use limit for military or space-and aeronautics–related applications. 

12a

For rigid polyurethane low-pressure two-component spray foam, list unacceptable HFC-134a, HFC245fa, and blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of 

HFC-365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI in 2020, except 

as allowed under a narrowed use limit for military or space-and aeronautics–related applications.

12b*

For rigid polyurethane low-pressure two-component spray foam, list unacceptable HFC-134a, HFC245fa, and blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of 

HFC-365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI in 2021, except 

as allowed under a narrowed use limit for military or space-and aeronautics–related applications.

13a

For rigid polyurethane one-component foam sealants, list unacceptable HFC-134a, HFC-245fa, and 

blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of HFC365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI in 2019, except as 

allowed under a narrowed use limit for military or space-and aeronautics–related applications.

13b*

For rigid polyurethane one-component foam sealants, list unacceptable HFC-134a, HFC-245fa, and 

blends thereof; blends of HFC-365mfc with at least 4% HFC-245fa, and commercial blends of HFC365mfc with 7 to 13% HFC-227ea and the remainder HFC-365mfc; and Formacel TI in 2020, except as 

allowed under a narrowed use limit for military or space-and aeronautics–related applications.

14* In flexible polyurethane foam, list methylene chloride as unacceptable 30 days after publication of a 

final rule.

15* In integral skin polyurethane foam, list methylene chloride as unacceptable in 2017. 

16* In polyolefin foam, list methylene chloride as unacceptable in 2020.

Fire Suppression and Explosion Prevention

17a*

For total flooding uses, list unacceptable perfluorocarbons (C3F8 and C4F10) one year after publication of 

a final rule.

17b

For total flooding uses, list unacceptable perfluorocarbons (C3F8 and C4F10) and SF6 one year after 

publication of a final rule and list HFC-23 as acceptable, subject to narrowed use limits one year after 

publication of a final rule.

18 For streaming uses, list unacceptable perfluorocarbon (C6F14) one year after publication of a final rule.