THE U.S. PHASEOUT OF HCFCS:

PROJECTED SERVICING NEEDS IN THE U.S. 

AIR-CONDITIONING, REFRIGERATION, AND FIRE 

SUPPRESSION SECTORS

UPDATED FOR 2015 TO 2025

Prepared for 

U.S. Environmental Protection Agency

Office of Air and Radiation

Stratospheric Protection Division

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Prepared with support from

ICF International

1725 Eye Street, NW

Washington, DC 20006

DRAFT, NOVEMBER 2013
This draft report estimates the quantity of HCFC-22 (also recognized by the American Society of Heating 

Refrigerating and Air- Conditioning Engineers (ASHRAE) designation, R-22), HCFC-142b, HCFC-123 and 

HCFC-124 needed to service air-conditioning and refrigeration equipment and the anticipated installed 

base of such equipment beyond 2015 in the United States. The report also discusses the uses and need

for other HCFCs, including HCFC-123 use in nonresidential fire suppression. This analysis has been 

developed to inform the allocation of HCFC consumption allowances in 2015-2019. This report updates 

the 2009 version of the report of the same name that was released with the 2009 Final Rule titled 

“Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export,” (December 

2009, 74 FR 66412). This draft report also builds on the discussion included in the memo to the docket 

titled “Analysis of HCFC-22 Servicing Needs in the U.S. Air Conditioning and Refrigeration Sector: 

Additional Considerations for Estimating Virgin Demand,” (Adjustment Memo, docket ID # EPA-HQ-OAR2011-0354-0003). A description of notable updates and additions to the Vintaging Model (the model used 

to develop the data provided in this report) since the 2009 report can be found in Appendix C of this

document. 

Questions concerning this report should be directed to: 

Elizabeth Whiteley

Stratospheric Protection Division 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (6205J)

Washington, D.C. 20460

1-202-343-9310 (phone)

1-202-343-2338 (fax)

whiteley.elizabeth@epa.gov
Contents

Executive Summary....................................................................................................................................1

1. Background: The U.S. HCFC Phaseout Schedule.............................................................................5

1.1. Report Objective ...........................................................................................................................6

2. Methodology Overview ........................................................................................................................8

3. Overview of HCFC Use in the United States......................................................................................9

3.1. Projected HCFC Need ................................................................................................................10

3.2. HCFC Use in Refrigeration and Air-Conditioning........................................................................11

3.3. HCFC Use in Nonresidential Fire Suppression...........................................................................15

4. Projected HCFC Scenarios................................................................................................................17

4.1. HCFC-22 .....................................................................................................................................17

4.1.1. HCFC-22 Equipment Used Beyond 2015 ...........................................................................17

4.1.2. Projected HCFC-22 Servicing Needs..................................................................................18

4.2. HCFC-123 ...................................................................................................................................19

4.2.1. HCFC-123 Equipment Used Beyond 2015 .........................................................................19

4.2.2. Projected HCFC-123 Needs ...............................................................................................20

4.3. HCFC-124 ...................................................................................................................................20

4.3.1. HCFC-124 Equipment Use Beyond 2015 ...........................................................................20

4.3.2. Projected HCFC-124 Needs ...............................................................................................21

4.4. HCFC-142b .................................................................................................................................21

4.5. HCFC Sources ............................................................................................................................21

4.6. Meeting Refrigeration and AC Service Need ..............................................................................23

4.6.1. Servicing Need and Recovery Projections for HCFC-22 ....................................................24

4.6.2. Need and Recovery Projections for HCFC-123 ..................................................................26

4.6.3. Servicing Need and Recovery Projections for HCFC-124 ..................................................27

4.6.4. Summary of HCFC-22, HCFC-123, and HCFC-124 Servicing Need and Recovery 

Projections ...........................................................................................................................................28

4.7. Factors Affecting Projections ......................................................................................................29

4.7.1. Transitioning to Alternative Refrigerants.............................................................................29

4.7.2. Recovery and Reuse Practices...........................................................................................31

4.7.3. Recycling, Reuse, and Managing Inventory .......................................................................31

4.7.4. HCFC-22 Economics ..........................................................................................................32

4.7.5. Increasing Seasonal Energy Efficiency Ratio (SEER)........................................................32

4.7.6. Lower Loss Rates................................................................................................................32

5. Conclusion ..........................................................................................................................................34

Appendix A: Methodology Used to Calculate Projected Servicing Needs .........................................36

Appendix B: HCFC Projections by End-Use ..........................................................................................46

Appendix C: Changes to the Vintaging Model.......................................................................................48

Appendix D: Sensitivity Analyses ...........................................................................................................49

Appendix E: HCFC-22 Inventory Estimate..............................................................................................54

References.................................................................................................................................................55
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Updated Projected Servicing Needs in the U.S. Air-Conditioning, Refrigeration, and Fire Suppression Sectors for 2015 to 2025

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Executive Summary

Hydrochlorofluorocarbons (HCFCs) are a class of chemical compounds that deplete the stratospheric 

ozone layer, increasing the chances of overexposure to ultraviolet (UV) radiation at the earth’s surface. 

Excessive UV radiation damages biological systems and causes malignant melanoma and other skin 

cancers, cataracts and other eye damage, and harm to certain crops and marine organisms. Reversing 

the course of stratospheric ozone depletion is crucial to human and environmental health worldwide. As a 

Party to the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol), the 

United States is subject to a cap on HCFC consumption—defined as production1plus imports minus 

exports—in an international effort to protect the stratospheric ozone layer (UNEP 2000). Specifically, the 

United States is obligated to phase out production and consumption of HCFCs by 2030 by making 

graduated reductions in HCFC production and consumption by certain dates. 

To meet these interim reduction targets, the U.S. Environmental Protection Agency (EPA) established a 

schedule for the phaseout of HCFCs. EPA phased out consumption of HCFC-141b in 2003. On January 

1, 2010, the production and import of HCFC-142b and HCFC-22 were banned except for servicing 

equipment manufactured before January 1, 2010. The next phaseout milestone will occur in 2015 with a 

ban on production and import of any other HCFCs, except for use as refrigerants in equipment 

manufactured prior to January 1, 2020. In addition, in December 2011, Title VI of the Clean Air Act was 

amended to permit the use of HCFCs in non-residential fire suppression applications. Starting on January 

1, 2020, there will be a ban on any remaining production and import of HCFC-22 and HCFC-142b,

2

and 

production and import of other remaining HCFCs will be limited to use as a refrigerant to service existing 

equipment. 

Thus, starting in 2015, the production and import of virgin HCFCs in the United States will be limited to 

servicing existing refrigeration and AC equipment, and non-residential fire suppression applications.

3

Historically, only HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 have been used in significant 

quantities in these applications. Table ES 1 presents an overview of the use limitations, applications, and 

servicing need projections for these four HCFCs. 

ES 1: Overview of HCFC Use Limitations, Applications, and Projections for 2015 to 2025

HCFC Regulatory Limitations

Applications

Is Servicing Need Projected for 

Ref/ AC 2015- 2025?

NonResidential 

Fire 

Suppression

HCFC22Production and import limited January 1, 2010 

to use as a refrigerant in, or to provide service 

to, appliances manufactured prior to January 

1, 2010.

 -- Yes.

HCFC142b

 --

Not in the Vintaging Model. HCFC142b is a component of certain blends 

that have limited refrigeration 

applications, some of which (e.g., R409A) are not modeled.

HCFC123Production and import will be limited beginning 

January 1, 2015, to use as a refrigerant in, or 

to provide service to, appliances 

manufactured prior to January 1, 2020. HCFC123 and HCFC-124 can also be produced and 

imported for use as a nonresidential fire 

suppressant until 2020.

 * Yes.

HCFC124

 --

Yes. In addition, HCFC-124 is a 

component of certain blends that have

limited refrigeration applications, some 

of which (e.g., R-409A) are not 

modeled.

* HCFC-123 is a constituent of the Halotron I blend used in fire applications.

 

1 Under the Montreal Protocol, production is defined as “the amount of controlled substances produced, minus the amount 

destroyed...and minus the amount entirely used as feedstock in the manufacture of other chemicals. The amount recycled and 

reused is not to be considered as production” (UNEP 2000).

2 Exceptions to this ban include the use of HCFC-22 or HCFC-142b in: 1) processes resulting in their transformation or destruction 

or 2) pre-authorized importation of recovered, reclaimed, or recycled HCFCs. 

3

The Clean Air Act allows for the continued use of “used, recovered and recycled” HCFCs.
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Table ES 2 presents the Vintaging Model’s projected servicing need for HCFC-22, HCFC-142b, HCFC123, and HCFC-124 in refrigeration, air conditioning, and non-residential fire suppression applications. As 

noted above, although the Vintaging Model projects no servicing need for HCFC-142b and minimal 

servicing need for HCFC-124 between 2015 and 2025, other information—such as refrigerant sales data 

collected by the California Air Resources Board—suggests that HCFC-142b and HCFC-124 are still in 

use in niche refrigeration applications.

Table ES 2: Projected HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 Servicing Need for 

Refrigeration, Air-Conditioning, and Fire Suppression, 2015-2025 (Metric Tons)

HCFC 2015 2016 2017 2018 2019 2020 2025

HCFC-22 46,100 41,600 36,700 32,300 27,700 22,500 5,500

HCFC-142b - - - - - - -

HCFC-123 2,200 2,200 2,200 2,300 2,300 600 500

HCFC-124 4 4 4 4 4 3 -

Source: Vintaging Model (2012).

Although limited production and consumption of virgin HCFC-22 and HCFC 142b can be allowed until 

2020, and HCFC-123 and HCFC-124 production can be allowed until 2030 (HCFC-22, HCFC-142b),

4 with 

industry effort, a significant portion of the need for HCFCs for servicing is expected to be met with 

previously used refrigerant that is recovered and then recycled or reclaimed. To determine the potential 

amounts of used refrigerant available to service equipment, EPA used its Vintaging Model to develop 

three scenarios of recovery to estimate: 1) the projected amount of recovered HCFCs potentially available 

to meet servicing need of equipment still in use; and 2) the subsequent quantity of HCFCs needed to 

satisfy the remaining need. Scenarios based on the Vintaging Model were not developed for HCFC-142b.

Figure ES-1, Figure ES-2, and Figure ES-3 present the results 

of these lower, baseline, and higher HCFC recovery scenarios. 

For HCFC-22, the lower recovery scenario assumes that 35 

percent of HCFC-22 from retired or retrofitted equipment is 

recovered and available for reuse in equipment;

5

the baseline

scenario assumes a recovery rate that is equal to the rate that 

is modeled by EPA’s Vintaging Model;6and the higher 

recovery scenario assumes 65 percent recovery. For HCFC123 and HCFC-124, the recovery rate modeled by the 

Vintaging Model is used for all three scenarios, since it is 

significantly higher (approximately 80 to 90 percent).

In accordance with U.S. commitments under the Montreal 

Protocol, HCFC consumption (i.e., production and imports of 

virgin HCFCs) cannot exceed 1,524 ODP-weighted metric tons 

from 2015 to 2019 and cannot exceed 76.2 ODP-weighted 

metric tons starting in 2020. Figures ES-1 through ES-3 

summarize servicing need in comparison to this U.S. HCFC 

consumption cap. The figures also present the amount of need that can be met by recovered and reused 

material (dark grey) and the remaining amount that would need to be met by virgin material.

 

4 New production and import of HCFC-22 for servicing is possible until January 1, 2020. While EPA has not proposed allowances for 

HCFC-123 after 2019, EPA is considering allowing new production and import for servicing up until January 1, 2030.

5

The remaining 65% is not available for reuse.

6 Varies by end-use but in total equals about 50% industry-wide for the time period considered.

Box ES-1: Sensitivity Analysis

While EPA’s assumptions are frequently 

updated to refine assumptions, the projections 

of future servicing needs for HCFC-22 can be 

affected by outside factors that are not fully 

reflected in the estimates. A sensitivity 

analysis performed on key modeling 

assumptions suggests that HCFC-22 servicing 

demand could be marginally to significantly 

lower than what is projected. In particular, 

servicing need may be lower if the system 

charge size, leak rate, and/or equipment 

lifetime are less than current assumptions. The 

projections in this report provide only some of 

the information necessary for determining 

post-2015 servicing needs.
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Figure ES 1: Total Projected HCFC Demand, Lower Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand

 3,000

Figure ES 2: Total Projected HCFC Demand, Baseline Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand
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The analysis demonstrates that it is possible to meet the projected servicing and new equipment needs7

for HCFC-22, HCFC-123, and HCFC-124 in 2015 under the baseline and higher recovery scenarios (see 

Figure ES-2 and Figure ES-2). Recovered refrigerant, in addition to limited amounts of virgin refrigerant 

(not exceeding the cap), can satisfy future servicing needs. As shown in Figure ES-1, the AC and 

refrigeration industry may face potential shortage risks in a lower recovery scenario. 

Several other factors also influence the level of HCFC servicing need and sufficiency of recovered supply 

in 2015 and beyond. For example, with approximately 97 million AC and refrigeration units projected to be 

in use in 2015, the sooner consumers transition to equipment using alternative refrigerants, the better the 

chance for an adequate HCFC-22, HCFC-123, and HCFC-124 supply to satisfy the forecasted servicing 

need. This report explores the following market trends and how they may influence future HCFC servicing 

need and available supply estimates, including:

• the rate of market transition to alternative refrigerants in the United States;

• HCFC-22 cost;

• assumed equipment leak and servicing loss rates; 

• increased seasonal energy efficiency ratio (SEER) standards; and

• quantities of refrigerant recovered for reuse, reclamation, and/or banking.

If leak rates, practiced equipment lifetimes, and charge sizes are less than what the agency currently 

assumes—as suggested by some stakeholders—servicing need, as well as necessary virgin supply, 

could be significantly lower than what is presented in the figures above.

 

7 Because the Clean Air Act prohibits the use of virgin HCFC-123 starting in 2020, this report only models new equipment demand 

for HCFC-123 for 2015 to 2020.

Figure ES 3: Total Projected HCFC Demand, Higher Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand
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1. Background: The U.S. HCFC Phaseout Schedule

Title VI of the 1990 Clean Air Act Amendments (CAAA) mandates the development and implementation 

of regulations to protect the stratospheric ozone layer and ensure U.S. compliance with the Montreal 

Protocol on Substances that Deplete the Ozone Layer (the Montreal Protocol). Under the Montreal 

Protocol, the United States and other signatories have agreed to achieve progress toward the total 

phaseout of the consumption and production of HCFCs, which are ozone-depleting substances (ODS) 

and have been widely used as refrigerants, solvents, foam blowing agents, and fire suppressants.8

Consumption is defined as production plus imports minus exports; production is defined as the 

manufacture of a controlled substance minus amounts destroyed and amounts completely used as 

feedstock in the manufacture of other chemicals. Neither consumption nor production includes amounts 

that are reused or recycled (UNEP 2000).

In September 2007, the nineteenth Meeting of the Parties to the Montreal Protocol was held in Montreal, 

Canada, marking the 20th anniversary of the signing of the Protocol. At the meeting, the Parties agreed 

upon a strengthened phaseout of HCFCs. The adjustments call for non-Article 5 countries—the Protocol’s 

identifying term for developed countries—to limit HCFC production and consumption to 25 percent of 

baseline by 2010, 10 percent by 2015, and 0.5 percent by 2020—allowing for 0.5 percent of the baseline 

for annual servicing over the period 2020-2030.9Previously, the 2010 reduction step was 65 percent and 

was limited solely to consumption, not production.

Table 1-1 presents the HCFC consumption baseline and the graduated reductions (caps) to allowable 

HCFC consumption for the United States (and all Article 2 countries). 

Table 1-1. U.S. HCFC Consumption Phaseout Schedule under the Montreal Protocol

Date Consumption Cap ODP Weighted Metric 

Tonsa

Quantity Expressed in 

HCFC-22 Metric Tonsb

Jan 1, 1996

Baseline set at 2.8% of the 1989 ODP-weighted 

CFC consumption plus 100% of the 1989 ODPweighted HCFC consumption15,240 277,091 

Jan 1, 2004 35% reduction from the baseline 9,906 180,109 

Jan 1, 2010 75% reduction from the baseline 3,810 69,273

Jan 1, 2015 90% reduction from the baseline 1,524 27,709 

Jan 1, 2020 99.5% reduction from the baseline 76.2 0

c

Jan 1, 2030 100% reduction from the baseline 0 0

aAn ODP-weighted metric ton takes into account each ODS’ relative contribution to ozone depletion. One metric ton equals approximately 

2,204 pounds. 

bCalculated using an ODP of 0.055 for HCFC-22. 

c

In 2020, 0.5 percent of the U.S. consumption baseline remains, but the U.S. phaseout schedule prevents any allocation to HCFC-22.

Table 1-2 details the U.S. phaseout schedule for HCFCs established under the 1990 CAAA to comply 

with the targets set by the Montreal Protocol (as presented in Table 1-1). The production and import of 

HCFC-141b, the HCFC with the highest ODP, was phased out with limited exemptions on January 1, 

2003. Beginning in 2003, EPA established an allowance system to control the U.S. production and 

consumption (including import and export) of HCFCs and to apportion consumption allowances amongst 

HCFCs. Allowances are the privilege granted to an allowance holder to produce and/or import a limited 

quantity of an HCFC on an annual basis. Production and consumption allowances for HCFC-141b (for 

limited exemptions), HCFC-22, and HCFC-142b were authorized and distributed (on a kilogram basis) to 

certain companies (EPA 2003a).10 In the 2009 HCFC allocation rule, Protection of Stratospheric Ozone: 

 

8

The production and import of other ODS used by these industries, including chlorofluorocarbons, carbon tetrachloride, and methyl 

chloroform, were phased out in 1996 – halons in 1994 (with limited exemptions).

9 Article 5 countries—the Protocol’s identifying term for developing countries—follow a later phaseout schedule than Article 2 

countries and as a result of the agreement in 2007 are subject to a freeze in 2013 followed by reduction steps of 10 percent by 

2015, 35 percent by 2020, 67.5 percent by 2025, and allowing for servicing at an annual average of 2.5 percent from 2030-2040.

10 The production of one kilogram of HCFC requires the expenditure of one production allowance and one consumption allowance. 

The import of one kilogram of HCFC requires the expenditure of one consumption allowance. While the import of used HCFCs does 

not require the expenditure of allowances, it does require petition approval by EPA; see Section 4.2.1 for more detail.
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Adjustments to the Allowance System for Controlling HCFC Production, Import, and Export, EPA 

authorized and distributed (on a kilogram basis) production and consumption allowances for HCFC-123, 

HCFC-124, HCFC-225ca, and HCFC-225cb to certain companies in addition to HCFC-22 and HCFC142b (EPA 2009). The 2009 HCFC allocation rule was challenged in Arkema v EPA (618 F.3d 1, DC Cir. 

2010) and the portion of the rule that establishes company-by-company production and consumption 

baselines and calendar-year allowances for HCFC-22 and HCFC-142b was vacated. All other aspects of 

the rule are intact. In August 2011, EPA issued an interim final rule that established new company-bycompany HCFC-22 and HCFC-142b baselines and allocated production and consumption allowances for 

2011 (EPA 2011). In April 2013, EPA published a final rule allocating HCFCs for 2012 through 2014.

Table 1-2: U.S. HCFC Phaseout Schedule as Implemented by EPA Under the 1990 CAAA 

(to comply with the Protocol)

Date Restriction

Jan 1, 2003  Ban on production and import of HCFC-141b.

Jan 1, 2010  Ban on production and import of HCFC-22 and HCFC-142b except for on-going servicing needs 

in equipment manufactured before January 1, 2010.a

Jan 1, 2015

 Ban on the production, import, and introduction into interstate commerce or use of HCFCs 

except where the HCFCs are used as a refrigerant in equipment manufactured prior to January 

1, 2020 or where HCFCs are used as a fire suppression agent for nonresidential applications.

a, b

Jan 1, 2020

 Ban on remaining production and import of HCFC-22 and HCFC-142b.a

 Ban on production and consumption of all other HCFCs except for use in servicing refrigeration 

and AC equipment produced before January 1, 2020.c

Jan 1, 2030  Ban on production and import of all HCFCs.a

aCertain additional exemptions apply, including exemptions for (1) HCFCs used in processes resulting in their transformation or 

destruction, or (2) pre-authorized import of HCFCs that are recovered and either recycled or reclaimed.

bTitle VI of the Clean Air Act was amended in December 2011 to allow the use of HCFCs for nonresidential fire suppression purposes.

cArticle 2F of the Montreal Protocol requires that each Party shall ensure that consumption and production of hydrochlorofluorocarbons 

does not exceed zero; however, each Party may exceed that limit provided that consumption is restricted to the servicing of 

refrigeration and AC equipment manufactured before January 1, 2020.

Source: EPA (2003a); EPA (2007); United States Congress (2011); UNEP (2000).

Effective January 1, 2010, U.S. production and import of HCFC-22 and HCFC-142b were limited to use in 

equipment manufactured prior to January 1, 2010, with a complete phaseout of these HCFCs by January 

1, 2020.11 In addition to the HCFC-22 and HCFC-142b restrictions, beginning January 1, 2015, U.S. 

production, import, use, or introduction into interstate commerce of all other HCFCs will be banned except 

for use as refrigerants in equipment manufactured prior to January 1, 2020 or for use in nonresidential fire 

suppression. Starting in 2020, the Montreal Protocol further restricts production and import of virgin 

HCFCs to servicing of existing AC and refrigeration equipment. A complete ban on production and import 

of HCFCs goes into effect January 1, 2030.

12

This report evaluates the amount of HCFCs needed to ensure that the U.S. meets its international 

commitment under the Montreal Protocol, while also allowing for equipment owners to service HCFCdependent equipment until the end of its useful life. 

1.1. Report Objective

This report presents quantitative estimates of the projected amount of (a) units of equipment using HCFC22, HCFC-142b, HCFC-123, and HCFC-124 beyond 2015 in the United States and (b) HCFC-22, HCFC142b, HCFC-123, and HCFC-124 needed to meet servicing need beyond 2015 in the United States.13

This report is an update to the 2009 report The U.S. Phaseout of HCFCs: Projected Servicing Needs in 

the U.S. Air-Conditioning and Refrigeration Sector that provided projections through 2020. This report 

estimates HCFC consumption needs for air-conditioning (AC) and refrigeration equipment (the largest 

 

11 Or where additional exemptions apply.

12 HCFCs can also be produced and imported for use as a feedstock.

13 HCFC-22 and HCFC-142b are only permitted for servicing existing equipment beyond 2015. HCFC-123 and HCFC-124 can be 

used for servicing or to charge new air-conditioning or refrigeration equipment manufactured before January 1, 2020, or in 

nonresidential fire suppression applications.
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HCFC market and the largest industry sector using HCFCs) that will be in use after 2015 and possible 

future recovery scenarios to help meet those needs. This analysis also explores, in a limited way, 

servicing need for HCFCs for nonresidential fire suppression applications beyond 2015. 

The remainder of the report is organized as follows:

 Section 2 provides a brief overview of the methodology used to project servicing scenarios.

 Section 3 provides an overview of HCFC use in the United States, including projected servicing 

need of HCFCs, an overview of HCFC use in the AC and refrigeration sector, and an overview of 

HCFC use for nonresidential fire suppression.

 Section 4 provides three projected recovery scenarios and resulting HCFC-22, HCFC-123, and 

HCFC-124 consumption needs. Section 4 also provides some discussion on expected HCFC142b servicing need based on industry feedback.

 Section 5 summarizes factors that may affect the projections presented in the report.

 Appendix A presents further information on the projection methodology and its limitations.

 Appendix B provides AC and refrigeration projections by end-use.

 Appendix C provides an overview of the changes that have been made to EPA’s Vintaging Model 

since the 2009 report The U.S. Phaseout of HCFCs: Projected Servicing Needs in the U.S. AirConditioning and Refrigeration Sector (“Servicing Tail Report”).

 Appendix D provides sensitivity analyses performed to determine the effect that several key 

assumptions may have on HCFC-22 servicing need. Assumptions considered include: system 

charge size, average annual equipment leak rates (i.e., loss rates), and the expected length of 

time a system is in operation (i.e., equipment lifetime). 
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2. Methodology Overview

This report provides projections estimating the servicing need for HCFCs for 2015 to 2025. Appendix A 

discusses the assumptions used to develop the supply and servicing need estimates presented in this 

report and the limitations and caveats inherent in the analysis. EPA’s Vintaging Model is the primary tool 

used to perform the analysis and forms the basis for quantitative estimates of current and projected 

HCFC consumption. The Vintaging Model estimates the annual chemical emissions from industry sectors 

that have historically used ODS, including AC, refrigeration, foams, solvents, aerosols, and fire protection. 

Within these industry sectors, there are over 60 independently modeled end-uses. The model uses 

information on the market size and growth for each end-use, as well as a history and projections of the 

market transition from ODS to alternatives. 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 tracks emissions of annual 

“vintages” of new equipment that enter into operation by incorporating information on estimates of the 

quantity of equipment or products sold, serviced, and retired or retrofitted each year, and the quantity of 

the chemical required to manufacture, charge, and/or maintain the equipment. EPA’s Vintaging Model 

uses this market information to build an annual inventory of in-use stocks of equipment and the ODS and 

non-ODS substitutes in each end-use. The model is updated on a regular basis to reflect changes in the 

market and new industry information. Updates to the Vintaging Model since the release of the 2009 

Servicing Tail Report are summarized in Appendix C.

This report provides an update of HCFC-22 servicing needs for air-conditioning and refrigeration 

equipment, as well as an update on the estimated servicing need for other HCFCs. This analysis has 

undergone many revisions; key milestones include:

 The first release of this report was on November 4, 2005 when EPA made the preliminary 

draft version available for comment in a Notice of Data Availability (NODA, 70 FR 67172). 

Based on comments received from stakeholders, EPA used the Vintaging Model to test 

whether servicing need might exceed supply under some circumstances. 

 On September 29, 2006, EPA’s Stratospheric Protection Division held a meeting for HCFC 

stakeholders regarding the 2010 milestone in the HCFC phaseout. EPA issued a September 

2006 version of this report at that time. This version contained one additional scenario of 

consumption needs for HCFC-22 based on stakeholder input on the 2005 draft report. 

 A June 2008 version of the report took into account the comments from stakeholders and 

provided an updated set of analyses based on the most recent Vintaging Model output. The 

June 2008 version of the report included the HCFC-22 estimates of a recovery rate of 15, 20, 

and 75 percent in addition to updating the previous scenarios of 10 and 50 percent.

 On December 23, 2008, EPA published two proposed rules, Adjustments to the Allowance 

System for Controlling HCFC Production, Import, and Export (73 FR 78680) and Ban on the 

Sale or Distribution of Pre-charged Appliances (73 FR 78705). Comments on both proposed 

rules were submitted during the public comment period in early 2009 in Docket ID No. EPA–

HQ–OAR–2008–0496 and Docket ID No. EPA–HQ–OAR–2007–0163 respectively. The 

Allowance System proposed rule requested comments on the draft servicing tail analysis. 

 In December 2009, another version of the report took into account relevant comments from 

stakeholders. The report focused on two recovery rates scenarios (20 and 50 percent) and 

presented the actual allocation amounts for the 2010-2014 control periods as found in EPA’s 

final rule. 

 In November 2011, EPA conducted research and analysis to account for the changes in the 

HCFC-22 market since the 2009 Final Rulemaking. The 2011 memorandum (Docket ID No.

EPA-HQ-OAR-2011-0354-0003) provided additional information on virgin HCFC-22

inventory, recovery and reuse practices in large retail food, and reclamation trends and 

capacity.

The purpose of the projections presented in this report and earlier versions is to support the process of 

allocating HCFC consumption allowances. To that end, this report update focuses on the next segment of 

years in the phaseout—2015 through 2025 and the four main HCFCs of concern—HCFC-22 HCFC-123, 

HCFC-124, and HCFC-142b.
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Box 3-1: Summary of Common HCFCs and their End-Use Applications

 HCFC-141b - historically used as a blowing agent in rigid polyurethane foams and integral skim foams and in 

aerosol solvent cleaning applications. Production and consumption phased out in 2003 except for exemption 

production for specific applications.

 HCFC-22 - used as a refrigerant in several applications such as unitary air conditioners, cold storage, retail food 

refrigeration equipment, chillers, and industrial process refrigeration; see Section 4 for further information. Also used 

(in smaller quantities) as a blowing agent for certain foam applications and as a component of some sterilant 

mixtures. Production and consumption phased out in 2010 except for servicing appliances manufactured before 

January 1, 2010.

 HCFC-123 - used in centrifugal chillers and portable fire extinguishers.

 HCFC-124 - used in sterilant mixtures and as a component in some replacements for CFCs as a refrigerant or for 

halon as a fire suppressant. Replaces CFC-114 in some heat pumps and special air conditioning equipment. HCFC124 (combined with HCFC-142b) is also a component of some blends (e.g., R-409A, R-414B), which are primarily 

used as a retrofit alternative to CFC-12 and R-500 in refrigeration applications. Use of HCFCs as a sterilant is being 

phased out in 2015 by the Clean Air Act.

 HCFC-142b - historically used as a blowing agent in extruded polystyrene boardstock. Also used in small quantities 

in refrigerant blends as a retrofit refrigerant for applications such as motor vehicle ACs that previously used CFC-12 

and other refrigeration applications that previously used CFC-12 and R-500. Production and consumption phased 

out in 2010 except for servicing appliances manufactured before January 1, 2010.

 HCFC-225ca/cb - used as a solvent, an aerosol solvent, and in small quantities in the adhesives, coatings, and inks 

sector. HCFC-225 ca/cb is a mixture of the two isomers HCFC-225ca and HCFC-225cb typically in a 45/55% by 

weight ratio. Use of HCFCs as a solvent is being phased out in 2015 by the Clean Air Act.

Table 3-1. HCFC Atmospheric Lifetime (Years) and Ozone Depletion Potential

HCFC Chemical Name CAS 

Number

Atmospheric

Lifetime 

(years)

ODPa

HCFC-141b (CH3CFCl2) 1,1-Dichloro-1-fluoroethane 1717-00-6 9.2 0.11

HCFC-142b (CH3CF2Cl) 1-Chloro-1,1-difluoroethane 75-68-3 17.9 0.065

HCFC-22 (CHF2Cl) Chlorodifluoromethane 75-45-6 12.0 0.055

HCFC-124 (CF3CHFCl) 2-Chloro-1,1,1,2-tetrafluoroethane 2837-89-0 5.8 0.022

HCFC-123 (CHCl2CF3) 1,1-Dichloro-2,2,2-trifluoroethane 306-83-2 1.3 0.02

HCFC-225cb 

(CF2ClCF2CHClF)

1,1,2,2,3-pentafluoro-1,3-

dichloropropane 507-55-1 2.1 0.033

HCFC-225ca 

(CF3CF2CHCl2)

1,1,1,2,2-pentafluoro-3,3-

dichloropropane 422-56-0 5.8 0.025

aODP values are taken from the Montreal Protocol (UNEP 2003b).

3. Overview of HCFC Use in the United States

HCFCs have a variety of applications in the foam, aerosol, solvent cleaning, fire protection, and 

sterilization industry sectors; however, their largest presence is in the AC and refrigeration industries. 

Although the Montreal Protocol has identified numerous HCFCs under Article 2F, only those listed in Box 

3-1 have been consumed in significant quantities in the United States. Starting in 2015, use of virgin 

HCFCs will be limited to refrigeration, AC, and nonresidential fire suppression applications.

Section 3 is organized into three subsections. Section 3.1 provides a brief discussion of projected 

servicing need of HCFCs, including estimates in ODP-weighted metric tons. Section 3.2 presents an 

overview of the HCFC servicing need in the AC and refrigeration sector. Section 3.3 presents an overview 

of the HCFC servicing need for nonresidential fire suppression.
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3.1. Projected HCFC Servicing Need

Servicing need is projected for the following HCFCs: HCFC-22, HCFC-142b, HCFC-123, and HCFC-124.

An overview of the use limitations, applications, and projected servicing need for these HCFCs is included 

in Table 3-2.

Table 3-2. Overview of HCFC Use Limitations, Applications, and Projections for 2015 to 2025

HCFC Regulatory Limitations

Applications Is Need

Projected 

for 2015-

2025?

Notes on Servicing Need

Ref/ AC Projections

NonResidential 

Fire 

Suppression

HCFC-22 Production and import 

limited January 1, 2010 

to use as a refrigerant in, 

or to provide service to, 

appliances 

manufactured prior to 

January 1, 2010.

 -- 

 Estimated based on EPA’s 

Vintaging Model

HCFC-142b

 -- --

 For 2015 and beyond, the 

Vintaging Model projects no 

HCFC-142b servicing need, 

although other data suggests 

that HCFC-142b is still in use 

 HCFC-142b is a component 

of some blends (e.g., R409A*), which are primarily 

used as a retrofit alternative 

to CFC-12 and R-500 in 

refrigeration applications

HCFC-123 Production and import 

will be limited beginning 

January 1, 2015, to use 

as a refrigerant in, or to 

provide service to, 

appliances 

manufactured prior to 

January 1, 2020.

HCFC-123 and HCFC124 can also be used for 

nonresidential fire 

suppression purposes 

between 2015 and 2020.

  

 Estimated based on Vintaging 

Model and other sources

 HCFC-123 is used as a 

refrigerant and as a 

constituent of the Halotron I 

blend used in fire suppression 

applications

HCFC-124

 -- 

 Sterilant use no longer 

allowed

 Projections based on 

Vintaging Model 

 HCFC-124 is used in several 

SNAP-approved refrigerant 

blends (e.g., R-401A, R401B, R-409A*, R-414A, R414B, and R-416A)

*R-409A is not modeled in the Vintaging Model.

Figure 3-1 demonstrates projected HCFC servicing need in 2015 and 2020; as shown, HCFC-22 

servicing needs constitute over 95% percent of all HCFC servicing need in 2015 and over 97% of HCFC 

servicing need in 2020.
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Figure 3-1. Total Projected HCFC Servicing Need for Refrigeration, AC, and Fire Suppression14

(Metric Tons)

3.2. HCFC Use in Refrigeration and Air-Conditioning

Historically, CFCs were extensively used as refrigerants in the AC and refrigeration industries; by the 

1970s, HCFC-22 and R-502 (a blend of CFC-115 and HCFC-22) were also well established refrigerants. 

On January 1, 1996, the production and import of CFC refrigerants, classified as Class I controlled 

(ozone-depleting) substances under the CAA Amendments of 1990, were phased out in the U.S. and 

other industrialized countries. HCFC refrigerants, which deplete the ozone layer to a lesser degree and 

are classified as Class II controlled substances under the 1990 CAAA, were found acceptable as 

substitutes for the controlled CFCs in some end use applications. 

Air-Conditioning End-Uses

AC equipment can be categorized as either mobile or stationary. Figure 3-2 below illustrates these 

categories and identifies those AC end uses for which supply and servicing need projections are 

estimated in this report.

Mobile air-conditioning systems include all forms of AC that provide cooling to passenger

compartments in all types of moving vehicles. This category can be further broken down into motor 

vehicle air-conditioning for light-duty vehicles and other mobile air-conditioning systems.

 Motor vehicle air-conditioning (MVAC) includes AC in the passenger compartments of light duty 

vehicles—both cars and trucks (e.g., pick-up trucks, minivans, sport utility vehicles). A variety of 

refrigerant blends, some of them including HCFCs, are approved for use in the United States by 

EPA as replacements for CFC-12 in MVACs. However, these blends have not been endorsed by 

vehicle or system manufacturers for such use, thereby capturing only a small and declining share 

of the retrofit market, which consists mainly of HFC-134a. HFC-134a is not an ODS; therefore, 

the light-duty MVAC sector is not considered further in this analysis. 

 Other mobile air-conditioning includes AC in the passenger compartments of both buses 

(including school, transit, and tour buses) and trains (including heavy, light, and commuter rail, 

and Amtrak trains).15 Although most bus AC systems converted directly from CFC-12 to HFC134a, the majority of the existing fleet of transit buses, tour buses, and trains are projected to 

continue to use HCFC-22 in their AC systems.

 

14 The estimates for fire suppression demand are based on EPA’s Vintaging Model projections assuming no phaseout of HCFCs for 

fire suppression use between 2015 and 2019.

15 For the purposes of this report, “other mobile AC” does not include ships, planes, RVs, or construction/farm equipment. In the 

case of boats, some HCFC-22 is used in AC systems (UNEP 2003a), but this consumption is accounted for in this report under 

stationary AC equipment, such as packaged terminal units or chillers (Cold Ships 2009). 

HCFC-22

95.5%

HCFC-123

4.5%

HCFC-124

<1%

2015

Total: 48,300 MT

HCFC-22

97.5%

HCFC-123

2.5%

HCFC-124

<1%

2020

Total: 23,100 MT
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Stationary air-conditioning includes a wide variety of equipment, further categorized into the following 

six categories. 

 Unitary air-conditioners and heat pumps include both split systems and packaged units and are 

designed for air circulating, cooling, cleaning, and dehumidifying and sometimes heating in 

residential and small and large commercial applications. While HCFC-22 systems are still in use, 

new systems are largely charged with HFC-134a, R-410A, and R-407C refrigerant blends.

 Chillers regulate the temperature and humidity in offices, hotels, shopping centers, and other 

large buildings. There are two major categories of chillers—centrifugal and positive displacement.

Centrifugal chillers are centralized air conditioning systems typically used in larger buildings (e.g., 

offices, hotels, shopping centers, and other large buildings). Positive displacement chillers are 

smaller and may be water-cooled or air-cooled. There are three principle types of positive 

displacement chillers—1) reciprocating, 2) screw, and 3) scroll—each of which is named for the 

type of compressor employed. HCFC-22 and HCFC-123 chillers are still in use, though a portion 

of the market is transitioning to R-410A, R-407C, and HFC-134a refrigerants. Historically, these 

chillers used CFC-12, CFC-11, CFC-114, and R-500 refrigerants.

 Dehumidifiers are mechanical refrigeration systems designed to remove moisture from the air by 

drawing air first over cold evaporator coils and then warm condenser coils, causing the moisture 

in the air to condense onto the cold coils. Examples include indoor pool dehumidifiers and 

portable units used to dehumidify basements. Existing dehumidifiers still use HCFC-22 and new 

systems have transitioned to HFC-134a and R-410A.

 Water and ground source heat pumps use fluid circulated in a common piping loop as a heat 

source/sink to cool and heat air. Water-source heat pumps typically use water pumped from a 

well, lake, or stream as a heat source/sink. Direct expansion geothermal heat pumps circulate 

refrigerant through piping in the earth. Water and ground source heat pumps historically used 

HCFC-22; new systems are charged with HFC-134a, R-410A, and R-407C.

 Window units, also known as room air-conditioners, are small appliances used to condition the air 

in one room. Window units historically used HCFC-22; new systems are charged with R-410A.

 Packaged terminal units are ACs or heat pumps that are mounted through the wall. They are 

often used in hotel rooms, dormitories, or classrooms, and historically used HCFC-22; new 

systems are charged with R-410A.

Figure 3-2: Types of Air-Conditioning Systemsa

aEPA assumes HCFC refrigerants are not used in MVACs (dashed box); shaded enduses are those for which supply and servicing need projections are estimated in this 

report.

Air-Conditioning (AC) 

Equipment

Motor 

Vehicle AC

Stationary Air-Conditioning

Water and

Ground Source 

Heat Pumps

Dehumidifiers

Residential

Small 

Commercial

Large 

Commercial

Other Mobile 

AC

Mobile Air-Conditioning

Window Units

Packaged 

Terminal AC 

and Heat 

Pumps

Centrifugal

Chillers

Positive 

Displacement

Reciprocating Screw Scroll

Unitary AC and 

Heat Pumps
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Refrigeration End-Uses

Refrigeration equipment can be broken down into four categories: domestic refrigeration, refrigerated 

transport, industrial process refrigeration, and commercial refrigeration. Figure 3-3 below illustrates these 

categories and identifies those end uses for which supply and servicing need projections are estimated in 

this report.

Domestic refrigeration includes household refrigerators, household freezers, combination 

refrigerator/freezer units, and water coolers. For the majority of these equipment types, the refrigerants 

used do not typically include HCFCs or blends containing HCFCs. Older household freezers sometimes 

employed HCFC-22; however, because these units are viewed as a minor part of the domestic 

refrigeration market, this end-use is not further analyzed in this report. 

Refrigerated transport includes refrigeration used in equipment that moves products from one place to 

another and includes refrigerated ship holds, truck trailers (i.e., reefer trucks), railway freight cars, and 

other shipping containers. Refrigerated transport units have historically used R-502 (an HCFC-22 blend), 

but have transitioned to HFC-134a and R-404A.

Industrial process refrigeration (IPR) systems are complex, customized systems used to cool process 

streams in the chemical, food processing, pharmaceutical, petrochemical, and manufacturing industries.

This sector also includes industrial ice machines, equipment used directly in the generation of electricity, 

and ice rinks. IPR systems with HCFC-22, HCFC-123, and HCFC-124 (as R-401A) are still in use though 

a portion of this market has transitioned to HFC-134a, R-404A, R-410A, and R-507A. IPR systems 

historically used CFC-11 and CFC-12.

Commercial refrigeration can be further broken down into three end-uses:

 Cold storage warehouses are refrigeration systems with varying designs and charge sizes. They 

are used to store meat, produce, dairy products, and other perishable goods before and after 

food processing. Cold storage units historically used CFC-12, R-502, and HCFC-22 refrigerants; 

new systems are charged with R-404A and R-507A.

 Retail food systems are used to refrigerate food in commercial retail establishments, such as 

grocery stores. These systems can be classified as either centralized systems, condensing units,

or self-contained units. Centralized retail food systems, also known as remote systems, consist of 

a series of compressors located in a remote machinery room, providing a cooling medium to 

display cabinets and cold storage rooms in other parts of the building. The most common form of 

centralized systems circulate refrigerant throughout the store. Alternatives to these types of 

systems include secondary loop and distributed systems that largely use HFC refrigerant blends. 

These large retail food systems historically used CFC-12 and R-502 refrigerants; new systems

have transitioned to R-404A, R-507A, and R-407A. Condensing units are large- or small-size 

refrigeration equipment with one or two compressors and a condenser installed on the roof or in a 

small machine room. Examples include walk-in refrigerators, coolers, and freezers. Condensing 

units historically used HCFC-22; new systems are charged with R-404A, HFC-134a, and R-507A 

refrigerants. Self-contained retail food units, also referred to as stand-alone systems, are factory

produced with all the components integrated. Examples include roll-in refrigerators/freezers, 

under-counter refrigerators/freezers, reach-in refrigerators/freezers, wine and beer coolers, ice 

cream machines, beverage vending machines, and a variety of stand-alone upright or horizontal 

display cases (e.g., beverage merchandisers, deli cases). Self-contained refrigeration units 

historically used CFC-12 refrigerants and have transitioned to HFC-134a, R-404A, R-507A, and 

CO2 refrigerants. HCFCs were never used in this application.

 Ice makers are factory-made units used in commercial establishments to produce ice for 

consumer use (e.g., in hotels, restaurants, and convenience stores). Ice makers are not further 

analyzed in this report because they do not typically employ HCFCs or blends containing HCFCs.

Ice makers moved directly from CFC-12 to HFC-134a.
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Figure 3-3: Types of Refrigeration Systemsa

aS

aDashed boxes cover end-uses that are assumed to not use HCFC refrigerants; shaded end-uses are those for which supply and servicing 

need projections are estimated in this report.

Table 3-3 presents projected estimates of HCFC refrigerant servicing need for the refrigeration and AC 

industries. As shown, HCFC-22 represents the majority of the refrigeration and AC market for 2015 to 

2025. The Vintaging Model also projects continued use through 2020 for HCFC-124 and through 2025 

and beyond of HCFC-123 as a refrigerant in, or to provide service to, equipment manufactured prior to 

January 1, 2020. Although the Vintaging Model does not project servicing need for HCFC-142b in the 

2015-2025 timeframe, other information suggests that HCFC-142b is still in use in niche refrigerant 

blends. More detail on the projected use of each HCFC in refrigeration and AC applications is provided in 

the following table.

Table 3-3: Projected HCFC-22, HCFC-142b, HCFC-123, and HCFC-124 Need for 

Refrigeration and Air-Conditioning, 2015-2025 (Metric Tons)

a

HCFC 2015 2016 2017 2018 2019 2020 2025

HCFC-22 46,100 41,600 36,700 32,300 27,700 22,500 5,500

HCFC-123 2,200 2,200 2,200 2,200 2,300 600 500

HCFC-124 5 5 5 4 4 3 -

HCFC-142b - - - - - - -

Source: Based on modeling assumptions from EPA (2012).

aChanges to assumptions in the Vintaging Model since the 2009 Servicing Tail Report have increased projected servicing need. For more 

detail on the changes, please see Appendix C.

 HCFC-22—Projected HCFC-22 servicing need from 2015 onward is for AC and refrigeration 

applications. AC applications include window units, packaged terminal units, residential and 

commercial unitary AC, chillers, dehumidifiers, water and ground source heat pumps, and nonlight duty mobile AC in buses, trains, etc. Refrigeration applications include refrigerated 

transportation, industrial process refrigeration, and commercial retail food. HCFC-22 is used as 

both a stand-alone refrigerant as well as a component in refrigerant blends.

 HCFC-123—HCFC-123 is used in the refrigeration and AC sector mainly in centrifugal chillers for 

industrial process refrigeration and commercial comfort AC. The production and import of virgin 

HCFC-123 is scheduled for phaseout in 2020 for use in new AC and refrigeration equipment, and 

in 2030 for use in AC and refrigeration equipment manufactured before January 1, 2020.

 HCFC-124—HCFC-124 is minimally used as a refrigerant; its primary use as a refrigerant is in 

blends, mainly R-401A, in industrial process and transport refrigeration equipment, as well as R409A and R-414B in commercial refrigeration applications. As a stand-alone refrigerant, it has 

found some niche applications that reach high condensing temperatures as well as an alternative 

for CFC-114 in some naval chillers. Starting in 2020, virgin HCFC-124 can no longer be used in 

new AC and refrigeration equipment. Starting in 2030, virgin HCFC-124 can no longer be

produced or imported to service existing AC and refrigeration equipment. However, its use in 

blends R-401A, R-401B, R-409A, R-414A, R-414B and others is constrained because those 

blends also contain HCFC-22. Starting in 2020, HCFC-22 will not be produced or imported for 

use in these blends. HCFC-124 is also a component of R-416A, which does not contain any other 

Refrigeration Equipment

Domestic Refrigeration Refrigerated 

Transport

Industrial 

Process 

Refrigeration

Commercial 

Refrigeration

Cold 

Storage

Ice 

Makers

Retail

Food 

Household 

Refrigerators

Household 

Freezers

Water 

Coolers
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Box 3-2: Summary of Several HCFCs used in Refrigerant Blends

Often refrigerants are formulated with several substances, such as hydrofluorocarbons (HFCs) or hydrocarbons (e.g., 

propane, butane, isobutane). Table 3-4 presents the composition of some of the more common refrigerant blends containing 

HCFCs. 

Table 3-4: Compositions of Common HCFC Refrigerant Blends (percent by weight)

Blend HCFC-22 HCFC-124 HCFC-142b HCFC-123 Other

R-401A 53% 34% 13% HFC-152a

R-402A 38% 60% HFC-125, 2% propane (R-290) 

R-409A 60% 25% 15%

R-502 48.8% 51.2% CFC-115

End-uses in which these refrigerant blends containing HCFCs are currently used are presented in the Table 3-5.

Table 3-5: HCFC-Containing Refrigerant Blends by End-Use

Refrigeration Equipment 

Type

Refrigerant Type

R-401A R-402A R-409A R-502

Retail Food x x x x

Cold Storage x x x

IPR x

Transport Refrigeration x x x

ODS. While feedback from several industry sources indicates there are a minimal number of 

legacy systems still in use, the number is declining (U.S. HCFC Manufacturer Representatives

2013). 

 HCFC-142b—HCFC-142b is used as a constituent of a few refrigerant blends that have 

historically served as replacements for CFC-12 and R-500 (a blend containing CFC-12 and HFC152a) medium-sized refrigeration equipment. Based on refrigerant sales data collected by the 

California Air Resources Board (see Preliminary 2011 and 2012 Sales and Distribution Data from 

the California Air Resources Board’s Refrigerant Management Program in the docket) and 

information provided by stakeholders, R-409A (composed of HCFC-22, HCFC-124, and HCFC142b) and R-414B (composed of HCFC-22, HCFC-124, HCFC-142b and R-600a) are the most 

common refrigerant blend using HCFC-142b. Although servicing need for R-409A, R-414B and 

some other niche refrigeration needs are not currently modeled in the Vintaging Model, these 

sources indicate there is continuing, albeit decreasing, servicing need for HCFC-142b refrigerant 

blends.

Box 3-2 presents a brief summary of HCFCs used in refrigerant blends.16

3.3. HCFC Use in Nonresidential Fire Suppression

Fire-extinguishing applications can be divided into two categories: portable fire extinguishers (i.e., 

streaming applications) that originally used Halon 1211, and total flooding applications that originally used 

Halon 1301 or Halon 2402 (EPA 2006). The Significant New Alternatives Policy (SNAP) program 

approved the use of HCFC-22, HCFC-123, and HCFC-124 in total flooding and streaming applications; 

 

16 HCFC consumption data presented in this analysis include quantities consumed in blends by employing the percent composition 

of the corresponding HCFC constituent(s) of that blend. In order to accurately portray the number of units containing HCFC blends, 

however, blends are not disaggregated when presenting the number of units of equipment (i.e., a unit running on an HCFCcontaining blend counts as one unit). 
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however, only HCFC-123 and HCFC-124 are used as streaming agents in practice (EPA 2012). HCFC123 is the primary constituent in Halotron I (also referred to as HCFC Blend B in EPA regulations). 

Specifically, the blend Halotron I is used in commercial/industrial, maritime, and military applications in the 

United States (Halotron 2008). HCFC-124 has some niche fire protection applications for specialty marine 

systems (pleasure boats) from the 1990s that may still be in use but are not modeled by the Vintaging 

Model. HCFC-124 was primarily used in Europe for fire suppression applications (Hughes Associates, 

Inc., 2012). This analysis considers fire suppression applications using HCFC-123 only.

In December 2011, House Resolution (HR) 1540 was signed into public law. Section 320, Fire 

Suppression Agents, amends section 605(a) of the Clean Air Act to allow HCFCs to continue to be used 

after 2015 for nonresidential fire suppression purposes. Production and import of HCFCs for fire 

suppression can continue until January 1, 2020, when Article 2F of the Montreal Protocol limits any 

continued consumption of HCFCs to servicing of refrigeration and AC equipment only. Table 3-5 presents 

projected servicing need estimates for HCFC-123.17

Table 3-5: Projected HCFC-123 Need for Fire Suppression, 2015-2025 (Metric Tons)

HCFC 2015 2016 2017 2018 2019 2020 2025

HCFC-123 190 200 200 210 210 - -

Source: EPA (2012).

Alternatives to HCFCs in the fire extinguishing industry include HFCs such as HFC-236fa; some members 

of the industry have begun transitioning to non-ODS alternatives (EPA 2012).

 

17 The Vintaging Model does not yet reflect the amendment to section 605(a) of the Clean Air Act; however, a scenario assuming no 

phaseout was run to estimate the use of Halotron I, and was compared to industry information for consistency.
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4. Projected HCFC Scenarios 

Section 4 presents projections of the number of HCFC-containing units of equipment and the associated 

servicing needs for 2015 through 2025. Scenarios were developed by investigating various trends that 

are expected to affect future market needs. Such trends include changes in charge sizes, the transition to 

alternative refrigerants, changes in refrigerant recovery and reuse practices, and HCFC economics. 

 Section 4.1 summarizes the projected market size of equipment and the servicing need for

HCFC-22 beyond 2015 in the United States.

 Section 4.2 summarizes the projected market size of equipment and servicing need for HCFC123 beyond 2015 in the United States.

 Section 4.3 summarizes the projected market size of equipment and servicing need for HCFC124 beyond 2015 in the United States.

 Section 4.4 provides discussion on anticipated HCFC-142b servicing needs based on stakeholder

feedback.

 Section 4.5 discusses the various sources of HCFCs that can be used to meet servicing need, 

including recycled, reclaimed, and imported (used) HCFCs as well as interpollutant transfers of 

allowances.

 Section 4.6 provides projections of servicing need that can be met by reuse and recovery based 

on three different recovery scenarios.

 Section 4.7 discusses factors that may affect projections of servicing need and recovery, 

including: certain equipment specification requirements, the transition to alternative refrigerants, 

and the stockpiling of refrigerant.

Appendix B presents further detail on the estimates provided in Section 4, disaggregating HCFC-22,

HCFC-123, and HCFC-124 containing equipment and overall servicing need estimates into end-use 

specific projections.

4.1. HCFC-22

The HCFC-22 equipment and servicing need estimates provided below were developed using EPA’s 

Vintaging Model (EPA 2012). Appendix A provides more detail on the methodology used to develop these 

projections. Appendix B provides projections disaggregated by end-use.

4.1.1. HCFC-22 Equipment Used Beyond 2015 

The only HCFC-22 equipment that is projected to be in use (i.e., within the installed base) from 2015

onward will be used for refrigeration and AC applications, including window units, packaged terminal 

units, residential and commercial unitary AC, chillers, dehumidifiers, water and ground source heat 

pumps, non-light duty mobile AC in buses and trains, retail food, industrial process refrigeration, and 

transport refrigeration equipment. As presented in Table 4-1, approximately 95.8 million units of AC 

equipment will be in use in 2015, decreasing from 2015 levels by about 79 percent by 2020, and by over 

99 percent by 2025. Approximately 976,600 units of refrigeration equipment will be in use in 2015.

18 The 

installed base of refrigeration equipment is projected to decrease from 2015 levels by about 52 percent by 

2020 and 85 percent by 2025. 

Table 4-1: Projected Number of HCFC-22 Units (2015-2025)

a,b

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total AC 95,814,200 81,732,700 67,286,500 52,551,500 37,024,700 20,592,800 330,100

Total Refrigeration 976,600 852,700 734,000 639,300 549,900 467,500 145,600

Total 96,790,800 82,585,400 68,020,500 53,190,800 37,574,600 21,060,300 475,700

a

Including units that use blends containing HCFC-22.

bBecause the estimates for cold storage warehouses are expressed in cubic feet, this equipment type is not included in this table. 

Source: Based on modeling assumptions using EPA (2012).

 

18 This estimate is not inclusive of cold storage warehouses.
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Box 4-1: Sensitivity Analysis on Key Assumptions Affecting 

HCFC-22 Servicing Demand

System Charge Sizes: This sensitivity analysis explores the 

impacts of a lower 4 kg charge size for 13 SEER HCFC-22 

residential unitary AC equipment rather than the current 

assumption of approximately 4.8 kg. This change reduces 

HCFC-22 servicing need by about 2-7 percent per year from 

2015 to 2023.

Leak Rates: Leak rates for residential unitary AC, large and 

medium retail food refrigeration, and cold storage units may be 

lower as a result of partnership programs such as GreenChill and 

more careful servicing. Lower loss rates can reduce HCFC-22 

servicing need by about 10-23 percent per year between 2015 

and 2025.

Lifetimes: The ban on HCFC-22 in new equipment 

manufactured after 2010 and price increases for HCFC-22 are 

likely to have prompted some end-users to transition away from 

HCFC-22 equipment earlier than the end of the equipment’s 

lifetime. This sensitivity analysis explores the impact on servicing 

need if 20 percent of residential unitary AC, industrial process 

refrigeration units, and retail food equipment transitions out of 

HCFC-22 five years earlier. These changes can reduce HCFC22 servicing need by 9-14 percent per year between 2015 and 

2025.

4.1.2. Projected HCFC-22 Servicing Needs

Refrigeration and AC equipment commonly requires servicing, which may include adding refrigerant to 

account for refrigerant losses that occur over time.19 While the production and import of HCFC-22 was

banned for use in new appliances in 2010, it may be permitted for servicing and maintenance purposes 

until January 1, 2020. Table 4-2 presents projected HCFC-22 servicing need (including that used in 

blends) for servicing equipment in 2015, 2020, and 2025. 

As shown in Table 4-2, approximately 46,100 metric tons of HCFC-22 are projected to be required to 

service AC and refrigeration equipment in 2015, of which the majority—27,900 metric tons (61%)—will be 

used to service AC systems. EPA projects that servicing need for HCFC-22 in AC and refrigeration 

equipment will decrease to 22,500 metric tons by 2020 and 5,500 metric tons by 2025. The 2015 

projections of servicing need exceed the U.S. consumption cap for virgin HCFCs; however, a portion of 

the servicing needs can be met by using recovered refrigerant, thus decreasing the need for virgin HCFC22.

Table 4-2: Projected HCFC-22 Servicing Need (2015-2025) (Metric Tons)

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total AC 27,900 24,900 21,600 18,400 14,900 11,100 360

Total Refrigeration 18,200 16,700 15,100 13,900 12,700 11,400 5,200

Overall Total 46,100 41,600 36,700 32,300 27,700 22,500 5,500

Source: Based on analysis using EPA (2012).

Note: Totals may not sum due to independent rounding.

While assumptions in EPA’s Vintaging Model 

are continually updated to refine inputs, the 

projections of future servicing needs for HCFC22 can be affected by outside factors that are 

not fully reflected in the estimates. In addition, 

as HCFC use decreases and the phaseout 

approaches, modeling with precision becomes 

more difficult. In recognition of these challenges, 

sensitivity analyses on the impact of key 

assumptions on HCFC-22 servicing need were 

conducted in response to information from 

stakeholders. As described in Box 4-1, altering 

assumptions about system charge sizes, leak 

rates, and lifetimes can modestly to significantly 

decrease projected servicing need. For 

example, more careful servicing practices that 

result in lower loss rates can reduce servicing 

need by up to 23 percent per year past 2020. 

Additional details on these sensitivity analyses 

are presented in Appendix D. 

Figure 4-1 displays the breakdown of HCFC-22 

servicing need by AC and refrigeration 

equipment type for 2015 and 2020. As shown, 

residential AC, retail food refrigeration 

equipment, and IPR are projected to account for over 90 percent of HCFC-22 servicing need in 2015. By

2020, these three end-uses are still projected to account for 90 percent of HCFC-22 servicing need

although IPR’s portion of servicing need is slightly higher than 2015 and residential AC is slightly lower. 

This trend is partly the result of the modeled lifetimes for these end uses; EPA assumes an average 

 

19 The servicing need estimates projected in this analysis include refrigerant to replace quantities that leak from operating equipment 

as well as de minimis losses that may occur while servicing operating equipment.
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lifetime for residential AC of 15 years, while IPR systems are assumed to last 25 years. Differences 

between modeled average lifetimes and practiced lifetimes can impact actual servicing need for 

residential and AC equipment, as examined further in Box 4-1.

Figure 4-1: HCFC-22 Need for Servicing Refrigeration and AC Equipment, by End-Usea

aOther Equipment” includes window units, packaged terminal units, water and ground source heat pumps, other mobile AC, and 

refrigerated transport.

Source: Based on data analysis using EPA (2012).

4.2. HCFC-123

The HCFC-123 equipment and servicing need estimates provided below were developed using EPA’s 

Vintaging Model (EPA 2012). Appendix A provides more detail on the methodology used to develop these 

projections. Appendix B provides projections disaggregated by end-use.

4.2.1. HCFC-123 Equipment Used Beyond 2015

HCFC-123 is used in the refrigeration and AC sector mainly in centrifugal chillers for industrial process 

refrigeration and commercial comfort AC. The production and import of virgin HCFC-123 can be 

continued for use in refrigeration and AC equipment manufactured prior to 2020; by 2020 its remaining 

permissible use is for the servicing of this equipment until 2030, when all production and import is 

banned. A 2011 amendment to section 605(a) of the Clean Air Act also allows HCFC-123, a component 

of Halotron I, to be used for nonresidential fire suppression applications. Halotron I is used for 

commercial/industrial, maritime, and military applications in the United States (Halotron 2008).

Stakeholders consulted for this report indicated that there are currently no chemical substitutes for 

Halotron I. While bromotrifluoropropene (BTP) has been explored for use in the aviation sector, it is 

reportedly more toxic and expensive than Halotron I and, as such, is not regarded as a viable substitute. 

Stakeholders indicated that they plan to sell extinguishers with virgin material until 2019 and to continue 

selling extinguishers with recycled material in 2020 and beyond.

2020

Total Consumption for Servicing: 22,500 MT

2015

Total Consumption for Servicing: 46,100 MT
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As presented in Table 4-3, approximately 47,600 units of AC equipment using HCFC-123 are estimated 

to be in use in 2015. The number of HCFC-123 AC units is projected to decrease from 2015 levels by 16 

percent by 2025. Approximately 12,600 units of HCFC-123 refrigeration units are estimated to be in use 

in 2015, decreasing by approximately 5 percent by 2025. EPA estimates 1,422,100 Halotron fire 

suppression units in use in 2015, which is expected to decrease to 871,100 by 2025. This estimate for fire 

suppression is similar to the estimated of number of units provided by a stakeholder in the industry.

Table 4-3: Projected Number of HCFC-123 Refrigeration, AC, and Fire Suppression Units (2015-

2025)

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total AC 47,600 48,900 50,400 50,900 51,400 49,500 39,800

Total Refrigeration 12,600 13,300 13,900 14,400 14,800 14,300 12,000

Fire Suppression 1,422,100 1,464,800 1,508,700 1,554,000 1,600,600 1,487,800 871,100

Total 1,482,300 1,527,000 1,573,000 1,619,300 1,666,800 1,551,600 922,900

Source: Based on analysis using EPA (2012).

4.2.2. Projected HCFC-123 Needs

Table 4-4 presents projected HCFC-123 need for charging and servicing equipment before 2020 and for 

servicing equipment only after 2020. Table 4-4 also provides the projected HCFC-123 servicing need for 

nonresidential fire suppression systems from 2015 to 2020. In 2015, approximately 2,200 metric tons of 

HCFC-123 will be required for servicing and charging refrigeration, AC, and fire suppression units, of 

which the majority—1,200 metric tons (55%)—will be used to service AC systems. Servicing need for 

HCFC-123 in AC and refrigeration equipment is projected to decrease to 470 metric tons by 2025. The 

Montreal Protocol prohibits the production and import of virgin HCFCs for fire suppression beginning

January 1, 2020, thus fire suppression servicing need is modeled as zero after this date.

Table 4-4: Projected HCFC-123 Refrigeration and AC Servicing Need (2015-2025) (Metric Tons)

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total AC 1,200 1,200 1,200 1,200 1,200 220 180

Total Refrigeration 770 800 830 850 860 370 290

Total Fire Suppression 190 200 200 210 210 - -

Overall Total 2,200 2,200 2,200 2,200 2,300 600 500

Source: Based on analysis using EPA (2012).

Note: Numbers may not sum due to independent rounding.

4.3. HCFC-124

HCFC-124 servicing need is projected by the Vintaging Model through 2020 (EPA 2012). Appendix B 

provides projections disaggregated by end-use.

4.3.1. HCFC-124 Equipment Use Beyond 2015

HCFC-124 is used in the refrigeration sector mainly in industrial process refrigeration and medium retail 

food refrigeration (small condensing units). The production and import of virgin HCFC-124 can be 

continued for use in refrigeration equipment manufactured prior to 2020; by 2020 its remaining 

permissible use is for the servicing of this equipment until 2030, when all production and import is 

banned. 

As presented in Table 4-5, approximately 27,400 units of refrigeration equipment using HCFC-124 are 

estimated to be in use in 2015. The number of HCFC-124 refrigeration units is projected to decrease to 

zero by 2025. 
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Table 4-5: Projected Number of HCFC-124 Refrigeration Units (2015-2025)

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total Refrigeration 27,400 26,500 25,200 23,500 21,400 18,900 -

Total 27,400 26,500 25,200 23,500 21,400 18,900 -

Source: Based on analysis using EPA (2012).

4.3.2. Projected HCFC-124 Needs

Table 4-6 presents projected minimal HCFC-124 need for charging and servicing equipment before 2020 

and for servicing equipment only after 2020. In 2015, approximately 4 metric tons of HCFC-124 will be 

required for servicing and charging refrigeration units. Servicing need for HCFC-124 in AC and 

refrigeration equipment is projected to decrease to zero metric tons by 2025. 

Table 4-6: Projected HCFC-124 Refrigeration Servicing Need (2015-2025) (Metric Tons)

Equipment Type 2015 2016 2017 2018 2019 2020 2025

Total Refrigeration 5 5 5 4 4 4 -

Total 5 5 5 4 4 4 -

Source: Based on analysis using EPA (2012).

While the Vintaging Model predicts minimal servicing need for HCFC-124, feedback from stakeholders

and refrigerant sales data collected by the California Air Resources Board indicates the servicing need 

may be higher than projected (see Preliminary 2011 and 2012 Sales and Distribution Data from the 

California Air Resources Board’s Refrigerant Management Program in the docket). This difference is in 

large part a result of servicing need for R-409A and R-414B in refrigeration applications, which is not 

modeled in the Vintaging Model.

4.4. HCFC-142b

HCFC-142b is predominantly used in refrigerant blends that serve as replacements for CFC-12 and R500 medium-sized refrigeration equipment. The production and import of virgin HCFC-142b is allowed 

until 2020 for servicing refrigeration equipment manufactured prior to 2010. 

The Vintaging Model projects that servicing need for HCFC-142b will be zero after 2015 (EPA 2012); 

however, the Model does not include servicing need for some niche HCFC-142b blends such as R-409A. 

According to refrigerant sales data collected by the California Air Resources Board, R-409A equipment is

still in use (see Preliminary 2011 and 2012 Sales and Distribution Data from the California Air Resources 

Board’s Refrigerant Management Program in the docket). HCFC manufacturers have also indicated that 

there will be continued, declining need for HCFC-142b in niche refrigerant blends beyond 2015.

4.5. HCFC Sources

Since January 1, 2010, only existing sources of HCFC-22 and a controlled quantity of virgin HCFC-22 

(limited through allowance allocations distributed by EPA) are available to the AC and refrigeration 

industry to meet servicing need.

20 Virgin HCFC-123 and HCFC-124 will be permitted for use in appliances

manufactured prior to January 1, 2020 and virgin HCFC-142b will be permitted for use in appliances

manufactured prior to January 1, 2010. Beyond 2020, only existing sources of HCFC-123 and HCFC-124, 

and a controlled quantity of virgin HCFC-123 and HCFC-124 (limited through allowance allocations 

distributed by EPA), will be made available to meet servicing need. Existing sources of HCFCs for 

servicing equipment include: 

 

20 Virgin HCFC-22 may be stored as inventory; however, the extent to which this activity may occur is unknown. A discussion on 

inventorying plans is covered in Section 4.5.4.
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1. HCFC refrigerants that are recovered and either recycled or reclaimed before reuse. Under 

EPA regulations at 40 CFR 82.156, refrigerants containing HCFCs must be recovered. After the 

recovery process, the refrigerant held in the storage container may be:21

a. Recycled (i.e., cleaned through the use of recycling equipment) and recharged back into 

the equipment from which it came;

b. Recycled and used in other equipment of the same owner; or

c. Reclaimed (shipped to an EPA-certified reclaimer) prior to resale to a new owner.

2. Import of used HCFCs that companies can acquire, if the import is preauthorized by EPA, 

through a petition process.

3. The conversion of allocations from other chemicals to HCFCs as allowed under the final 

allocation rules.

Each of these existing sources of HCFCs is described in more detail below. 

Recycled HCFC Refrigerants

Recovered HCFC refrigerants are often recycled prior to being used again in equipment. The recycling 

process cleans the refrigerant for reuse without meeting all the requirements of reclamation, discussed 

further below. HCFC refrigerants are commonly recovered from a piece of equipment, adequately 

cleaned, and then recharged into the same piece of equipment using a recycling device (EPA 2003b).

EPA regulations allow for the recharge of used refrigerant without subsequent reclamation for refrigerants 

that are recovered and charged back into the same appliance or to another appliance if those appliances 

have the same owner. Several companies, such as supermarket chains, employ recycling plans through 

which the refrigerant is recovered when dismantling or converting one establishment’s equipment and 

reused to service equipment at another facility with the same ownership. Stakeholder feedback has 

indicated that recovery and direct reuse is a widespread practice amongst supermarkets in large retail 

food equipment (ICF 2011). Some supermarkets have sufficient recovered HCFC-22 in-stock for servicing 

such that there is no anticipated need for virgin material before their equipment is retired (ICF 2011). EPA 

does not collect quantitative data on the amount of HCFC-22, HCFC-123, HCFC-124, or HCFC-142b that 

is recycled.

Reclaimed HCFC Refrigerants

Refrigerants that are resold to be used in other equipment must be reclaimed to a standard level of purity 

based on the AHRI Standard 700. EPA certified reclaimers are approved to reprocess used refrigerant to 

at least the purity level based on the AHRI 700 Standard.

In 2012, the amount of HCFC-22 reclaimed by EPA-certified reclaimers totaled approximately 4,264

metric tons, or 9.4 million pounds (EPA 2013). Reclamation of HCFC-22 increased by approximately 13 

percent between 2011 and 2012; the higher price of HCFC-22 is a likely factor in encouraging increased 

reclamation of the refrigerant. Fewer quantities of the refrigerant blend R-502, composed of 48.8 percent 

HCFC-22 and 51.2 percent CFC-115, are also being reclaimed, with only 14 metric tons, or 30,748

pounds reported for 2012 (EPA 2013).22 The amount of HCFC-123 reclaimed in 2012 totaled 

approximately 143 metric tons, or 316,340 pounds (EPA 2013). Reclamation data from 2003 to 2012 is 

presented in Table 4-7.

 

21 Recovered refrigerants may also be destroyed through the use of environmentally-acceptable technologies that meet the 

definition of destruction in 40 CFR 82.3 (i.e., liquid injection incineration, reactor cracking, gaseous/fume oxidation, rotary kiln 

incineration, cement kilns, and radio frequency plasma) (EPA 2003b).

22 Feedback received from a stakeholder in response to the NODA indicated that because R-502 is an azeotropic blend, it is difficult 

and expensive to separate HCFC-22 from the blend, and hence such separation is very limited (National Refrigerants 2006).
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Table 4-7: Reclaimed HCFC-22 and HCFC-123 by Year (Metric Tons)

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

HCFC-22 1,976 3,280 2,800 3,872 3,716 4,556 3,422 3,622 3,776 4,264

R-502 41 48 25 52 34 40 62 13 19 14

HCFC-123 50 114 145 144 103 124 198 165 154 143

 Note: HCFC-124 and HCFC-142b reclamation data is not available.

 Source: EPA (2013).

As 2015 approaches, both the price of HCFC-22 and reclamation of HCFC-22 may increase.

Stakeholders report reclamation capacity of 19,700 MT or more that can be mobilized to meet service 

need, should the price of HCFC-22 increase or the availability of HCFC-22 decrease sufficiently to 

provide increased market incentive for recovery and reclamation (ICF 2011). A more detailed discussion 

on HCFC-22 economics and recovery and reuse practices is provided in Section 4.5, “Factors Affecting 

Projections.”

Imports of Used HCFCs

Unlike virgin HCFCs, used HCFCs are not subject to Montreal Protocol or Clean Air Act restrictions on 

consumption or use.

23 However, in creating the allocation system for the use of HCFCs, EPA developed a 

shipment-by-shipment petition process for importing used HCFCs as described in 40 CFR 82.24 (EPA 

2003a).The petition process ensures that HCFCs have been used (and were not newly produced) prior to 

import. For each shipment of used HCFC greater than five pounds, the importer needs to petition EPA at 

least 40 working days before the shipment is to leave the country of export. EPA reviews and verifies data 

in the petition and issues either an objection notice or a non-objection notice to the prospective importer. 

The projections in this report do not specifically include the potential future quantities obtained from the 

import of used HCFC-22, HCFC-123, HCFC-124, or HCFC-142b. 

Interpollutant Transfers of Allowances

Another source of HCFCs can result from allowance holders transferring their allowances from one HCFC 

to HCFC-22, HCFC-123, HCFC-124, or HCFC-142b which is permitted on an annual and ODP-weighted 

basis. Section 607 of the Clean Air Act permits year-by-year inter-pollutant transfers of production and 

consumption allowances. Section 607(b) requires that EPA’s rules are to permit “a production allowance 

for a substance for any year to be transferred for a production allowance for another substance for the 

same year,” plus a 0.1 percent offset to benefit the environment. For example, converting 10,000

allowances of HCFC-124 (with an ODP of 0.022) would result in 3,996 allowances of HCFC-22 (with an 

ODP of 0.055). Allowance holders have converted their allowances to meet market needs historically; this 

practice is expected to continue, however, the projections in this analysis do not quantitatively assess the 

potential future quantities that could be obtained from converted allocations.

4.6. Meeting Refrigeration and AC Service Need

Although limited production of virgin HCFCs may be allowed to service appliances until 2020 and 2030 

through production and consumption allowances, this analysis indicates that, with industry effort, a 

significant portion of the need for HCFCs for servicing can be met with previously used refrigerant that is 

recovered and then recycled or reclaimed. Increased amounts of recovered HCFCs are a source made 

available as a result of the venting prohibition EPA has established under Section 608 of the CAA (EPA 

2004a). 

To determine the potential amounts of used refrigerant available to service equipment, EPA used its 

Vintaging Model to develop three theoretical scenarios, representing low, baseline and high recovery, to 

estimate: 1) the amount of recovered HCFCs potentially available to meet servicing need of other 

equipment still in use; and 2) the subsequent remaining quantity needed to satisfy servicing need. The 

three scenarios investigated are summarized in Table 4-8. Because no servicing need is projected in the 

Vintaging Model for HCFC-142b, no recovery scenarios are modeled for this HCFC.

 

23 “Used controlled substances” are controlled substances that have been recovered from their intended use systems (which may 

include controlled substances that have been, or may be subsequently, recycled or reclaimed) (EPA 2003a).
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As shown, for HCFC-22, different recovery rates are modeled for the baseline, lower, and higher recovery 

scenarios. For HCFC-123 and HCFC-124, the recovery rate modeled by the Vintaging Model is used for 

all three scenarios. The baseline recovery rates for HCFC-123 and HCFC-124 are significantly higher (90 

percent for HCFC-123 and between 80 and 90 percent for HCFC-124) than for HCFC-22, given HCFC123 and HCFC-124’s primary use in larger systems, including chillers, IPR, and medium retail food.

Table 4-8: Summary of Recovery Scenarios

Scenario Assumptions for 2015-2025

HCFC-22 HCFC -123 and HCFC-124

Lower Recovery

35 percent of refrigerant from retired or retrofitted equipment is 

recovered and available for reuse in equipment (i.e., a 35 percent 

recovery rate). The remaining 65 percent is not available for reuse. The percentage of refrigerant from 

retired or retrofitted equipment that 

is available for reuse in equipment 

is equal to the recovery rate 

modeled by EPA’s Vintaging Model

(approximately 80 to 90% industrywide).

Baseline Recovery

The percentage of refrigerant from retired or retrofitted equipment 

that is available for reuse in equipment is equal to the recovery rate 

modeled by EPA’s Vintaging Model (approximately 50% industrywide).

Higher Recovery

65 percent of refrigerant from retired or retrofitted equipment is 

recovered and available for reuse in equipment (i.e., a 65 percent 

recovery rate). The remaining 35 percent is not available for reuse.

Note: HCFC-123 has a recovery rate of 90% and HCFC-124 has a baseline recovery rate of 80%.

In developing the scenarios using the Vintaging Model, EPA projected the amount of recovered HCFC

based on the quantity available from decommissioned or retrofitted equipment. While refrigerant 

recovered from equipment during servicing can also be available for reuse in other equipment, this 

potential source is not included in these scenarios for several reasons. First, it is projected to be minimal

in net terms (i.e., refrigerant recovered during service would likely be returned to the same equipment 

from which it was recovered). Also, according to industry sources, refrigerant recovered during service 

events primarily originates from commercial and industrial equipment (i.e., equipment with relatively large 

charges). Refrigerant is rarely recovered during the servicing of small equipment because these units 

tend not to be overcharged or leaking (Home Energy Center 2006, Airgas 2006). Additionally, only a 

small portion of all servicing events conducted on commercial and industrial equipment involve the 

refrigerant circuit, and when recovering refrigerant to perform repairs is necessary, often only a section of 

the refrigerant charge is isolated and recovered, not the entire charge.

To estimate refrigerant recovery and reuse, EPA assumed that a certain percentage of refrigerant is 

recovered from decommissioned or retrofitted equipment.24 It is important to note that not all refrigerant is 

assumed to be recovered. While EPA has regulations prohibiting intentional venting, for the purposes of 

this analysis it is appropriate to create scenarios that assume less than the full charge of refrigerant is 

recovered at equipment end-of-life. For example, in many instances, equipment is disposed of after a 

catastrophic failure, which might have resulted in a large or even complete loss of the refrigerant. Also, 

when equipment is removed from service, there can be losses associated with previous leaks and during 

attempts to recover the remaining refrigerant. It is also possible that owners or technicians disposing of a 

piece of equipment might not comply with the regulations and might vent the refrigerant. 

This analysis then assumes that the entire pool of recovered refrigerant re-enters the market (see 

Appendix A for more details) and can be used to meet a portion of the servicing need for HCFCs. The

results of the three recovery scenarios are presented in the sections that follow.

4.6.1. Servicing Need and Recovery Projections for HCFC-22

Table 4-9 to Table 4-11 summarizes the projections for HCFC-22 under each recovery scenario. Table 

4-9 shows that modeled HCFC-22 supplied from recovery or reuse that is available under a Lower 

Recovery Scenario would meet 32 percent of servicing need in 2015, 72 percent in 2020, and 100 

 

24 To calculate the amount recovered, the Vintaging Model assumes equipment contains a full charge at disposal and assumes a 

certain percent of that is recovered. It does not take into account a) refrigerant destroyed after equipment is decommissioned or b) 

any inventory of recovered refrigerant banked beyond a one-year timeframe. See Appendix A for further details.
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percent of servicing need by 2023. Under this scenario, the quantity of recovered HCFC-22 projected to 

be available before 2023 is inadequate to meet all of the projected servicing need. Given the ban on 

remaining production and import of virgin HCFC-22 in 2020, these modeling results suggest that industry 

may face a shortfall for 2020, 2021, and 2022. Shortfalls in 2015 and 2016 also exist based on limits set 

under the Montreal Protocol (see Section 4.6.4).

For the Baseline Recovery Scenario (

Table 4-10) and Higher Recovery Scenario (Table 4-11), the modeled amount of recovered material is 

sufficient to meet total servicing need for HCFC-22 equipment starting in 2020 and 2019, respectively. In 

the Baseline Recovery and Higher Recovery Scenarios, the amount of recovered material is more than 

double the servicing need starting in 2024 and 2023, respectively. 

As noted in Section 4.1.2, the sensitivity analyses conducted on key modeling assumptions suggests that 

HCFC-22 servicing need could be marginally to significantly less than what is presented in the following 

tables, depending on the extent to which leak rates, charge sizes, and equipment lifetimes are lower than 

what the Vintaging Model currently assumes. Information provided by stakeholders indicates that 

increasing prices for HCFC-22 may have motivated servicing technicians to be more careful with 

refrigerant and equipment owners to move more rapidly to alternatives. While the impact of these 

sensitivity analyses on HCFC-22 recovery or reuse has not been explicitly modeled, the results suggest 

that the need for virgin HCFC-22 may also be less than what is presented in the following tables.

Table 4-9: Lower Recovery Scenario: 35% Recovery Rate

Summary of Projected HCFC-22 Supply, Servicing Need, and Shortfall (Metric Tons)a

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025b

Total HCFC-22 

Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Modeled HCFC22 Supplied from 

Recovery or 

Reuse 

14,600 14,000 14,700 14,400 15,000 16,200 14,300 12,100 10,900 9,500 4,800

Estimated Supply 

Needed to Satisfy 

Remaining 

Servicing Need

31,500 27,500 22,000 18,000 12,700 6,300 3,600 1,700 0 0 800

% of Total 

Servicing Need

Supplied by 

Modeled 

Recovery/Reuse

32% 34% 40% 44% 54% 72% 80% 88% >100% >100% 86%

aBased on analysis using EPA (2012).

bThe values presented for 2025 do not take into account the possibility of carrying over surplus HCFC-22 from 2023 and 2024. The 

carryover of surplus HCFCs could help meet the total servicing need for HCFC-22 in 2025. 
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Table 4-10: Baseline Recovery Rate Scenario

Summary of Projected HCFC-22 Supply and Servicing Need (Metric Tons)a

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Total HCFC-22 

Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Modeled HCFC-22 

Supplied from 

Recovery or 

Reuse 

21,300 20,800 21,800 21,100 21,800 23,100 20,700 18,100 17,000 15,600 10,800

Estimated Supply 

Needed to Satisfy 

Remaining 

Servicing Need

24,800 20,700 14,900 11,300 5,900 0 0 0 0 0 0

% of Total 

Servicing Need

Supplied by 

Modeled 

Recovery/Reuse

46% 50% 59% 65% 79% >100% >100% >100% >100% >100% >100%

aBased on analysis using EPA (2012).

Note: Totals may not sum due to independent rounding.

Table 4-11: Higher Recovery Scenario: 65% Recovery Rate

Summary of Projected HCFC-22 Supply and Servicing Need (Metric Tons)a

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Total HCFC-22 

Servicing Need 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Modeled HCFC-22 

Supplied from 

Recovery or 

Reuse 

27,200 26,100 27,300 26,700 27,800 30,100 26,500 22,400 20,200 17,700 8,900

Estimated Supply 

Needed to Satisfy 

Remaining 

Servicing Need

18,900 15,500 9,400 5,700 0 0 0 0 0 0 0

% of Total 

Servicing Need

Supplied by 

Modeled 

Recovery/Reuse

59% 63% 74% 83% >100% >100% >100% >100% >100% >100% >100%

aBased on analysis using EPA (2012).

Note: Totals may not sum due to independent rounding.

4.6.2. Need and Recovery Projections for HCFC-123

Table 4-12 summarizes the projections for HCFC-123 under the Baseline Recovery rate scenario. HCFC123 need is modeled for both servicing and initial charging of new AC equipment and fire suppression 

systems; however, only servicing need is assumed to be able to be met by recovered material. The table 

provides the modeled servicing need for HCFC-123, the amount of HCFC-123 servicing need that can be 

met by recovery/reuse, as well as additional need for new equipment.

As shown in Table 4-12, the projected amount of recovered and reused HCFC-123 will meet total 

servicing need needs starting in 2020. Chillers and IPR equipment have high baseline recovery rates 

(90%), thus larger volumes of refrigerant can be reused for servicing. Unlike HCFC-22, HCFC-123 

servicing need is not expected to decrease significantly over the 2015 to 2025 timeframe.
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Table 4-12: Baseline Recovery Rate Scenario

Summary of Projected HCFC-123 Supply and Servicing Need (Metric Tons)a

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Total Servicing Need

(MT) 610 600 590 600 610 580 560 540 520 490 470

Additional Servicing 

Need for Charging New 

Equipment (MT)b

1,600 1,600 1,600 1,600 1,700 - - - - - -

Anticipated HCFC-123 

Supplied from Recovery 

or Reuse (MT)

330 330 330 820 920 970 1,020 1,030 1,040 1,050 1,060

Estimated Supply 

Needed to Satisfy 

Remaining Servicing and 

New Equipment Need

1,900 1,900 1,900 1,400 1,400 0 0 0 0 0 0

% of Total Servicing 

Need Supplied by 

Anticipated 

Recovery/Reuse

15% 15% 15% 36% 40% >100% >100% >100% >100% >100% >100%

aBased on analysis using EPA (2012). 

bServicing Need for Charging New Equipment” refers to need associated with new refrigeration and AC units (before 2020) and charging fire 

suppression systems. Use of HCFC-123 for fire suppression will not be permitted as of January 1, 2020.

Note: Totals may not sum due to independent rounding.

4.6.3. Servicing Need and Recovery Projections for HCFC-124

Table 4-13 summarizes the projections for HCFC-124 under the Baseline Recovery rate scenario. HCFC124 need is modeled for servicing of new refrigeration equipment. The table provides the modeled 

servicing need for HCFC-124 and the amount of HCFC-124 servicing need that can be met by 

recovery/reuse.

As shown, the projected amount of recovered and reused HCFC-124 will meet total servicing needs 

starting in 2020. Medium Retail Food and IPR equipment have high baseline recovery rates (80%), thus 

larger volumes of refrigerant can be reused for servicing. 

Table 4-13: Baseline Recovery Rate Scenario

Summary of Projected HCFC-124 Supply and Servicing Need (Metric Tons)a

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Total HCFC-124 

Servicing Need 5 5 5 4 4 4 3 2 1 <1 -

Modeled HCFC124 Supplied from 

Recovery or 

Reuse 

<1 1 1 1 2 9 17 14 11 7 4

Estimated Supply 

Needed to Satisfy 

Remaining 

Servicing Need

4 4 4 3 2 0 0 0 0 0 0

% of Total 

Servicing Need

Supplied by 

Modeled 

Recovery/Reuse

8% 16% 24% 31% 41% >100% >100% >100% >100% >100% -

aBased on analysis using EPA (2012). As mentioned previously, feedback from stakeholders and CARB data indicate this number is low.

Note: Totals may not sum due to independent rounding.
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4.6.4. Summary of HCFC-22, HCFC-123, and HCFC-124 Servicing Need and 

Recovery Projections

Figure 4-2, Figure 4-3, and Figure 4-4 illustrate the projected supply of recovered refrigerant available to 

meet servicing need under the Lower Recovery Scenario, the Baseline Recovery Scenario, and Higher 

Recovery Scenario, as well as its subsequent importance in meeting future servicing need. These figures 

display servicing need and supply projections of HCFC-22, HCFC-123, and HCFC-124 summed together 

and expressed in ODP-weighted quantities to compare to the ODP-weighted HCFC consumption cap for 

the United States. The solid line indicates the total HCFC projected servicing need between 2015 and 

2025 while the dotted line indicates the U.S. HCFC consumption cap (the value of the HCFC 

consumption cap does not change between the three scenarios). Shading in the figures represents 

supply. The dark grey shading indicates the portion of projected supply that is available through 

recovered and reusable HCFCs under the scenario in question. The remaining portion of servicing need

that cannot be met is shaded a lighter grey to represent virgin supply that would be required to meet 

modeled servicing need.

Figure 4-2 illustrates that a virgin supply that exceeds the U.S. HCFC consumption cap would be 

necessary to meet modeled servicing need during some years between 2015 and 2025, given the amount 

of material recovered under this scenario. Virgin HCFCs are needed to meet modeled servicing need

under the Lower Recovery Scenario through 2022 and in 2025. 

Figure 4-3 and Figure 4-4 illustrate that, between 2015 and 2020, the projected supply from recovered 

HCFCs combined with a smaller supply from virgin material that is below the U.S. cap is sufficient to meet 

modeled HCFC servicing need under the Baseline Recovery and Higher Recovery Scenarios. In addition, 

beyond 2019, the projected supply from recovered HCFCs exceeds the HCFC servicing need projections.

Note: In 2025, HCFC-22 recovery is not projected to fully meet service need under this scenario.

Figure 4-2: Total Projected HCFC Demand, Lower Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand

 3,000
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4.7. Factors Affecting Projections

Several market dynamics affect the projections of future servicing needs for HCFCs. Certain equipment 

specification requirements, the transition to alternative refrigerants, surplus inventory of refrigerant, as 

well as equipment manufactured with HCFCs for sale after the phaseout can all potentially alter the 

projected servicing scenarios. Each of these issues is discussed further below.

4.7.1. Transitioning to Alternative Refrigerants

A wide range of alternative refrigerants found acceptable under EPA’s SNAP program are available in the 

AC and refrigeration sector. Hydrofluorocarbon (HFC) alternatives, including HFC-134a, R-410A 

Figure 4-4: Total Projected HCFC Demand, Higher Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand

Figure 4-3: Total Projected HCFC Demand, Baseline Recovery Scenario

 -

 500

 1,000

 1,500

 2,000

 2,500

 3,000

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

H

CFC-22, H

CFC-123, and

H

CFC-124

(O

D

P-tonnes)

HCFC Supply from Recovered HCFCs

HCFC Supplied from Virgin HCFCs

U.S. HCFC Consumption Cap

Total HCFC Demand
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(composed of HFC-32/HFC-125), R-407C (composed of HFC-32/HFC-125/HFC-134a), R-404A 

(composed of HFC-125/HFC-143a/HFC-134a), and R-507A (composed of HFC-125/HFC-143a), are most 

widely used in refrigeration and AC equipment. Other alternatives—found acceptable under EPA’s SNAP 

program for specific end-uses, and sometimes with use conditions—are not only ozone-friendly but also 

climate-friendly, including hydrocarbons, carbon dioxide, ammonia, and lower-GWP fluorinated 

refrigerants, such as HFO-1234ze(E). The pace of transition to equipment using these alternatives has 

varied by industry and type of equipment. 

Production and import of new refrigeration/AC equipment using HCFC-22 has been prohibited in the 

United States as of January 1, 2010. Several AC and refrigeration equipment manufacturers had 

discontinued production of new equipment using HCFC-22 well before this phaseout date (Hill Phoenix 

2009; Hussmann 2009; Kysor/Warren 2009; Johnson Controls 2009). Such actions were consistent with 

those taken in the mid-1990s, when the refrigeration and AC industries phased out CFC refrigerants from 

new production chillers, refrigerators, motor vehicle air conditioners, and other products two or more 

years before the 1996 CFC consumption phaseout.

Feedback from numerous points in the supply chain has indicated that sales of alternative refrigerants 

have increased dramatically since 2011. As the phaseout progresses, the percentage of HCFC-22 

servicing need met by retrofit refrigerants is expected to rise, thereby further reducing the need for HCFC22 and adding to the potential inventory of recovered refrigerant.

Air-Conditioning Industry

HFC-134a, R-410A, and R-407C are replacing HCFC-22 in new stationary and mobile AC equipment. 

Some mobile AC equipment has been using alternatives since the early 1990s, with some buses and 

trains using HFC-134a, and some heavy rail cars using R-407C (WMATA 2005; Amtrak 2005; 

Motorcoach Training 2005; Greyhound 2005; Carrier Corporation 2005b). Stationary AC equipment using 

R-410A has been commercially available since 1996 (HARDI 2004), and is the standard refrigerant in all 

systems installed after 2009 in the U.S. residential market (J.P. Morgan 2011). Manufacturers of R-410A 

saw significant growth in 2010 driven by the conversion to R-410A from HCFC-22 in the U.S. Between 

2009 and 2010, R-410A residential AC units as a percentage of all condensing unit shipments rose from 

55% to 90% due to the phaseout of HCFC-22 (J.P. Morgan 2011).

Since January 1, 2010, new appliances charged with HCFC-22 could no longer be sold on the market; 

however, dry-shipped replacement parts (e.g., condensing units, compressors) are still allowed.

Consumers have the option of selecting to repair existing HCFC-22 units rather than switching to 

alternatives. A replacement compressor would cost $1,800 to $2,000, approximately 40 percent of the 

cost of an R-410A system replacement (J.P. Morgan 2011). This analysis does not take into account the 

possibility that repairs may extend the lifetime of existing HCFC-22 appliances but the impact of extended 

equipment lifetime due to dry-shipped replacement parts is considered in Appendix D. EPA’s assumption 

that residential AC typically lasts for 15 years is consistent with the U.S. Department of Energy (DOE)’s

estimates for the average life of a system, which is estimated at 15-20 years (DOE 2012). 

Refrigeration Industry

Advanced refrigeration technologies (e.g., distributed systems and secondary loop systems) represent an 

estimated 40% of new equipment sales and are generally charged with HFC refrigerants (Hill Phoenix 

2009; Hussmann 2009). The current trend in the supermarket industry is to use HFC refrigerant blends, 

particularly R-407A. There has been a shift from R-404A towards blends with lower GWPs, such as R407A and R-407C (Verisae 2009). Carbon dioxide has been used as a secondary fluid in supermarkets 

since 2006 and more recently as a primary refrigerant. It is anticipated that the use of carbon dioxide as a 

primary refrigerant will become increasingly common in commercial and industrial applications (Shecco 

2012).

Based on an industry survey, HCFC-22 accounts for approximately 40% of the refrigerants (by weight) 

still used by supermarkets (Garry 2012). Of the 2,445 retailers surveyed, most did not plan to fully replace 

HCFC-22 until 2015 or 2020 (Garry 2012).
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4.7.2. Recovery and Reuse Practices

As indicated in the total projected servicing need scenarios presented in Section 4.4, recovered HCFC-22

and HCFC-123 that is recycled, inventoried, or reclaimed will likely need to increase to satisfy future 

servicing needs that cannot be met through virgin supplies. Key findings from this analysis include:

HCFC-22

 In 2015, the amount of recovered HCFC-22 refrigerant is projected to range from 21,300 to 27,200

metric tons, depending on the percentage of total available refrigerant from retired or converted 

equipment that is recovered and reused.

 Since virgin production of HCFC-22 for domestic use stops in 2020, recovery would have to be at 

approximately the baseline recovery scenario rate (51 percent) or higher to meet estimated servicing 

need (assuming no existing inventory, and not considering the assumptions in the sensitivity 

analyses).

 In 2025, the availability of recovered HCFC-22 refrigerant under the baseline and higher recovery 

scenarios would provide adequate supplies to meet estimated servicing need. In the lower recovery 

scenario, servicing need could potentially be met if surplus HCFC-22 from previous years is carried 

over.

HCFC-123

 In 2015, the amount of recovered HCFC-123 refrigerant is projected to be 330 metric tons, based on 

a baseline refrigerant recovery rate of 90 percent.

 Starting in 2020, recovered HCFC-123 refrigerant is expected to meet estimated servicing need.

HCFC-124

 In 2015, the amount of recovered HCFC-124 refrigerant is projected to be less than 1 metric ton.

By 2020, the availability of recovered HCFC-124 refrigerant would provide adequate supplies to meet 

estimated servicing need.

Although there is the potential for supply tightness the closer it gets to 2020, proper maintenance 

practices during the lifetime of equipment, recovery practices at the time of equipment disposal or 

decommissioning, and the full penetration of reclaim and reuse practices can greatly reduce the likelihood 

of future shortfalls. 

The use of recovery procedures during the lifetime of equipment and at the time of decommissioning 

reduces potential emissions of refrigerant and increases the available supply of refrigerant. End-users of 

AC and refrigeration equipment must have equipment installed by trained technicians. They must also 

have their equipment properly maintained to reduce incidences of major leaks. Service technicians must 

take efforts to isolate components or recover refrigerants prior to service as venting (releasing) HCFC 

(and CFC and HFC) refrigerant when making repairs is illegal. Service practices that involve locating and 

repairing leaks in lieu of “topping off” leaking systems further ensure future supplies of HCFC refrigerant. 

As with servicing procedures, the venting of refrigerant during decommissioning is illegal. The AC and 

refrigeration community, including end-users, service technicians, and all affected stakeholders, must 

position itself for approaching phaseouts of HCFCs by using proper recovery techniques and complying 

with regulations that are in place to promote the growth of HCFC recovery and reuse.

4.7.3. Recycling, Reuse, and Managing Inventory

With proper storage tanks, a reserve of recovered HCFC-22 can be collected, stored, and accessed to 

service equipment owned by the same company years later, when HCFC-22 is expected to be less 

affordable and less available. A report released in 1995 by the Food Marketing Institute (FMI) included a 

survey issued to supermarket operators on the use of refrigerant management plans (RMPs) as a 

strategy to ensure an adequate supply of CFC refrigerants for use after the December 31, 1995, CFC 
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production phaseout. Of those surveyed, 52 percent were banking recovered CFC refrigerant, an activity 

adopted primarily by store operators with 11 or more stores (FMI 1995). 

Industry sources suggest that recovery and direct reuse is a widespread practice amongst supermarkets 

in large retail food equipment; however, the extent can vary significantly between chains, depending 

largely on the extent to which supermarkets are converting their HCFC-22 equipment to alternatives (ICF 

2011). Some supermarkets who have converted a substantial proportion of their HCFC-22 equipment 

indicated that they have sufficient recovered HCFC-22 in-stock for servicing such that they do not 

anticipate a need to purchase any more virgin material in the future (ICF 2011).

Feedback from industry sources indicates there was a significant amount of HCFC-22 in the supply chain 

leading into 2012 (ICF 2011). Additionally, EPA collected data on HCFC-22 inventory from nine 

companies in early fall, 2013 using Clean Air Act section 114 authority. Additional discussion of HCFC-22 

inventory levels is included in Appendix E. Some of the pre-2012 inventory was consumed in 2012 to 

meet servicing needs but both anecdotal feedback and inventory data continue to indicate that there is a 

significant amount of inventory that can help meet servicing need in 2015 and beyond. 

4.7.4. HCFC-22 Economics

Another factor that affects the projections of HCFC-22 servicing supply and need is the cost of virgin and 

reclaimed HCFC-22. Prior to 2012, the price of HCFC-22 remained low. The relatively low cost of virgin 

HCFC-22 in the market, and the costs associated with sending recovered HCFC-22 to reclaimers,

decreased the incentives to properly manage HCFC-22 in existing systems (e.g., fixing leaks, recovering 

and recycling refrigerant, etc.).

As the allowed production and import of virgin HCFC-22 decreased in 2012 and 2013, HCFC-22 price 

increased. As a result, interest in and demand for recovery and reuse, reclamation, and retrofit options 

increased significantly. As the supply of virgin HCFC-22 continues to decrease, demand for recovered 

and reclaimed refrigerant and demand for HCFC-22 alternatives is expected to increase. All of these 

factors could affect realized lifetimes for equipment, which could decrease future servicing need. A

sensitivity analysis shows that shortening realized lifetimes by five years in 20 percent of equipment could 

result in a 9 to 14 percent decrease in HCFC-22 service need between 2015 and 2025. Additional details 

can be found in Appendix D.

4.7.5. Increasing Seasonal Energy Efficiency Ratio (SEER)

In 2001, the DOE set a stricter seasonal energy efficiency ratio (SEER) standard for residential unitary 

ACs and heat pumps. The minimum efficiency standard of residential unitary ACs and heat pumps was 

raised by 30 percent to a 13 SEER for all such units manufactured for sale on or after January 23, 2006 

(DOE 2001; DOE 2004). These increased SEER requirements are reflected in the Vintaging Model. The 

projections provided in this analysis do not consider the need for HCFC-22 to service higher efficiency 

residential AC equipment installed after 2015 because all new HCFC-22 systems were banned starting in 

2010 (see Appendix A for more details). 

The Vintaging Model currently assumes that the 13 SEER vintage of HCFC-22 residential unitary AC 

equipment uses a charge size of approximately 4.76 kg. Appendix D presents an analysis that examines 

the potential effects on service need of a lower charge size of 4 kg for HCFC-22 13 SEER residential 

unitary AC equipment. This change results in a 2 to 7 percent decrease in total HCFC-22 service need

across all refrigeration and AC end-uses between 2015 and 2023. As modeled, all HCFC-22 residential 

unitary AC equipment has reached end-of-life by 2023, so there is no longer servicing need for that enduse after 2023.

4.7.6. Lower Loss Rates 

EPA’s GreenChill program is committed to reducing refrigerant emissions by lowering equipment leak 

rates or eliminating leaks entirely within the commercial refrigeration industry. Approximately 20 percent 

of U.S. supermarkets participate in GreenChill. Increased participation in this program can lower the 

industry-wide leak rate for HCFC-22 equipment and therefore further decrease HCFC-22 servicing need. 
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Since 2008, the average commercial refrigeration emissions rate across GreenChill partners has been 13 

percent, which is nearly half the national average of 25 percent.25 In addition, the ban on HCFC-22 in new 

equipment manufactured after 2010 (and the resultant increase in price for virgin and reclaimed HCFC22) may also prompt service technicians to be more careful during servicing and encourage end-users to 

have leaks fixed more frequently, particularly for larger equipment, where the financial benefits of leaktightness are more apparent. 

Both of these factors can affect projections of future servicing needs for HCFC-22, particularly in 

residential unitary AC, large retail food, medium retail food, and cold storage. Reducing HCFC-22 loss 

rates was found to result in a 10 to 23 percent reduction in HCFC-22 servicing needs. Details on this 

sensitivity analysis are presented in Appendix D.

 

25 The Vintaging Model assumes an annual leak rate of 25 percent for HCFC-22 large retail food units, plus an annual 5 percent loss 

during servicing.
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5. Conclusion

On January 1, 2015, production, import, introduction into interstate commerce and use of HCFCs are 

banned except for on-going refrigeration and AC service needs for equipment manufactured on or before 

December 31, 2019 and for nonresidential fire suppression. To support development of the allocation 

levels that will allow the U.S. to comply with the Montreal Protocol’s 2015 and 2020 reduction steps, this 

report provides projections on the quantity of HCFC-22, HCFC-123, and HCFC-124 needed for (a) 

servicing AC and refrigeration equipment manufactured before January 1, 202026; (b) charging new AC 

and refrigeration equipment between 2015 and 2020 (HCFC-123 only); and (c) nonresidential fire 

suppression applications before January 1, 2020.

Under the Baseline and Higher Recovery scenarios developed in this analysis, future HCFC servicing 

needs can be met by using recovered refrigerant and an amount of virgin refrigerant allowable under the 

United States’ Montreal Protocol cap. If recovery and reuse is lower than expected (i.e., the lower 

recovery rate scenario), the refrigeration and AC industry could face the potential risk of a shortage of 

HCFC-22 starting in 2015, however, this is unlikely. Alternatively, if leak rates, practiced equipment 

lifetimes, and charge sizes are lower than what the Vintaging Model currently assumes—as considered in 

the sensitivity analysis in Appendix D—servicing need, as well as the need for virgin supply, could be 

significantly lower than what is presented below. 

The tables below summarize total projected HCFC-22, HCFC-123, and HCFC-124 servicing need in 

2015, 2020, and 2025 compared to the ODP-weighted HCFC consumption cap. The percentage shown in 

parentheses is the percent of servicing need met by either recovered or virgin HCFCs. Concluding points 

are also provided on the implications of the three recovery and reuse scenarios.

 In 2015, the projected servicing need for HCFC-22, HCFC-123, and HCFC-124 is equal to 2,580 

ODP-weighted MT. As shown in Table 5-1, under a higher recovery scenario, 58 percent of this need

could be met with recovered refrigerant; and 45 percent of servicing need can be met at the baseline

recovery rate. Only 31 percent of the total servicing need can be met under the lower recovery rate 

scenario, leading to a potential shortage of at least 250 ODP-weighted metric tons in 2015.

Table 5-1: Comparison of HCFC Servicing and New Equipment Servicing Need Projections (ODPWeighted Metric Tons) and Necessary Supply Projections by Source, 2015

2015

Lower Recovery 

Rate 

Baseline

Recovery Rate 

Higher Recovery 

Rate 

Capa 1,524

Servicing Need 2,580

Necessary Supply

Recovered 812 (31%) 1,177 (46%) 1,502 (58%)

Virgin 1,524 (59%) 1,402 (54%) 1,078 (42%)

Shortfall 244 (10%) 0 (0%) 0 (0%)

aHCFC consumption cap expressed in ODP-weighted metric tons.

Source: Based on modeling assumptions using EPA (2012).

 In 2020, the HCFC consumption cap is reduced to 0.5 percent of the baseline, or 76.2 ODP-weighted 

metric tons. Projected servicing need for 2020 is 1,250 ODP-weighted MT. As shown in Table 5-2

under the baseline and higher recovery scenarios, sufficient supplies of recovered material will be 

available to meet servicing needs, and no shortage is expected. For the lower recovery scenario, 73 

percent of the total servicing need can be met by recovered and reused material, resulting in a 

shortage of at least 272 ODP-weighted metric tons. EPA regulations prohibit consumption of HCFC22 and HCFC-142b in 2020, but allow consumption of HCFC-123 and HCFC-124. While this analysis 

projects that all servicing need for HCFC-123 can be met from recovered supplies, it is worthwhile to 

 

26 New appliances charged with HCFC-22 and HCFC-142b cannot be manufactured as of January 1, 2010.
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note that the total projected HCFC-123 servicing need of 580 metric tons (11.6 ODP-Tons) is 15% of 

the total HCFC cap.

Table 5-2: Comparison of HCFC Servicing Need Projections (ODP-Weighted Metric Tons) 

and Necessary Supply Projections by Source (ODP-Weighted Metric Tons and Percent), 2020

2020

Lower Recovery 

Rate

Baseline

Recovery Rate 

Higher Recovery 

Rate

Capa 76.2

Servicing Need 1,250

Necessary Supply

Recovered 910 (73%) 1,289 (100%) 1,673 (100%)

Virgin 76.2 (6%) 0 (0%) 0 (0%)

Shortfall 264 (21%) 0 (0%) 0 (0%)

aHCFC consumption cap expressed in ODP-weighted metric tons.

Source: Based on modeling assumptions using EPA, 2012.

 In 2025, HCFC servicing need is projected at 314 ODP-weighted MT (Table 5-3). There is no 

projected shortfall in any of the scenarios considered. For the lower recovery scenario, recovered and 

reused supplies can meet 90% of the total servicing need. The remaining need can be met with virgin 

materials without exceeding the consumption cap. No virgin material is expected to be needed for the 

baseline and higher recovery scenarios. While the Clean Air Act allows consumption of HCFC-123

and HCFC-124 until 2030, EPA has not yet proposed allowances for the 2020-2029 timeframe. While 

this analysis projects that all servicing need for HCFC-123 can be met from recovered supplies, it is 

worthwhile to note that the total projected HCFC-123 servicing need of 470 metric tons (9.4 ODPTons) is 12% of the total HCFC cap.

Table 5-3: Comparison of HCFC Servicing Need Projections (ODP-Weighted Metric Tons) 

and Necessary Supply Projections by Source (ODP-Weighted Metric Tons and Percent), 2025

2025

Lower Recovery 

Rate

Baseline

Recovery Rate

Higher Recovery 

Rate

Capa 76.2

Servicing Need 314

Necessary Supply

Recovered 284 (90%) 616 (100%) 509 (100%)

Virgin 30 (10%) 0 (0%) 0 (0%)

Shortfall 0 (0%) 0 (0%) 0 (0%)

aHCFC consumption cap expressed in ODP-weighted metric tons to represent allocations of HCFC-22 and HCFC-123.

Source: Based on modeling assumptions using EPA, 2012.

 Although no servicing need for HCFC-142b is projected from 2015 to 2020, stakeholder feedback and 

industry data from California indicate that there is still equipment using HCFC-142b and that there will 

be continued, but limited, refrigerant servicing need beyond 2015. 

Projections of future HCFC supply and servicing need vary depending on various market trends as 

addressed in this report. More rapid equipment transitions, reductions in loss rates through careful 

servicing and programs such as GreenChill, and lower charge sizes in more efficient equipment may

result in lower service need, and consequently lower need for virgin supply. The projections in this report 

provide only some of the information necessary for taking initial steps in determining post-2015 servicing 

needs for HCFC-22, HCFC-123, HCFC-124, and HCFC-142b equipment.
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Box A-1: Developing and Maintaining EPA’s Vintaging Model

The Vintaging Model synthesizes data from a variety of sources, 

including:

 EPA’s ODS Tracking System and submissions to the SNAP 

program, both maintained by the U.S. EPA Stratospheric 

Protection Division;

 Published literature from the United Nations Environment 

Programme (UNEP) Technical Options Committees, the 

Alternative Fluorocarbons Environmental Acceptability Study 

(AFEAS), and those provided in industry-related and EPA 

conference proceedings; and

 Numerous representatives at companies and trade 

associations, such as the Alliance for Responsible Atmospheric 

Policy, the Air-Conditioning Heating and Refrigeration Institute 

(AHRI), the Association of Home Appliance Manufacturers 

(AHAM), and the Alliance of Automobile Manufacturers.

In some instances the unpublished information that EPA uses in the 

model is classified as Confidential Business Information (CBI). The 

annual emissions inventories of chemicals are aggregated in such a 

way that CBI cannot be inferred. 

The Vintaging Model is continually updated to improve assumptions 

and modeling techniques and refine inputs based on information 

received from these sources. EPA shares the revised assumptions and 

results of model improvements with industry through publications such 

as this one as well as through presentations, such as those given at 

the April 2007 Spring Meetings of AHRI. 

Since 2009, the refrigeration and air-conditioning sectors of the 

Vintaging Model have been updated multiple times. In 2012, an update 

to the large, medium, and small retail food end-uses had an impact on 

the projected service, leak, and new chemical demand, as well as 

disposal recovery. In addition, changes to the small commercial and 

residential unitary AC end-uses also affected the service demand of 

HCFC-22.

Appendix A: Methodology Used to Calculate Projected 

Servicing Needs

This appendix outlines the methodology used to calculate the projected servicing and new chemical need

of AC, refrigeration, and fire suppression equipment using HCFC-22, HCFC-123 and HCFC-124. This 

appendix contains two sections:

 Section A.1 provides an overview of EPA’s Vintaging Model (EPA 2012), which was used to 

establish the estimates of units of equipment using HCFC-22 and HCFC-124 for servicing need

beyond 2015 and HCFC-123 for new equipment and servicing beyond 2015. 

 Section A.2 discusses the limitations to the servicing projections presented in this report.

A.1 EPA’s Vintaging Model

EPA’s Vintaging Model was developed as 

a tool for estimating the annual chemical 

emissions from industrial sectors that 

have historically used ODS in their 

products. Emissions are estimated from

the following end-use sectors: 1) AirConditioning and Refrigeration; 2) Foams; 

3) Aerosols; 4) Solvents; 5) FireExtinguishing; and 6) Sterilants. Within 

these sectors, there are over 60 

independently modeled end-uses. The 

model requires information on the market 

growth for each of the end-uses, as well 

as a history and projection of the market 

transition from ODS to alternatives. As 

ODS are phased out, a percentage of the 

market share originally filled by the ODS 

is allocated to 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. This 

means it models the consumption of 

controlled ozone-depleting substances 

and their substitutes based on:

1) Estimates of the quantity of 

equipment or products sold, 

serviced, and retired or retrofitted 

each year,27 and 

2) The quantity of the chemical 

required to manufacture and/or 

maintain the equipment. 

The model makes use of this market 

information to build an inventory of in-use 

stocks of equipment and quantities of 

ODS/ODS substitutes in each of the enduses. 

 

27 All installations and retrofits and assumed to take place on January 1, at the start of the calendar year. 
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Emissions are estimated by applying annual leak rates, service emission rates, and disposal emission 

rates to consumption data for each vintage of equipment. Emissions from AC and refrigeration equipment 

are split into two categories: emissions during equipment lifetime and disposal emissions. The first 

category includes the amount of chemical leaked during equipment operation and the amount of chemical

emitted during service. Consumption required to service or refill equipment is driven by the need to 

replace such losses, and therefore, emissions during the lifetime of equipment are equal to consumption 

for servicing (since it is assumed that all leaked refrigerant is eventually replaced). Emissions, and 

therefore, consumption from leakage and servicing can be expressed as follows:

Esj = (la + ls) × Σ Qcj-i+1 for i=1→k 

Where:

Es = Emissions from Equipment Serviced. Emissions in year j from normal leakage and 

servicing of equipment.

la = Annual Leak Rate. Average annual leak rate during normal equipment operation 

(expressed as a percentage of total chemical charge).

ls = Service Leak Rate. Average leakage during equipment servicing (expressed as a 

percentage of total chemical charge).

Qc = Quantity of Chemical in New Equipment. Total amount of a specific chemical used to 

charge new equipment in a given year by weight.

i = Counter, runs from 1 to lifetime (k).

j = Year of emission.

k = Lifetime. The average lifetime of the equipment.

The assumptions used in this calculation range by equipment, refrigerant, and vintage, reflecting that as 

new technologies replace older ones, improvements in their leak, service, and disposal emission rates 

are assumed to occur.

For the purpose of this analysis, the following data from EPA’s Vintaging Model were compiled and 

summarized for the AC and refrigeration sector:

1) Consumption for Servicing, which is equal to the need to service (i.e., refill) existing equipment. 

These data are back-calculated using service and leak emissions because the quantity emitted 

during the lifetime of equipment drives the need to replace such losses. These estimates are 

further distinguished between consumption of virgin and recycled/reclaimed chemical. The model 

assumes that a certain percentage of refrigerant, which varies by end-use, is recovered from 

discarded equipment. The model then assumes a “best-case” scenario in which all recovered and 

re-usable refrigerant re-enters the market. See Section A.2 for further discussion on this 

“recovery pool.”

2) Need for New Equipment, which is equal to the amount of chemical needed to fill new equipment. 

This estimate is further distinguished between consumption of virgin and recycled/reclaimed 

chemical.

2) Number of Units of Equipment, which is equal to, for “year X”’, the number of units existing in “year

X-1” plus the number of new units produced in “year X” minus the number of units disposed in 

“year X”. 

For example:

No. of Units in 1999 = No. of Units in 1998 + New Units in 1999 – Units Disposed in 1999

Estimates from EPA’s Vintaging Model are often cross-checked with actual historical data from EPA’s 

ODS Tracking System, which tracks actual ODS production and consumption (including import and 

export) by U.S. companies. The Model’s virgin manufacture parameter is considered to be most 

comparable to the Montreal Protocol’s definition of consumption (i.e., production plus imports minus 

exports). In EPA’s Vintaging Model, the Virgin Manufacture parameter is calculated to be any need for 

consumption (either for new equipment or servicing) that cannot be met through recycled or recovered 

material; no distinction is made in the Vintaging Model between whether that need is met through 
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domestic manufacturing or imports. As shown in Figure A-1, estimates from the model generally align to 

actual consumption from 1993 to 2011.

Figure A-1: Comparison of EPA’s Vintaging Model Estimates for Virgin Manufacture

and ODS Tracking System Data for HCFC-22 Consumption

Table A-1 presents the input assumptions used to develop the projections in this report. The loss rates 

represent the percent of the total charge that leaks in a given year plus the amount, on an annual basis, 

emitted at service, expressed as a percentage of total chemical charge. Because the amount lost from 

leaks and servicing is annualized, equipment is assumed to reach the end of its lifetime with a full 

charge.28 EPA’s Vintaging Model then applies a “recovery rate,” which refers to the percent of total charge 

of the equipment that is recovered and reused at the time of disposal. These recovery rates represent 

averages, intended to capture the range of possible practices occurring at disposal. 

Growth rate assumptions are also provided in Table A-1. The growth rates refer to the growth of the 

equipment market for each end-use as a whole and are not specific to the refrigerant. When the transition 

to different equipment and different refrigerants occur, the input assumptions are adjusted to account for 

these changes. 

 

28 For the majority of equipment types, the assumption that equipment contains a full charge at the end of life is theoretically

applicable. To ensure proper and continual functioning of equipment, homeowners and businesses typically have their airconditioning and refrigeration systems serviced regularly. Technicians will check these systems for leaks using proper techniques 

and if a loss of refrigerant is found, will refill the system to ensure it is functioning efficiently after repairing any leaking seals or 

damaged components. Note that this assumption may not be appropriate for smaller equipment types such as window units but is 

applied consistently for modeling purposes.

0

1000

2000

3000

4000

5000

6000

7000

19

9

3

19

9

4

19

9

5

19

9

6

19

9

7

19

9

8

19

9

9

2

0

0

0

2

0

01

2

0

0

2

2

0

0

3

2

0

0

4

2

0

0

5

2

0

0

6

2

0

0

7

2

0

0

8

2

0

0

9

2

010

2

011

O

D

P

W

eig

hte

d

M

etric

To

n

s

Vintaging Model Estimates

ODS Tracking System Data

Source: EPA's ODS Tracking System, Vintaging Model (VM IO file_v4.4_11.6.12)
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Table A-1: Input Assumptions, Years 2015 to 2025

Current 

Refrigerant

Equipment Type and

Original ODS Refrigerant

Charge 

Sizea

Loss 

Rate

Growth 

Rateb

Recovery 

Rate

Lifetime 

(Years)

Manufactured 

From

AC Equipment

HCFC-22

HCFC-22 Residential Unitary 

A/C 3 14% 0.8% 35% 15 1992-2005

HCFC-22

HCFC-22 Residential Unitary 

A/C 5 14% 0.8% 35% 15 2006-2009

HCFC-22

HCFC-22 Small Commercial 

Unitary AC 8 11% 0.8% 40% 15 1992-2009

HCFC-22

HCFC-22 Large Commercial 

Unitary AC 15 10% 0.8% 40% 15 1992-2009

HCFC-22

HCFC-22 Water & Ground 

Source Heat Pumps 4 5% 0.8% 57% 20 1992-2009

HCFC-22 HCFC-22 Dehumidifiers 0 1% 0.2% 50% 11 1985-2009

HCFC-22

HCFC-22 Packaged Terminal 

Units 1 5% 0.8% 35% 12 1992-2009

HCFC-22 HCFC-22 Window Units 1 1% 5.0% 50% 12 1985-2009

HCFC-22 CFC-12 School & Tour Buses 5 10% 2.6% 50% 12 1994-2006

HCFC-22 HCFC-22 Transit Buses 8 44% 2.6% 50% 12 1985-2008

HCFC-22 CFC-11 Centrifugal Chillers 700 14% 0.5% 80% 25 1991-1995

HCFC-22 CFC-11 Centrifugal Chillers 700 5% 0.5% 80% 25 1996-2009

HCFC-123 CFC-11 Centrifugal Chillers 440 1% 0.5% 90% 25 1993-Present

HCFC-22 CFC-12 Centrifugal Chillers 721 8% 0.5% 80% 27 1991-1995

HCFC-22 CFC-12 Centrifugal Chillers 721 5% 0.5% 80% 27 1996-2009

HCFC-123 CFC-12 Centrifugal Chillers 453 1% 0.5% 90% 27 1993-Present

HCFC-22 Reciprocating Chillers 230 6% 0.2% 80% 20 1993-1998

HCFC-22 Reciprocating Chillers 230 1% 0.2% 80% 20 1999-2009

HCFC-22 Screw Chillers 300 1% 0.5% 80% 20 1996-2009

HCFC-22 Scroll Chillers 240 1% 0.5% 80% 20 1996-2009

HCFC-22 R-500 Chillers 926 11% 0.5% 80% 27 1991-1995

HCFC-22 R-500 Chillers 926 5% 0.5% 80% 27 1996-2009

HCFC-123 R-500 Chillers 582 1% 0.5% 90% 27 1993-Present

Refrigeration Equipment

HCFC-22 CFC-12 Cold Storage <0.01 20% 2.5% 80% 20 1990-2009

HCFC-22 HCFC-22 Cold Storage <0.01 22% 2.5% 80% 20 1985-1992

HCFC-22 HCFC-22 Cold Storage <0.01 20% 2.5% 80% 20 1992-2009

R-502 R-502 Cold Storage <0.01 25% 2.5% 80% 20 1985-1995

HCFC-22 R-502 Cold Storage <0.01 20% 2.5% 80% 20 1990-2009

HCFC-22 CFC-12 Large Retail Food 1,800 30% 0.8% 80% 18 1991-1999

HCFC-22 CFC-12 Large Retail Food 1,360 30% 0.8% 80% 18 2000-2009

HCFC-22 R-502 Large Retail Food 1,800 30% 0.8% 80% 18 1990-1999

HCFC-22 R-502 Large Retail Food 1,800 30% 0.8% 80% 18 1995-1999

HCFC-22 R-502 Large Retail Food 1,360 30% 0.8% 80% 18 2000-2009

HCFC-22

HCFC-22 Large Condensing 

Units (Medium Retail Food) 25 15% 0.9% 80% 20 1985-2009

R-402A

HCFC-22 Large Condensing 

Units (Medium Retail Food) 25 15% 0.9% 80% 20 1995-2005

HCFC-22

HCFC-22 Small Condensing 

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1985-2009

R-402A

HCFC-22 Small Condensing 

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1995-2005
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Current 

Refrigerant

Equipment Type and

Original ODS Refrigerant

Charge 

Sizea

Loss 

Rate

Growth 

Rateb

Recovery 

Rate

Lifetime 

(Years)

Manufactured 

From

R-401A

HCFC-22 Small Condensing 

Units (Medium Retail Food) 3 8% 0.9% 80% 20 1995-2005

HCFC-22 CFC-12 Small Retail Food 1 8% 0.8% 35% 20 1990-2008

HCFC-22

CFC-11 Industrial Process 

Refrigeration 952 10% 2.5% 80% 25 1991-2009

HCFC-123

CFC-11 Industrial Process 

Refrigeration 598 5% 2.5% 90% 25 1992-2004

HCFC-123

CFC-11 Industrial Process 

Refrigeration 598 5% 2.5% 90% 25 2005-Present

HCFC-22

CFC-12 Industrial Process 

Refrigeration 992 10% 2.5% 80% 25 1991-2009

HCFC-123

CFC-12 Industrial Process 

Refrigeration 623 5% 2.5% 90% 25 1992-2004

HCFC-123

CFC-12 Industrial Process 

Refrigeration 623 4% 2.5% 90% 25 2005-Present

R-401A

CFC-12 Industrial Process 

Refrigeration 850 5% 2.5% 90% 25 1995-1999

HCFC-22

HCFC-22 Industrial Process 

Refrigeration 9,100 16% 2.5% 80% 25 1985-1992

HCFC-22

HCFC-22 Industrial Process 

Refrigeration 9,100 12% 2.5% 80% 25 1992-2009

Source: VM IO File_v4.4_11.6.12

aCharge size presented in kilograms. Cold storage charge size presented in kilograms/cubic foot.

bThe growth rate applies to new consumption/virgin manufacture for products entering the market. For example, in the window units market, 

any year’s consumption for new equipment is five percent greater than the previous year’s consumption.

Table A-2 presents the assumptions used to model the transition from HCFC-22, HCFC-123, and HCFC124 to alternatives for each end use. Only those end-uses that have been using HCFC-22, HCFC-123, or 

HCFC-124, or have in whole or in part transitioned to use HCFC-22, HCFC-123, HCFC-124, are shown. 

The first column of the table presents the HCFC-22, HCFC-123, and HCFC-124 equipment types by the 

refrigerants that they originally used. The second column presents the refrigerants that enter the market 

and are used in new equipment in place of HCFC-22, HCFC-123, or HCFC-124.

29 These refrigerants 

begin to enter the new-equipment market in the year presented in the third column and fully penetrate this 

market by the date presented in the fourth column, after which they continue to make up that portion of 

the market. The final column indicates the percent of the HCFC-22, HCFC-123, and HCFC-124 newequipment market that the given substitute refrigerant replaces by the transition end date. All transitions 

are assumed to occur linearly between the transition start and end dates. Each row represents a different 

vintage of equipment that can have different properties (e.g., charge size or leak rate) in addition to start 

date for the transition to the substitute, the end date to reach assumed market penetration, and assumed 

market penetration from the other vintages of equipment. By combining multiple transitions to different 

refrigerants and over different time periods, the Vintaging Model mimics actual, non-linear transitions that 

may occur.

 

29 These transition assumptions are for new equipment only; they do not imply that the original equipment was retrofitted to the 

alternative refrigerants.
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Table A-2: Transition to Alternatives Assumptions of EPA’s 

Vintaging Model for HCFC-22, HCFC-123, and HCFC-124 Refrigeration and AC Equipmenta

1 2 3 4 5

Equipment Type and Original 

ODS Refrigerant Substitute Start Date End Dateb

Market 

Penetration of 

Substitutec

HCFC-22 Residential Unitary AC R-410Ad

2000 2005 5%

2000 2006 5%

2006 2006 20%

2007 2010 20%

2010 2010 50%

HCFC-22 Small Commercial Unitary AC R-410A

1996 2000 3%

2001 2005 18%

2006 2009 8%

2009 2010 71%

HCFC-22 Large Commercial Unitary 

AC

R-407C 2006 2009 1%

2009 2010 5%

R-410A

2001 2005 5%

2006 2009 9%

2009 2010 81%

HCFC-22 Water & Ground Source Heat 

Pumps

R-407C

2000 2006 5%

2006 2009 3%

2009 2010 23%

R-410A

2000 2006 5%

2006 2009 5%

2009 2010 41%

HFC-134a 2000 2009 2%

2009 2010 18%

HCFC-22 Dehumidifiers HFC-134a 1997 1997 89%

R-410A 2007 2010 11%

HCFC-22 Packaged Terminal Units R-410A 2006 2009 10%

2009 2010 90%

HCFC-22 Window Units R-410A 2008 2009 10%

2009 2010 90%

CFC-12 Tour Buses HFC-134a 2006 2007 100%

HCFC-22 Transit Buses HFC-134a 1995 2009 100%

HCFC-22 Trains HFC-134a 2002 2009 50%

R-407 2002 2009 50%

CFC-12 Cold Storage R-404A 1996 2010 75%

R-507A 1996 2010 25%

HCFC-22 Cold Storage

R-404A 1996 2009 8%

2009 2010 68%

R-507A 1996 2009 3%

2009 2010 23%

R-502 Cold Storage

R-404A 1996 2010 38%

R-507A 1996 2010 12%

Other 1996 2010 50%

CFC-11 Industrial Process Refrigeration HFC-134a 1995 2010 100%

CFC-12 Industrial Process Refrigeration

HFC-134a 1995 2010 15%

R-404A 1995 2010 50%

R-410A 1999 2010 20%

R-507A 1995 2010 15%

HCFC-22 Industrial Process Refrigeration HFC-134a 1995 2009 2%
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1 2 3 4 5

Equipment Type and Original 

ODS Refrigerant Substitute Start Date End Dateb

Market 

Penetration of 

Substitutec

2009 2010 14%

R-404A 1995 2009 5%

2009 2010 45%

R-410A 1999 2009 2%

2009 2010 18%

R-507A 1995 2009 2%

2009 2010 14%

CFC-12 Large Retail Food

R-404A

2000 2000 14%

2000 2009 4%

2001 2010 13%

2009 2010 29%

2010 2010 23%

R-507A

2000 2000 6%

2000 2009 0.4%

2001 2010 1%

2009 2010 4%

2010 2010 2%

R-407A

2000 2009 1%

2001 2010 0.3%

2009 2010 2%

2010 2010 0.4%

R-502 Large Retail Food

R-404A

2000 2000 14%

2000 2009 4%

2001 2010 13%

2009 2010 29%

2010 2010 23%

R-507A

2000 2000 6%

2000 2009 0.4%

2001 2010 1%

2009 2010 4%

2010 2010 2%

R-407A

2000 2009 1%

2001 2010 0.3%

2009 2010 2%

2010 2010 0.4%

HCFC-22 Large Condensing Units 

(Medium Retail Food)

R-404A 1995 2000 30%

2008 2010 30%

HFC-134a 1993 2005 30%

2006 2006 10%

HCFC-22 Small Condensing Units 

(Medium Retail Food)

R-404A

1995 2005 5%

2006 2006 25%

2008 2010 45%

R-507A 1995 2005 10%

2008 2010 15%

CFC-12 Small Retail Food

HFC-134a 1993 1995 85%

R-404A 1993 1996 7.5%

2000 2009 7.5%

R-507A 1993 1996 2.5%

2000 2009 2.5%
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1 2 3 4 5

Equipment Type and Original 

ODS Refrigerant Substitute Start Date End Dateb

Market 

Penetration of 

Substitutec

CO2 2010 2010 5%

CFC-12 Transport HFC-134a 1995 1999 100%

R-502 Transporte

HFC-134a 1993 1995 55%

R-404A 1993 1995 45%

HCFC-22 Screw Chillers

R-410A 2010 2020 36%

R-407C

2000 2009 1%

2009 2010 9%

2010 2020 54%

HCFC-22 Scroll Chillers

R-410A 2010 2020 36%

R-407C

2000 2009 1%

2009 2010 9%

2010 2020 54%

CFC-12 Reciprocating Chillers R-410A 2010 2020 40%

CFC-11 Centrifugal Chillers HFC-134a 2000 2010 100%

CFC-12 Centrifugal Chillers HFC-134a 2000 2010 100%

R-500 Chillers HFC-134a 2000 2010 100%

Source: VM IO File_v4.4_11.6.12

a

Interim transitions (e.g., from a CFC to HCFC-22 to HFCs) are not shown. For example, the retail food new-equipment market that originally 

used CFC-12 first transitioned from CFC-12 to R-502 and then to HCFC-22. Then, between 1995 and 2010, 83 percent of the HCFC-22 newequipment market is assumed to transition to R-404A, 13 percent to R-507A., and the remaining 4% to R-407A.

bThe end date is January 1 of the year. Transitions are assumed to occur instantaneously on January 1.

cThe market penetration of the substitute represents the percent of the HCFC-22 new-equipment market that is replaced by the substitute 

refrigerant.

dMultiple vintages of equipment are represented in this table (i.e. Two vintages of R-410A equipment are represented separately. Each vintage 

has a different charge size and they reach their maximum market penetration a year apart).

eThe R-502 transport refrigeration market transitions directly to HFC-134a and R-404A. There is no interim transition to HCFC-22.

fOnly 13 SEER HCFC-22 equipment is modeled by the Vintaging Model.

A.2 Limitations and Caveats

This analysis utilized the best data available from various sources. Nonetheless, when making projections 

several assumptions are required. The following caveats should be noted.

Recycled or Reclaimed Refrigerant

EPA’s Vintaging Model was used to determine the quantities of HCFC-22, HCFC-123, and HCFC-124

from existing (recycled or reclaimed) sources that can meet post-2015 servicing needs. For a given year, 

the model assumes that a certain percentage of refrigerant, which varies by end-use, is recovered from 

discarded equipment, while the remainder is emitted. The model aggregates the quantities recovered but 

does not distinguish the “pool” of refrigerant between quantities that are reclaimed versus those that are 

recycled. The model then assumes that the entire pool of recovered refrigerant re-enters the market 

within the same year. The model assumes that any additional need for refrigerant above the estimated 

amount recovered is met by virgin manufacture. The recovery pool and the remaining virgin manufacture 

are evaluated only at the most aggregate level, across all end-uses, and not at the end-use level, as the 

model does not differentiate between virgin and recycled refrigerant when calculating need for each enduse. This model attribute reflects a more realistic scenario in that reclaimers are not likely to only sell back 

to the end-use market sector from which the used refrigerant originated; rather, reclaimed refrigerant can 

be retailed to the overall AC and refrigeration industry. 

Under this modeled approach, the model does not consider the quantity of refrigerant that companies 

send off for destruction after equipment is decommissioned. Although the quantities of destroyed 

refrigerant are very small, they are not subtracted from the recovered pool, so the quantity available for 

reuse may be slightly overestimated in the model. Additionally, the model does not account for any 
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stockpiling of recovered refrigerant beyond a one-year timeframe, as discussed in Section 4.3. To the 

extent that stockpiling has occurred over the last few years, the quantity of recovered refrigerant modeled 

as re-entering the market may be overestimated in earlier years (i.e., when refrigerant is banked), and the 

quantity modeled as re-entering the market in later years may be underestimated (i.e., when the 

accumulated stockpile is accessed as a source). However, EPA has collected data on HCFC-22 inventory 

from a handful of companies and is using that information to inform the 2015-2019 rulemaking. 

Repairs with Dry-Shipped Appliance Components

While it is illegal to install new HCFC-22 systems, HCFC-22 components (e.g., condensing units, 

compressors, line sets, etc.) that are shipped without a refrigerant charge are available for repairs of 

systems installed before 2010. The Vintaging Model assumes that components will continue to be 

available for usual repairs of existing equipment. A sensitivity analysis was performed to assess the 

potential impact of dry-shipped appliance components on Vintaging Model projections of HCFC-22 

servicing need. The analysis estimated that servicing need could be 7 to 11 percent higher than the 

Vintaging Model projections when the installation of dry-shipped components is accounted for. Additional 

details of this analysis can be found in Appendix D. 

Date of Shipment versus Date of Installation of HCFC-22, HCFC-123, and HCFC-124 Units

It is feasible and potentially common for some AC and refrigeration appliances to be manufactured, 

charged, shipped and/or purchased in one year and installed in another year. Such would be the case, for 

example, for units designated for construction projects that have received building code approval and 

entered into a binding contract in one year but are completed in some future year. The Vintaging Model 

relies on shipment data of new AC and refrigeration equipment to help estimate new units entering the 

market for a given year. The model does not make adjustments to shipment data to reflect the date of 

installation since shipment data is the closest and best proxy to installation for the purposes of modeling. 

Thus, the model assumes the year of installation is the same as the year of shipment. Any equipment 

modeled as “shipped” in 2014, for example, is therefore assumed to be part of the installed base in that 

year. In summary, shipment date becomes the modeled installation date. For example, a residential 

unitary AC system shipped in 2009 would be in service for 15 years from that date, and would be retired 

in 2024. 

The model assumes that the entire fleet of 2014 HCFC-123 units within a given end-use are being 

installed and retired in the same year, whereas, in reality some of these units may instead be installed a 

year or two after shipment, starting their lifetime and servicing need a year or two after the shipment date, 

and hence, retiring a year or two after the retirement of the rest of the fleet. In this case, the model is not 

accurately reflecting the actual start and end date for servicing need for this subset of equipment. Instead, 

the model uses an average lifetime for each unique equipment type. This average is intended to account 

for units that are used for a few years less than the assumed useful life as well as those that are used 

well beyond their assumed useful life. Given the use of an average lifetime in the model, variations of a 

year or two between shipment and installation date should fall within “normal” fluctuations in lifetime seen 

in actual equipment use. Additionally, the majority of HCFC consumption comes from residential and 

commercial refrigeration and AC equipment that have lifetimes of 15 years or longer. Thus, any such 

equipment entering the market after 2015 is assumed to remain in service beyond 2030, when all HCFC 

consumption will be phased out in the United States. 

HCFC-123 in Fire Suppression

Per an amendment to the Clean Air Act passed in December 2011, HCFC use in fire suppression in 

nonresidential applications can continue after 2015. The Vintaging Model does not yet reflect the 

amendment to section 605(a) of the Clean Air Act; however, a scenario was run to estimate the use of 

Halotron I—the most widely used fire suppression agent containing HCFC-123—assuming production 

and consumption continued until December 31, 2019. Table A-3 presents projected servicing need

estimates for HCFC-123. 
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Table A-3: Projected HCFC-123 Servicing Need for 

Fire Suppression, 2015-2025, (Metric Tons)

HCFC 2015 2016 2017 2018 2019 2020 2025

HCFC-123 190 200 200 210 210 - -

These servicing need estimates were included in the analysis presented in the report. 
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Appendix B: HCFC Projections by End-Use

This Appendix provides estimates of the projected installed base of HCFC equipment by end-use and the 

projected servicing need of HCFCs for AC and refrigeration equipment. Descriptions of end-uses are 

provided in Section 3 of the report. For the purpose of this analysis, data on HCFC blend consumption for 

servicing are divided among the corresponding HCFC constituent(s) of that blend, according to the

nominal percent composition. However, to accurately portray the number of units containing HCFC-22, 

blends are not disaggregated when presenting the number of units of equipment (i.e., a unit running on a 

blend containing HCFC-22 counts as one unit). 

Tables B-1, B-2, and B-3 present the number of units of equipment using HCFC-22, HCFC-123, and 

HCFC-124 (or a blend containing these chemicals) respectively that are estimated to be in use in 2010, 

2015, 2020, and 2025. These estimates were developed based on EPA’s Vintaging Model, which takes 

into account recent input from stakeholders (EPA 2012). Sections 3.1 and 3.2 provide an overview of 

these AC and refrigeration end-uses. 

Table B-1: Estimated Number of HCFC-22 Units in Operationa

Equipment Type 2010 2015 2020 2025

Window Units 76,181,000 43,444,500 4,102,700 -

Packaged Terminal Units 2,478,800 1,355,100 123,100 -

Residential Unitary AC 76,099,300 46,893,700 14,663,600 -

Small Commercial Unitary AC 3,092,700 1,887,900 751,100 -

Large Commercial Unitary AC 198,100 127,400 53,700 -

Chillers 443,900 326,300 202,800 82,600

Dehumidifiers 1,282,100 670,200 - -

Water & Ground Source Heat Pumps 1,393,700 1,104,800 695,800 247,500

Other Mobile AC (Bus & Train AC) 18,800 4,300 - -

Subtotal AC 161,188,400 95,814,200 20,592,800 330,100

Retail Food 2,112,000 969,100 461,870 142,100

Industrial Process Refrigeration 8,700 7,500 5,600 3,500

Subtotal Refrigeration 2,120,700 976,600 467,500 145,600

Total 163,309,100 96,790,800 21,060,300 475,700

aCold Storage is not shown in this table because the model estimates this end-use based on 

cubic feet of storage, rather than number of units.

Table B-2: Estimated Number of HCFC-123 Units in Operation

Equipment Type 2010 2015 2020 2025

Chillers 40,900 47,600 49,500 39,800

Industrial Process Refrigeration 9,200 12,600 14,300 12,000

Fire Suppression 1,226,700 1,422,100 1,487,800 871,100

Total 1,276,800 1,482,300 1,551,600 922,900

Table B-3: Estimated Number of HCFC-124 Units In Operation

Equipment Type 2010 2015 2020 2025

Industrial Process Refrigeration 170 170 140 -

Medium Retail Food 27,700 27,200 18,800 -

Total 27,800 27,400 18,900 0

Table B-4 presents the metric tons of HCFC-22 estimated to be needed to service AC and refrigeration 

equipment in 2010, 2015, 2020, and 2025. Table B-5 presents the metric tons of HCFC-123 estimated to 

be needed to service and charge new and existing AC and refrigeration equipment in 2010, 2015, 2020, 
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and 2025. Table B-6 presents the metric tons of HCFC-124 estimated to be needed to service 

refrigeration equipment in 2010, 2015, 2020, and 2025. 

Table B-4: Projected HCFC-22 Servicing Need (Metric Tons)

Equipment Type 2010 2015 2020 2025

Window Units 270 160 <50 -

Packaged Terminal Units 90 <50 <50 -

Residential Unitary AC 37,900 24,400 9,500 -

Small Commercial Unitary AC 2,600 1,600 600 -

Large Commercial Unitary AC 300 190 80 -

Chillers 3,300 1,300 720 310

Dehumidifiers <50 <50 - -

Water & Ground Source Heat Pumps 290 230 140 50

Other Mobile AC (Bus & Train AC) 80 <50 - -

Total AC 44,800 27,900 11,100 360

Cold Storage 1,100 830 570 340

Retail Food 14,700 10,200 5,500 1,300

Industrial Process Refrigeration 8,900 7,200 5,400 3,500

Total Refrigeration 24,700 18,200 11,400 5,200

Total 69,400 46,100 22,500 5,500

Note: Totals do not sum due to independent rounding

Table B-5: Projected HCFC-123 Servicing Need (Metric Tons)

Equipment Type 2010 2015 2020 2025

Chillers 420 1,200 220 180

Industrial Process Refrigeration 260 770 370 290

Fire Suppression 160 190 - -

Total 850 2,200 590 470 

Table B-6: Projected HCFC-124 Servicing Need (Metric Tons)

Equipment Type 2010 2015 2020 2025

Industrial Process Refrigeration 2 2 2 -

Medium Retail Food 2 2 1 -

Total 5 5 4 -

Note: Totals do not sum due to independent rounding
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Appendix C: Changes to the Vintaging Model

Table C-1 summarizes the changes that have been made to EPA’s Vintaging Model and the HCFCs 

affected by the alteration since the 2009 Service Tail Report. Changes were made to the model based on 

industry research and feedback.

Table C-1: Changes Made to EPA’s Vintaging Model (Since 2009)

End Use Change(s) Made HCFCs 

Affected

Large Retail FoodaIncreased 1985 stock assumptions

Charge size reduced

Distributed systems and Secondary Loop Systems (SLS) were introduced 

(reduced charge sizes)

Increased lifetime from 15 years to 17.5 years

Increased disposal loss rate for DX (20%) and Distributed (18.5%) and 

decreased disposal loss rate for SLS (14%)

New refrigerants added to end-use (R-402A, R-422A, R-422D, R-407A, 

R-408A [R-402A and R-408A blends contain HCFC-22])

HCFC-22

Medium Retail Fooda End-Use was split into two end-uses (large condensing units and small 

condensing units)

Decreased 1985 stock assumptions

Additional refrigerant blends were added (R-401A [containing HCFC-22 

and HCFC-124], R-402A, HFC-134a)

Large condensing units have a larger annual leak rate (increased from

6% to 13%)

HCFC-22, 

HCFC-124

Small Retail FoodaIncreased 1985 stock assumptions

Decreased leak and service rate

HCFC-22

Small Commercial Unitary 

AC

Increased original 1985 stock assumptions HCFC-22

Large Commercial Unitary 

AC

Decreased original 1985 stock assumption HCFC-22

Residential Unitary AC Increased original 1985 stock assumptions

Removed transitions to R-407C (all equipment transitions from HCFC-22 

to R-410A)

Increased service loss rate (10%)

HCFC-22

a

ICF, 2011.
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Appendix D: Sensitivity Analyses

Although EPA’s assumptions are continually updated to improve and refine the accuracy of the model, 

future servicing need for HCFC-22 is affected by outside factors that may not be fully reflected. The 

extent to which the market price of HCFC-22 fluctuates and affects usage patterns and transitions and

how HCFC allocations in recent years affect future servicing needs are two examples of market influence 

that is not captured in the current assessment. 

This Appendix presents analyses performed to determine the effect that different assumptions may have 

on HCFC-22 service need. The following sensitivity analyses were considered individually (i.e., the effects 

on HCFC-22 servicing need resulting from each analysis are not additive or cumulative): 

 Smaller system charge sizes;

 Lower equipment loss rates;

 Earlier transitions to alternatives; and

 Longer equipment lifetimes due to repairs using dry-shipped condensing units.

D.1 Smaller System Charge Size

This sensitivity analysis explores the impact on servicing need of a smaller charge size in residential 

unitary AC equipment. Residential unitary AC accounts for approximately 50 percent of the total servicing 

need across all refrigeration and AC end-uses for 2015 to 2019. This end-use represents such a large 

portion of the total servicing need for HCFC-22 in refrigeration and AC equipment due in part to its high 

installed base, larger equipment charge sizes, long lifetimes, and high loss rates. A large number of 

residential unitary AC units containing HCFC-22 will continue to be in use through 2023, and they are 

projected to require a significant amount of HCFC-22 to meet their servicing need. 

In 2001, the U.S. Department of Energy (DOE) set a stricter seasonal energy efficiency ratio (SEER) 

standard for residential unitary ACs and heat pumps. The minimum efficiency standard of residential 

unitary ACs and heat pumps was raised by 30 percent to a 13 SEER for all such units manufactured for 

sale on or after January 23, 2006 (DOE 2001; DOE 2004). These increased SEER requirements are 

reflected in this report, although earlier SEER requirements are not explicitly reflected. As shown in the 

Table D-1, the EPA currently assumes that the 13 SEER vintage of HCFC-22 residential unitary AC 

equipment uses a charge size of approximately 4.8 kg.

Table D-1: Charge Size, Loss Rate, and Lifetime for HCFC-22 Residential AC Equipment

End-Use

Original

Residential Unitary AC

13 SEER

Residential Unitary AC

Charge Size (kg) 3.4 4.8

Annual Loss Rate 13.6% 13.6%

Lifetime (years) 15 15

Manufactured From 1992 - 2005 2006 – 2009

This analysis examines the potential effects on service need of a smaller charge size of 4 kg for HCFC-22 

13 SEER residential unitary AC equipment. This change results in a 2 to 7 percent decrease in total 

HCFC-22 service need across all refrigeration and AC end-uses between 2015 and 2023, as shown in 

Table D-2. After 2023, all HCFC-22 residential unitary AC equipment is modeled as having reached endof-life, so there is no longer servicing need for the end-use. 
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Table D-2: HCFC-22 Service Need for Residential AC from Smaller 13 SEER Charge Size, 2015-

2025

End-Use 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Residential 

Unitary 

AC

VM Baseline 24,400 21,700 18,900 16,000 13,000 9,500 6,500 3,900 1,800 - -

Lower 

Charge 23,200 20,500 17,600 14,700 11,600 8,000 5,400 3,300 1,500 - -

Total

VM Baseline 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Lower 

Charge 45,000 40,400 35,500 31,000 26,300 21,000 16,800 13,100 9,800 6,900 5,500

Percent Decrease in 

Total HCFC-22 Need

(All Ref/AC End Uses)

2% 3% 3% 4% 5% 7% 6% 5% 3% - -

Note: Totals may not sum due to independent rounding.

D.2 Lower Equipment Loss Rate 

This sensitivity analysis explores the impact on servicing need of a lower loss rate for residential unitary 

AC, large and medium retail food refrigeration, and cold storage units. With the price of HCFC-22 

increasing, feedback from stakeholders has suggested that service technicians may now be more careful 

with the refrigerant, resulting in lower loss rates than those estimated in this report.

Between 2015 and 2021, service need from residential unitary AC, large retail food refrigeration, medium 

retail food refrigeration (large condensing units), and cold storage together are projected to account for 

approximately 70 to 80 percent of the total service need across all refrigeration and AC end-uses; by 

2025, this proportion drops to 30 percent of total need.

30 These four end-uses represent a large portion of 

the total servicing need for HCFC-22 in refrigeration and AC equipment due in part to their high installed 

base, larger equipment charge sizes, long lifetimes, and high modeled loss rates. A large number of units 

containing HCFC-22 within these end-uses will continue to be in use through 2025, and they are 

expected to require a significant amount of HCFC-22 to meet their servicing need. 

The annual loss rates for these end-uses (as modeled in the Vintaging Model) are shown in Table D-3.

The annual loss rate is equal to the annual leak rate plus the annual emission rate from servicing. 

Table D-3: Annual Loss Rate and Lifetime for HCFC-22 Residential AC, Large Retail Food 

Refrigeration, Medium Retail Food Refrigeration (Large Condensing Units), and Cold Storage 

Equipment

End-Use

HCFC-22 Equipment 

Charge Size (kg)

Lifetime 

(years)

HCFC-22 Equipment 

Annual Loss Rate

Residential Unitary AC 3-5 15 14%

Large Retail Food 1,360-1,800 18 30%

Medium Retail Food (Large Condensing Units) 25 20 15%

Cold Storage <0.01a 20-25 20%

aCold storage charge size presented in kilograms/cubic foot

This analysis examines the potential effects of a lower loss rate for HCFC-22 equipment on service need, 

by assuming that residential unitary AC, large retail food refrigeration, medium retail food refrigeration 

(large condensing units), and cold storage units undergo annual leak tightening beginning in 2012. The 

following specific assumptions are made:

 Residential Unitary AC: Annual loss rate will decline by 1 percentage point per year until the loss 

rate equals 10 percent.

 

30 Ref/AC end-uses include window units, packaged-terminal AC, residential unitary AC, small commercial unitary AC, large 

commercial unitary AC, chillers, dehumidifiers, water & ground source heat pumps, other mobile AC, cold storage, retail food,

refrigerated transport, and industrial process refrigeration.
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 Large Retail Food: Annual loss rate will decline by 5 percentage points so that the loss rate 

equals 25 percent.

 Medium Retail Food (Large Condensing Units): Annual loss rates will decline by 1 percentage 

point per year until the loss rate equals 10 percent.

 Cold Storage: Annual loss rate will decline by 1 percentage point per year until the loss rate 

equals 15 percent.

These changes result in a 10 to 23 percent decrease in total HCFC-22 service need across all 

refrigeration and AC end-uses between 2015 and 2025, as shown in Table D-4. 

Table D-4: HCFC-22 Service Need for Residential AC, Large Retail Food Refrigeration, Medium 

Retail Food (Large Condensing Units), and Cold Storage from Lower Annual Loss Rates, 2015-

2025

End-Use 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Residential 

Unitary AC31

VM 

Baseline 24,400 21,700 18,900 16,000 13,000 9,500 6,500 3,900 1,800 - -

Lower 

Loss 17,200 15,300 13,300 11,300 9,200 6,700 4,600 2,700 1,200 - -

Large Retail 

Food

VM 

Baseline 9,100 8,200 7,200 6,500 5,800 4,900 4,200 3,400 2,600 1,900 1,100

Lower 

Loss 6,000 5,400 4,800 4,300 3,800 3,300 2,700 2,200 1,700 1,200 700

Medium 

Retail Food 

(Large 

Condensing 

Units)

VM 

Baseline 900 800 700 700 600 500 500 400 300 300 200

Lower 

Loss 700 600 500 400 400 400 300 300 200 200 100

Cold Storage

VM 

Baseline 800 800 700 700 600 600 500 500 400 400 300

Lower 

Loss 700 600 500 500 500 400 400 400 300 300 300

Total

VM 

Baseline 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Lower 

Loss 35,400 31,900 28,300 25,000 21,600 17,700 14,300 11,200 8,400 6,100 5,000

Percent Decrease in 

Total HCFC-22 Need

(All Ref/AC End Uses)

23% 23% 23% 23% 22% 21% 20% 19% 16% 12% 10%

Note: Totals may not sum due to independent rounding.

D.3 Earlier Equipment Transitions to Alternatives

This sensitivity analysis explores the impact on servicing need of an earlier transition of HCFC-22 

residential unitary AC, retail food refrigeration, and IPR equipment to alternative refrigerants. Of total 

HCFC-22 service need from 2015 to 2020, residential unitary AC, retail food refrigeration, and industrial 

process refrigeration (IPR) together account for approximately 90 percent.32 As the price of HCFC-22 

increased and as equipment reached the end of its useful life, feedback from stakeholders indicates that 

retrofits and system replacements may have occurred more rapidly than modeled in this report.

New residential unitary AC equipment completed the transition from HCFC-22 to R-410A as of 2010, due 

to the ban on the use of virgin HCFC-22 to service new refrigeration and air-conditioning equipment. 

Although no new residential AC systems are manufactured today using HCFC-22, this report assumes 

 

31 Since the Vintaging Model assumes all new installations take place on January 1, the final HCFC-22 residential unitary AC 

installations are modeled as taking place on January 1, 2009. Thus, the 15 year modeled lifetime expires at the end of 2023 and so 

HCFC-22 servicing demand is modeled at zero starting in 2024.

32 Refrigeration and AC end-uses include window units, packaged-terminal AC, residential unitary AC, small commercial unitary AC, 

large commercial unitary AC, chillers, dehumidifiers, water & ground source heat pumps, other mobile AC, cold storage, retail food, 

refrigerated transport, and industrial process refrigeration.
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that an estimated 50 percent of the residential unitary AC market in the United States was using HCFC22 through 2009. As a result, servicing need for HCFC-22 is modeled for another 15 years—through the 

end of 2023—the full 15 year lifetime of these units. 

A significant portion of retail food refrigeration, which consists of large direct expansion (DX) systems, 

large condensing units, small condensing units, and stand-alone units, were also using HCFC-22 or 

blends containing HCFC-22 up until 2010; however, transitions away from HCFC-22 to other refrigerants 

and refrigerant blends (e.g., HFC-134a, R-507, and R-404A) are modeled as early as 1993. In the retail 

food sector, industry contacts, especially distributors, are suggesting that HCFC-22 sales have dropped 

off significantly in recent years, and that retrofits or system replacements are undertaken more frequently. 

While historical HCFC-22 use in IPR systems was somewhat limited—HCFC-22 systems only accounted 

for approximately 10-15 percent of the total IPR market, some HCFC-22 units continued to be 

manufactured until 2010 (as modeled in this report). These units have significant charge sizes and a 

lifetime of approximately 25 years, which contribute to the high service need for these units beyond 2015.

This analysis examines the potential effects of early retirement of HCFC-22 equipment on service need, 

by assuming that 20 percent of residential unitary air-conditioning, retail food refrigeration, and industrial 

process refrigeration equipment are retired 5 years earlier than this report assumes, beginning in 2010

(e.g., 20 percent of equipment that would have retired in 2015 is being retired in 2010 instead). These 

changes result in a 9 to 14 percent decrease in HCFC-22 service need between 2015 and 2025, as 

shown in Table D-5.

Table D-5: HCFC-22 Service Need for Residential AC, Retail Food Refrigeration, and Industrial 

Process Refrigeration from Early Retirement, 2015-2025

End-Use 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Residential

VM Baseline 24,400 21,700 18,900 16,000 13,000 9,500 6,500 3,900 1,800 - -

Early

Transition 21,400 18,700 15,900 13,200 10,400 7,600 5,200 3,100 1,400 - -

Retail Food

VM Baseline 10,200 9,200 8,000 7,200 6,400 5,500 4,700 3,800 3,000 2,200 1,300

Early

Transition 9,300 8,300 7,200 6,400 5,600 4,700 3,800 3,100 2,400 1,700 1,100

IPR

VM Baseline 7,200 6,800 6,400 6,000 5,700 5,400 5,000 4,600 4,300 3,900 3,500

Early

Transition 6,800 6,400 6,000 5,700 5,300 5,000 4,600 4,200 3,900 3,500 3,100

Total

VM 

Baseline 46,100 41,600 36,700 32,300 27,700 22,500 17,900 13,700 10,100 6,900 5,500

Early 

Transition 41,800 37,300 32,600 28,300 23,900 19,400 15,400 11,800 8,700 6,100 4,900

Percent Decrease in Total 

HCFC-22 Need 9% 10% 11% 13% 14% 14% 14% 14% 13% 12% 12%

Note: Totals may not sum due to independent rounding.

D.4 Longer Equipment Lifetimes Due to Repairs Using Dryshipped Condensing Units 

This sensitivity analysis explores the impact on servicing need of repairing residential unitary AC systems 

with dry-shipped condensing units (CUs). Although new HCFC-22 systems were banned in 2010, 

replacement dry-shipped CUs can be used for repairing systems, potentially extending the lifetime of the 

AC unit (and servicing need). This analysis assumes existing residential unitary AC units using HCFC-22 

are repaired with dry-shipped CUs. Table D-6 shows the percentage of new shipments that EPA assumes 

are HCFC-22 CUs instead of R-410a CUs. 

Table D-6: Assumptions for Percentage of New CU Shipments Going to HCFC-22 Repairs

Year 2010 2011 2012 2013 2014 2015 2016 2017 2018

Percentage of New Shipments 5% 20% 15% 10% 10% 5% 5% 5% 0%
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The analysis further assumes that repairing systems with dry-shipped CUs extends the equipment lifetime 

by 10 years.

Table D-7 shows the resulting increase in need in the residential unitary AC end-use and the percent 

increase in service need compared to total need from all refrigeration and air-conditioning end-uses

associated with increasing equipment lifetimes by 10 years with dry-shipped CUs. This change results in 

a 7 to 11 percent increase in HCFC-22 service need between 2015 and 2025.

Table D-7: Additional HCFC-22 Need in Residential Unitary AC from Dry-Shipped CUs, 2015-2025

End-Use 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Baseline 

Servicing Need

for Residential 

Unitary AC

24,400 21,700 18,900 16,000 13,000 9,500 6,500 3,900 1,800 - -

Additional 

Modeled 

Servicing Need

for Residential 

Unitary AC

3,700 3,900 4,100 2,700 2,700 2,600 1,900 1,300 900 600 400

Total Residential 

Unitary AC 

Servicing Need

28,100 25,600 23,000 18,800 15,700 12,100 8,300 5,200 2,700 600 400

Increase in Total 

Need for All 

HCFC-22 Ref/AC 

Servicing

8% 9% 11% 8% 10% 11% 10% 10% 9% 8% 7%

Note: Totals may not sum due to independent rounding.
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Appendix E: HCFC-22 Inventory Estimate

In August 2013, EPA asked questions of up to nine companies about their HCFC-22 inventory and sales. 

Under section 114(a) of the Clean Air Act, for the purpose of carrying out any provision of the Act, EPA 

has the authority to ask any person who is subject to any requirement of the Act to establish and maintain 

such records, make such reports, and provide such other information as the Administrator may 

reasonably require. Many stakeholders encouraged EPA to use this authority to gather data on HCFC-22 

inventory levels in particular. 

EPA used the data received in response to its section 114 request to substantiate what the agency had 

already heard from many industry representatives: HCFC-22 inventory is still high, and potentially higher 

than the agency had previously estimated in the fall of 2011. Concurrent with the 2012-2014 Proposed 

Rule, EPA published Analysis of HCFC– 22 Servicing Needs in the U.S. Air Conditioning and 

Refrigeration Sector: Additional Considerations for Estimating Virgin Demand (“Adjustment Memo”), 

which stated that EPA believed HCFC-22 inventory was between 22,700 and 45,400 MT. Based on 

inventory data from a limited number of companies as of December 31, 2012, as well as other information 

received by the agency during the development of this proposed rule, EPA knows HCFC-22 inventory is 

higher than its previous estimate. 

Given that inventory at the end of 2012 was higher than 45,400 MT, EPA expects that a significant 

amount of HCFC-22 servicing need in 2015-2019 can be met by existing stocks. Since HCFC-22 

inventory is quite large, and may even grow in 2013 and 2014, the preamble to the 2015-2019 Proposed 

Rule states that EPA is proposing to account for up to 10,000 MT of inventory drawdown each year as it 

considers an appropriate HCFC-22 consumption allocation. 
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References

Airgas. 2006. Personal communication between Lauren Flinn, ICF International, and Bob Mueller, 

Director, Utility & CPI Industries, Airgas. August 2006. 

The Alliance for Responsible Atmospheric Policy. 2006. Comment submitted in response to EPA’s Notice 

of Data Availability (NODA, 70 FR 67172), November 4, 2005. EDocket ID Number, OAR-2003-0130, 

Document ID No. 0172, 0174, January 19, 2006, January 26, 2006.

American Pacific. 2013. Personal communication between Derina Man, ICF International, and Jeff 

Gibson, American Pacific. April 2013.

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Amtrak. July 2005. 

ARI. 2005. Personal communication and transcribed correspondence between Lauren Flinn, ICF 

Consulting and Karim Amrane, Air-Conditioning and Refrigeration Institute (ARI). March to June 2005. 

Arkema. 2009. Comment submitted in response to EPA’s Notice of Data Availability (NODA, 40 FR Part 

82). December 23, 2008. EDocket ID Number, OAR-2008-0496, Document ID No. 0111.1, March, 9, 

2009. 

Badger/Kidde. 2013. Personal communication between Derina Man, ICF International, and Tom Lucier, 

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Carrier Corporation. 2005b. Personal communication between Iliriana Mushkolaj, ICF Consulting and 

Chris Repice, Carrier Corporation. June 2005.

Cold Ships. 2009. Personal communication between Lauren Flinn, ICF International and Gerald Donovan, 

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Updated Projected Servicing Needs in the U.S. Air-Conditioning, Refrigeration, and Fire Suppression Sectors for 2015 to 2025

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Updated Projected Servicing Needs in the U.S. Air-Conditioning, Refrigeration, and Fire Suppression Sectors for 2015 to 2025

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Updated Projected Servicing Needs in the U.S. Air-Conditioning, Refrigeration, and Fire Suppression Sectors for 2015 to 2025

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