Labeling HCFC Products Starting 2015:

What You Need to Know

What is an HCFC?

Hydrochlorofluorocarbons 

(HCFCs) are used globally in many 

applications—as refrigerants, foam 

blowing agents, fire suppression 

agents, sterilants, and solvents. 

These chemicals deplete the Earth’s 

stratospheric ozone layer, which 

protects humans and the environment 

from harmful ultraviolet (UV) radiation.

Products imported or manufactured after January 1, 2015 

that contain or were manufactured with an HCFC must 

bear a warning label before they can be introduced into 

interstate commerce. Imported products must be labeled 

before clearing U.S. Customs.

Regulatory basis for product labeling 

requirements

Product labeling is mandated by section 611 of the Clean 

Air Act. The full labeling requirements can be found in the 

Code of Federal Regulations at Title 40 Part 82 Subpart E 

(40 CFR 82.100–82.124).

Which products will likely be affected 

by the requirement?

The Clean Air Act greatly restricts the production and 

import of HCFCs, as well as their use in equipment and 

products. Because of these restrictions, the universe of 

products potentially subject to labeling requirements is 

narrow, and consists primarily of imported products.

Products that could contain HCFCs, and may still be imported:

Certain foam products, which could include: refrigerators; water heaters; vending machines; building/roof insulation; 

pipe wrap and other insulating foam products; boats or other equipment containing foam for buoyancy purposes; 

taxidermy manikins made of rigid polyurethane foam

Spray foam (specifically aerosolized polyurethane foam) sometimes referred to as insulating foam sealant

Certain imported aerosol, solvent, and adhesive products

Domestically manufactured products that contain HCFCs:

Portable fire extinguishers containing HCFC blends

Products that may still be manufactured with HCFCs in the U.S. or abroad:

Electronics, aerospace equipment, medical equipment, and critical infrastructure where the product was cleaned or 

lubricated with an HCFC solvent
What must the label say and where should it appear?

The purpose of the label is to allow consumers to make informed choices before buying products containing 

or manufactured with HCFCs. To that end, the warning statement must be clearly legible and conspicuous 

such that it is likely to be read by consumers prior to making their purchase. The label must include the 

following statement:

FOR MORE INFORMATION visit http://www.epa.gov/ozone/title6/labeling/index.html, or contact 

Elizabeth Whiteley at 202-343-9310 or whiteley.elizabeth@epa.gov.

Printed on 100% recycled/recyclable paper with a minimum 

50% post-consumer waste using vegetable-based inks.

The warning may be printed directly on a product or its outer packaging or on an alternative label, including 

the following conspicuous placements:

• Principal display panel or display panel area

• Alternative labels, such as hang tags, stickers, or similar overlabeling

• Outer packaging

• Supplemental printed materials, such as invoices, bills of lading, or package inserts

• Promotional materials, such that the warning statement is visible before the time of purchase 

Additional information on labeling placement and requirements can be found in the Code of Federal 

Regulations at Title 40 Part 82 Subpart E (40 CFR 82.108 and 82.110). The labeling regulations 

(40 CFR 82.100–82.124) also contain certain exemptions to the requirements, as well as requirements for 

when the label must accompany a product that is sold for use in manufacturing another product.

WARNING: [Contains / Manufactured with] [name of HCFC], a substance that harms public health 

and environment by destroying ozone in the upper atmosphere.

Office of Air and Radiation (6205J) 

EPA-402-E-13-001

August 2013