December 5, 2014

Rebecca von dem Hagen, Mail Code 6205T

Stratospheric Protection Division, Office of Atmospheric Programs

Environmental Protection Agency

1200 Pennsylvania Ave. NW.

Washington, DC 20460

Subject: Docket ID Number EPA–HQ–OAR–2014–0198

In response to your recent request, this letter provides additional information regarding the U.S. 

Environmental Protection Agency (EPA) notice of proposed rulemaking (NOPR) about changes to the

listing status for certain substitutes under the SNAP program. Coca-Cola believes the SNAP program is 

an effective vehicle to reduce f-gas atmospheric pollutants and address climate protection.

The rulemaking proposes a singular transition date of January 1, 2016 to set HFC-134a and other HFC 

refrigerant blends as unacceptable for new stand-alone retail food refrigeration and new vending 

machines because acceptable alternatives exist [79 Federal Register 46126 (August 6, 2014), to amend 

40 C.F.R. Part 82]. However, these acceptable alternatives (R744, R717, R600a, R290, R441a) currently 

do not have essential system components commercially available in all refrigerating capacities to 

establish efficient equipment for the full range of equipment sizes.

The supply chain for a preferred alternative, CO2 refrigerant (R744), is not fully developed at this time. 

R744 is attractive because it offers the lowest GWP, is a readily available substance, is nontoxic and safe, 

and provides the best coverage within our broad equipment portfolio. Coca-Cola believes that R744 has 

the potential to provide a single refrigerant solution.

R744 solutions will not be available for the full range of retail food refrigeration equipment cabinet sizes 

by the end of use deadline of January 1, 2016 specified in the NOPR. Components are in development 

and/or being prototyped, but are yet to be tooled and scaled-up for production. The chart of Table 1 

below differentiates when the various sizes are expected to be achieved and available for commercial 

application. Understand that even when the appropriate components become commercially available, 

time must still be allocated to develop the new refrigeration system for the appliance, test and optimize 

it, secure safety certification, and make arrangements for production.

Coca-Cola recommends that the EPA refine the timetable of the NOPR to reflect what can be realistically 

achieved as expressed below in this table.

Thank you for soliciting our input. Do not hesitate to request greater detail, if needed.

Very Truly Yours

Bruce Karas,

V.P., Environmental and Sustainability

Coca-Cola North America
Table 1 – Expected dates for available R744 commercial refrigerators and vending machines

Machine categories Expected Date Comment

Available

Large countertop visicooler

Medium temperature, self-contained,

transparent door(s), 3 – 7 cu.ft.

Available

______

Floor standing single-door visicooler

Medium temperature, self-contained,

one transparent door, 8 – 28 cu.ft.

Available

______

Floor standing two-door visicooler

Medium temperature, self-contained,

two transparent doors, 18 – 45 cu.ft.

Available

______

Solid door zone-cooled refrigerated 

beverage vending machine

Available

______

Near 

Term

Glass door fully-cooled refrigerated 

beverage vending machine

~ January 1, 2016 Refrigeration system optimization still 

ongoing by OEMs.

Delayed Commercialization

(January 1, 2016 +1-2 years)

Chest & barrel cooler

Medium temperature, self-contained, 

horizontal transparent door(s), < 6 cu.ft.

~ January 1, 2017

Additional supporting components 

needed to optimize performance for 

Energy Star, then system optimization.

Floor standing three or more-door 

visicooler

Medium temperature, self-contained, 

> 3 transparent doors, > 45 cu.ft.

No R744 compressor > 1200 W 

commercially available until late 2015. 

Time then needed to develop & 

optimize systems, tooling, and secure 

approvals.

Small countertop visicooler

Medium temperature, self-contained,

transparent door(s), < 3 cu.ft.

~ January 1, 2018 No suitable R744 small compressor (< 

300W) commercially available until 

January 2017. Price increase of 8-20% 

likely.

Significant Challenges

(January 1, 2016 +3-4 years)

Supermarket fast-lane merchandiser

Medium temperature, self-contained, 

2 or more vertical glass doors, 9 – 18 cu.ft.

~ January 1, 2019 Suitable R744 compressor (i.e., variable 

capacity) to achieve Energy Star not 

developed. Also, radical system 

redesign required. Price increase of 8-

20% likely.

Open-front cooler (no doors)

Medium temperature, self-contained, 

> 13 - 26 cu.ft.

~ January 1, 2020

Development of cabinets cannot begin 

until after > 1200W compressor is 

available, and higher priority sizes are 

completed.

Open-front cooler (no doors)

Medium temperature, self-contained, 

> 26 cu.ft.

1600W R744 compressor on drawing 

board for after commercializing smaller 

sizes. Not expected before 2019.

Commercially available: Model in the proper electrical voltage for the U.S. power grid, with all 

regulatory and industry approvals, produced by at least one manufacturer with production capacity, and 

available for purchase, shipment and use in the marketplace.