Comments regarding the Proposed Rule - Protection of 

Stratospheric Ozone: Change of Listing Status for Certain 

Substitutes under the Significant New Alternatives Policy Program 

(SNAP). 

Maersk Container Industry, part of the A. P. Meller- Maersk group, is the 

world's number two manufacturer of intermodal refrigerated containers, 

aka reefers. Our Star Cool units are omnipresent in international food 

trade and are currently the most energy-efficient refrigerating machines 

on the marine container market, according to independent customer tests. 

Furthermore, our insulation foaming solution, SuPoTec®, was invented 

and marketed several years ahead of the enactment of the European 

legislation to protect the stratospheric ozone layer. 

As solicited by the EPA, we are commenting on the use and viability of 

low-GWP refrigerants (including R-744 and HCs) in refrigerated transport. 

Maersk Container Industry commends the US administration for its 

climate action plan and the recently announced efforts to reduce the 

emissions of hydrofluorocarbons (HFCs). Our company has already 

invested considerable resources in finding climate-friendly alternatives to 

high-GWP coolants such as R134a, which is currently used by Star Cool. 

Here's a rundown of MCI's progress so far: 

1. Ongoing research into the replacement of HFCs with low GWP 

refrigerants, including hydrocarbons (HCs): 

a. HCs and other flammable substances could be safely used 

as refrigerants in reefers, according to MCI own 

calculations, ongoing tests and simulations, as well as a 

risk assessment for operation led by a classification 

society. 

b. The substitution of HFC refrigerants with HCs will reduce 

the total GHG emissions of a reefer machine by at least 15 

per cent throughout its service life. 

c. A gradual introduction of HC refrigerants in the current 

global marine reefer fleet will lead to a cumulative 

reduction of GHG emissions by approximately six million 

tonnes C02 eq in ten years compared to R134a. This 

estimate takes into account both emissions and energy 

usage of the current reefer fleet. 

2. Continuing efforts in the development of safe reefer design with 

the approach "as safe as before or better'' in all operations. 
MCI wholeheartedly supports all research efforts to limit the use of HFCs, 

and we believe we will be able to market our own climate-friendly solution 

in 3-4 years. Our guiding philosophy is to develop a technology that 

enables the industry to move away from high-GWP refrigerants such as 

R134a without simultaneously increasing safety risks and GHG 

emissions from operations. 

Therefore our interest is in the safe use of HCs within the boundaries of 

future legislation. 

With this in mind, MCI seeks to partner with the US Administration and 

register the safe usage of HCs in reefer container refrigeration systems 

within the US EPA SNAP framework. 

Please don't hesitate to contact us if you would like more information 

about our development of safe alternatives to high-GWP refrigerants. We 

will be happy to submit further information at a later stage. 

fte Heide 

Global Head of Research and Development 

Maersk Container Industry 

Email: 

Direct telephone: 

Mobile: 

mhe@maerskbox.com 

(+45) 73 64 35 12 ( +45) 24 23 24 45