ENVIRONMENTAL INVESTIGATION AGENCY

P.O. BOX 53343 Washington DC, 20009

TEL +1 202 483 6621 FAX +1 202 986 8626

www.eia-global.org

info@eia-global.org

October 6th, 2015

Administrator Regina McCarthy 

Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460

By email and hand delivered: 

CC: Sarah Dunham, Director, Office of Atmospheric Programs

 Cindy Newberg, Chief, Alternatives and Emissions Reduction Branch

Dear Administrator McCarthy: 

The Environmental Investigation Agency (EIA) congratulates the United States Environmental 

Protection Agency (EPA) on the two recently finalized rulemakings which alter the alternatives approved 

by the Significant New Alternatives Policy (SNAP) program: SNAP Rule 19 - EPA–HQ–OAR–2013–

0748; FRL–9922–26– OAR] RIN 2060–AS04, Listing of Substitutes for Refrigeration and Air 

Conditioning and Revision of the Venting Prohibition for Certain Refrigerant Substitutes (Rule 19), and 

SNAP Rule 20 – EPA–HQ–OAR–2014–0198; FRL-9926-55-OAR] RIN 2060-AS18, Change of Listing 

Status for Certain Substitutes under the Significant New Alternatives Policy Program (Rule 20). 

EPA’s SNAP Rules 19 and 20 were a significant first step toward meeting the President’s Climate 

Action Plan (CAP) and eliminating the use of unnecessary high-GWP alternatives, particularly in the 

retail food refrigeration and motor vehicle air conditioning end-uses, while simultaneously approving 

many new low-GWP alternatives for use in the U.S. market. This petition is filed pursuant to Section 

612(d) of the Clean Air Act (CAA) and 40 CFR 82.184(b)(3). Under section 612 of the Clean Air Act, the 

EPA has the authority to evaluate alternatives to ozone-depleting substances and publish a list of 

acceptable and unacceptable substitutes through the SNAP Program. Under its authority, the EPA used 

notice-and-comment rulemaking both to remove the high-GWP substitutes in SNAP Rule 20 from the list 

of acceptable substitutes, and to list the low-GWP alternatives of SNAP Rule 19 as acceptable subject to 

use conditions or narrowed use limits.

I. Background and Summary of Petition 

EIA hereby petitions the EPA to issue an additional notice-and-comment rulemaking under the 

same authority and reasoning exercised in Rule 20 to change the SNAP status of additional high-GWP 

refrigerants and deem them as unacceptable (or acceptable subject to use restrictions only in specific types 

of equipment where the EPA determines there are not sufficient proven low-GWP alternatives) across a 

number of sectors and end-uses. The full list of requests in this Petition is provided in this summary, in a 
2

detailed table summarizing the list of high-GWP refrigerants covered by this Petition is set forth in the 

Appendix and detailed narratives are set forth in the body of the petition for each end-use. 

In the proposal for Rule 20, EPA requested comment on the use and viability of low-GWP 

refrigerants including R-744, R-717, and hydrocarbons in additional end-uses including refrigerated 

transport, cold storage warehouses, and industrial process refrigeration with the intent of considering

listing additional high-GWP substitutes as unacceptable for these additional end-uses.

1

The overall 

structure of this Petition is based upon a response to the EPA’s request for comment, covering a list of 

substitutes with GWPs comparable to or higher than those high-GWP HFCs removed under Rule 20, and 

expanding this approach to additional sectors and end-uses where there are sufficient proven low-GWP 

alternatives available to warrant the change in status of the listed high-GWP HFCs. 

Although EPA’s SNAP program does not adopt specific GWP thresholds as the sole criteria for 

rulemakings, it is consistent with EPA’s mandate and authority under the Climate Action Plan and CAA

to undertake an additional rulemaking that takes a graduated approach to establishing timeframes for 

additional changes in listing status for high-GWP HFCs based upon the different ranges of GWP and the 

availability of low-GWP alternatives. With this in mind, proposed changes in listing status and 

accompanying timeframes outlined in this Petition are generally structured to achieve a graduated 

elimination of additional high-GWP HFCs beginning with the highest-GWP substitutes in the most 

immediate timeframe, progressing in stages to cover additional substitutes with timeframes for effective 

dates in 2017, 2019 and 2022. This tiered approach is intended to serve as a framework for eliminating the 

alternatives with the greatest overall impact on human health and the environment in the shortest feasible 

timeframe, while sending a clear longer term signal to encourage private sector investment in lowemissions technology and the related infrastructure. Setting multiple dates in a single rulemaking for 

staged changes in listing status will also allow manufacturers and end users reasonable timelines for 

undertaking a transition in each of their manufacturing lines for equipment using existing refrigerants 

directly to the lowest-GWP alternatives available. In order to ensure that the rulemaking has this policy 

impact, the EPA must issue a rulemaking that comprehensively addresses all three tiers of high-GWP 

HFCs in the sectors as set forth herein. Such an approach will allow for the most significant and rapid 

transitions away from HFCs and ensure maximum gains for the environment, human health and energy 

efficiency.

The three tiers consist of the following: the first and highest-GWP tier includes SF6, HFC-23 and 

HFC-23 blends R-508A and R-508B, which should be listed unacceptable as of January 1, 2017 or one 

year following the passage of a final rule. SF6, with GWP of 22,800, HFC-23 with GWP of 14,800 and 

HFC-23 blends R-508A and R-508B with GWPs above 13,000, are between ten to fifteen times more 

damaging to the climate than other refrigerants already eliminated under Rule 20, making them by far the 

highest-GWP substitutes allowed under the SNAP program. SF6, HFC-23 and HFC-23 blends should be 

eliminated in all remaining end-uses, which include fire suppression equipment, very low temperature 

refrigeration, and industrial process refrigeration. In the second tier, EPA should target all chemicals with 

a GWP greater than 3,000 to be listed as unacceptable for all remaining stationary refrigeration end-uses 

 

1

http://www.gpo.gov/fdsys/pkg/FR-2014-08-06/pdf/2014-18494.pdf, see p46149.
3

by January 1, 2019. This class of alternatives includes HFC-236fa, HFC-227ea, HFC-507A, and HFC404A. For certain end-uses, such as household refrigeration, where low-GWP alternatives are sufficient, it 

is also feasible to include substitutes with GWPs ranging from 1,430-3,000 in the same timeframe,

including HFC-410A, HFC-134a, and HFC-407A/B/C, while for other end-uses with fewer available lowGWP alternatives, these substitutes are included in the third tier to allow additional time for industry to 

transition. The third tier should cover all remaining substitutes with GWPs higher than 1,000, including

HFC-134a, R-410A, with a suggested effective date of January 1, 2022. While these timelines should be 

feasible for refrigeration end-uses as covered under this Petition, certain other air conditioning end-uses 

such as split and unitary air conditioning will require additional time and should be considered under a 

subsequent rulemaking. 

Finally, this petition addresses the issue of the recently SNAP listed high-GWP HFC blends: 

alternatives R-513A, R-450A, R-448A, and R-449 These chemicals, with GWPs of approximately 

between 600-1400, were recently listed under [EPA–HQ–OAR–2003–0118; FRL–9918–30– OAR] RIN 

2060–AG12 Protection of Stratospheric Ozone: Determination 29 for Significant New Alternatives Policy 

Program (Notice 29) and [EPA–HQ–OAR–2003–0118; FRL–9930–55– OAR] RIN 2060–AG12 

Protection of Stratospheric Ozone: Determination 30 for Significant New Alternatives Policy Program 

(Notice 30)] have been deemed as acceptable for new and retrofit equipment for eleven different end-uses 

including domestic refrigeration, vending machines, stand-alone refrigeration equipment, and industrial 

process refrigeration, among many others. These new substitutes have GWPs that are comparable to 

other high-GWP substitutes removed from the list of approved SNAP alternatives in Rule 20 and their

impacts on human health and the environment is a major policy decision. Use of these substances and 

other similar substances will lead to sustained high-GWP HFC emissions within these end-uses and subsectors for decades to come given the long lifetimes of these types of equipment, and the experiences of 

previous phase-outs of ozone depleting substances. CFCs, for example were phased out in the year 2,000 

and yet it was estimated by industry representatives more a decade later that 20-30,000 chillers using 

CFCs were still in service.2Introducing new high-GWP substitutes to the market also undermines the 

market development for low-GWP alternatives, many of which are already proven and widely 

commercially available in the U.S. and/or the international market, by dis-incentivizing private sector 

investment in the low-emission technology and the related infrastructure. 

These new high-GWP HFCs have not yet been widely adopted by equipment manufacturers and 

thus should have their status changed and be removed from the SNAP list of acceptable alternatives 

effective immediately, except as noted herein, before a market is created for their widespread use. At 

minimum, these substitutes should not be allowed for use in new equipment, and allowed in used 

equipment only where they will contribute to substantial emission reductions from existing equipment 

through retrofits. The use of these chemicals in retrofits should be limited to use in equipment 

manufactured before January 1, 2019 to ensure that these chemicals remain the transitional alternatives 

that they are intended to be.

 

2

http://www.rses.org/assets/rses_journal/0610_Capitol.pdf
4

The changes in listing status and effective dates suggested in this Petition will help maintain the 

role of the United States as a global leader in the transition away from high-GWP refrigerants, by putting 

the U.S. refrigeration sector on a path similar to that of the European Union, China, Australia, and other 

countries implementing national policies to move as quickly as feasible to the lowest-GWP alternatives. 

The EU F-Gas Regulation already prohibits the sale of domestic refrigerators and freezers containing 

HFCs with GWPs greater than 150, and will prohibit sale of all stationary refrigeration equipment (except 

those designed to cool products below -50°C) containing HFCs with a GWP greater than 2,500 as of 

January 1, 2020.

3

It also prohibits hermetically sealed commercial refrigeration equipment, the equivalent 

to the SNAP end-use for stand-alone equipment, containing HFCs with a GWP greater than 150 as of 

January 1, 2022.4 Australia recently announced a commitment to reduce HFC emissions by 80% in 2036.5

In order to maintain its leadership role, it is imperative that the U.S. follow a similar path and avoid a 

sustained transition to using new HFC blends with high GWPs. 

In summary, and as outlined in more detail within table contained in the Appendix and following 

section of the Petition for each sector and end-use, EIA petitions EPA to make the following changes in 

listing status of the following high-GWP HFCs in the listed end-uses:

 Remove SF6, HFC-23 and R-508A and R-508B (blends containing HFC-23) from the list of 

acceptable substitutes in all fire suppression and explosion protection applications, all new and 

retrofit industrial process refrigeration and very low temperature refrigeration applications, 

effective January 1, 2017. 

 Remove HFC-236fa, HFC-125, HFC-227ea and all remaining PFCs from the list of acceptable 

substitutes in fire protection and explosion protection for both total flooding and streaming 

applications effective January 1, 2019. Consider narrowed use restrictions for HFC-134a in 

these applications, with potential exemption of HFC-227ea for specified applications where 

HFC-134a or low-GWP alternatives are not feasible for technical or safety reasons. 

 Remove R-450A, R-513A, R-448A, and R-449A from the list of acceptable substitutes for 

new equipment in all applications effective immediately. Allow these substitutes in retrofit 

equipment only for equipment manufactured before January 1, 2019. 

 Remove R-507A, R-404A, HFC-236fa, and HFC-227ea from the list of acceptable substitutes 

for all new and retrofit stationary refrigeration and industrial air conditioning applications 

effective January 1, 2019. Stationary refrigeration applications include: industrial process 

refrigeration, cold storage warehouses, very low temperature refrigeration, refrigerated 

transport, industrial process air conditioning, reciprocating/screw/scroll/centrifugal chillers, 

household refrigerators and freezers, commercial ice machines, and water coolers. 

 Remove R-407A, R-410A, and R-410B from the list of acceptable substitutes for cold storage 

warehouses effective January 1, 2019. Remove HFC-134s, R-407F, R-407C, R-420A and all 

 

3

See Annex III, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0517&from=EN

4

Ibid. 

5

https://www.environment.gov.au/system/files/resources/d8c15c43-2966-43fe-aff2-bfff3f23f600/files/factsheet-actionsaustralia-taking.pdf
5

other alternatives with a GWP >1,000 from the approved list of substitutes for cold storage 

warehouses effective January 1, 2022. 

 Remove R-407A, R-410A, R-410, and R-134a from the list of acceptable substitutes for all 

new and retrofit equipment in industrial process refrigeration, effective January 1, 2022. 

 Remove R-422, R-422B, and R-422C from the list of acceptable substitutes for all new and 

retrofit equipment for very low temperature applications, effective January 1, 2019. 

 Remove HFC-134a from the list of acceptable substitutes for all new and retrofit equipment 

for refrigerated transport, effective January 1, 2022. Remove R-407C/F, R-410A/B, and HFC134a from the list of acceptable substitutes for all new and retrofit equipment for industrial 

process air conditioning effective as of January 1, 2022. 

 Remove KDD6, R-134a,R-245fa, R-410B, R-421A, R-422D, R-424A, R-434A, R-422B, R422C, R-427A, R-423A, R-420A, SP34E, R-414B (Hot Shot), Hot Shot 2, FOR12A, and

FOR12B from the list of acceptable substitutes in new and retrofit reciprocating, screw and 

centrifugal chillers in new and retrofit equipment effective as of January 1, 2019. 

 Remove R-410A from the list of acceptable substitutes in new and retrofit reciprocating, screw 

and centrifugal chillers in new and retrofit equipment effective as of January 1, 2022. 

 Remove R-428A, R-421B, R-434A, R-401B, R-402A, R-402B , R-409A, R-409B, R-406A, 

R-407C, R-407F, R-420A, R-422B, R-422C, R-422D, R-427A, R-426A, R-424A, R-426A 

(RS-24), KDD5/R-438A and KDD6 from the list of acceptable substitutes in all new 

household refrigerators and freezers effective January 1, 2017. 

 Remove HFC-134a from the list of acceptable substitutes in all new household refrigerators 

and freezers effective January 1, 2019,

 Reference international standards IEC 60335-2-24 and ISO 7371 with respect to acceptable 

use conditions for hydrocarbons in household refrigerators and freezers and other applicable 

household and commercial applications where hydrocarbons are listed as acceptable in future.

IEC working groups have been formed under IEC TC61C and TC61D with mandates to 

develop additional requirements for A2 and A3 refrigerants including re-evaluation charge size 

limits, new technologies and safety mechanisms and additional mitigation measures. 

 Remove FOR12A, FOR12B, HFC–134a, KDD6, R– 125/290/134a/600a (55.0/1.0/42.5/1.5), 

R– 404A, R–407C, R–410A, R–410B, R–417A, R–421A, R–422B, R–422C, R–422D, R–

426A, R–437A, R–438A, R–507A, RS-24 (2002 formulation), SP34E from the list of 

acceptable substitutes in retrofit equipment for vending machine applications, effective 

January 1, 2022. 

 Remove HFC-134a, R-406A, R-407A/B/C, R-411A/B from the list of acceptable substitutes in 

new and retrofit commercial ice machines with an effective date of January 1, 2022.

 Remove R-407A, R-407C, R-407F, R-427A, R-421A, R-410A, R-410B from the list of 

acceptable substitutes in new and retrofit supermarket systems and remote condensing units 

effective as of January 1, 2022. 

 Remove R-134a, R-421A/B, R-424A, R-426A, R-438A, R-422A/B/C/D, R-407A/B, R-407F 

from the list of acceptable equipment in new and retrofit water coolers effective as of January 

1, 2022. 
6

II. Analysis of Sectors and End-Uses for Additional Changes in Listing Status

The following sections provide detailed analysis for each end-use and information regarding the 

availability of low-GWP alternatives to support the suggested changes in listing status and accompanying 

timelines contained in this Petition. 

Fire Suppression and Explosion Protection

The fire suppression and explosion protection sector is divided into two end-uses: total flooding 

agents and streaming applications. Total flooding agents are classified as when a specific concentration of 

extinguishing agent is discharged into an enclosed area by an automated system. Streaming applications 

consist of extinguishing agents when used as directed in a portable fire extinguisher. 

In this sector, in addition to HFCs, the petition also focuses on the need to remove 

perfluorochemicals (PFCs) from the list of acceptable alternatives. PFCs are a group of chemicals which 

do not break down in the environment and have been found to affect growth, development, reproduction, 

and liver function in laboratory animals.6 While the effects of PFCs on human health is still uncertain, 

restricting their use due to their direct impacts on human health is also advisable under the precautionary 

principle, by which EPA is charged to act. PFCs used in fire extinguishing have GWPs above 8,000, and 

therefore, their impact on climate, and related effects on the environment and human health provide an 

immediate justification for completely eliminating them as SNAP approved alternatives. As reasoned 

below, there are sufficient alternatives to high-GWP HFCs and PFCs in both total flooding and streaming 

fire suppression and explosion protection applications to remove these substances from the SNAP list of 

alternatives. Removal of PFCs from the SNAP list of approved alternatives is consistent with the EPA’s

Significant New Use Rule (SNUR) under the Toxic Substances Control Act and its 2009 Long-Chain 

Perfluorinated Chemicals Action Plan to work toward eliminating products containing PFCs by 2015.7

Total Flooding 

In total flooding applications, EPA should list SF6 with a GWP of 22,800, HFC-23 with a GWP of 

14,800, and HFC-23 blends R-508A and R-508B with GWPs above 13,000, as unacceptable as of 

January 1, 2017 or one year following the final passage of a rule. Fire protection equipment containing 

HFC-23 has been prohibited from placement on the market under the European Union’s F-Gas Regulation 

beginning January 1, 2016 which demonstrates sufficient alternatives are available for its elimination as 

an alternative. 

8 Additionally, EPA should list HFC-236fa, PFC-218 and PFC-410 with GWPs between

8,800 and 9,8109as unacceptable by January 1, 2019. Finally, EPA should list all other substitutes with 

100-year GWPs above 3,000 as unacceptable, or unacceptable subject to narrowed use restrictions, as 

 

6

http://www.cdc.gov/biomonitoring/PFCs_FactSheet.html

7

http://www.epa.gov/oppt/existingchemicals/pubs/actionplans/pfcs.html See also 

http://www.epa.gov/oppt/existingchemicals/pubs/pfcs_action_plan1230_09.pdf

8

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0517&from=EN See Annex III.

9

AR4 values, http://www.ghgprotocol.org/files/ghgp/tools/Global-Warming-Potential-Values.pdf
7

follows: HFC-125, HFC-227ea by 2022. Finally, EPA should restrict the acceptable use of R-134a with a 

GWP of 1,430 in fire suppression and explosion protection applications by 2022 to only those 

applications where the EPA establishes that low-GWP substitutes are not yet sufficiently available. 

SF6, HFC-23, R-508A and R-508B (HFC-23 blends), HFC-125 and HFC-227ea are all currently 

listed as acceptable substitutes for Halon 1301 in total flooding systems. PFC-218 and PFC-410 are listed 

as acceptable substitutes for Halon 1301 subject to narrowed use limits in non-residential uses where 

other alternatives are not technically feasible. HFC-236fa is currently listed as acceptable subject to 

narrowed use limits where other non-PFC agents are not technically feasible due to safety or performance. 

The EPA should remove these six substitutes from all subsectors where HFC-134a or low-GWP 

substitutes including carbon dioxide, water, and Foam A are available as alternatives. In cases where EPA 

determines that sufficient proven lower-GWP alternatives do not exist at present, HFC-125 and HFC227ea, may remain listed acceptable subject to narrowed use limits and revisited in a subsequent 

rulemaking.

Streaming (portable fire extinguishers)

In streaming applications, EPA should follow a similar approach listing HFC-227ea and HFC236fa, with GWPs of 3,350 and 8,060 respectively as unacceptable as of January 1, 2019. In addition, 

EPA should also change the listing status to unacceptable for PFC-614 with a GWP of 9,300.10 These 

substitutes are currently listed as acceptable subject to use limits in non-residential uses. EIA has 

determined through investigation and interviews that high-GWP HFCs can be eliminated from all

commercial and residential end uses of portable fire extinguishers by the dates set forth in this Petition.

Low-GWP substitutes that are acceptable for this end use and widely used in portable fire extinguishers

include carbon dioxide, water, dry chemical, foam, and Firebane 1170 & 1115. Carbon dioxide fire 

extinguishers are widely available and used for Class B and C liquid and electrical fires.11 Water fire 

extinguishers using air-pressurized water are widely used for Class A fires that involve flammable solids, 

such as paper or wood.12 Dry chemical extinguishers come in a variety of types and are suitable for a 

combination of class A, B, and C fires and are filled with foam or powder and pressurized with nitrogen.13

Carbon dioxide, nitrogen and argon systems such as those sold by Kidde14 and Fike15 are proven and 

available alternatives that are sufficient for almost all applications where a ‘clean agent’ that is both nonconductive and non-corrosive to electronics is required. These alternatives have the advantage of not 

leaving a corrosive residue on electronic equipment, and thus good substitutes for HFC-227ea and HFC236fa, which are touted for their non-corrosive property in specialty uses involving sensitive electronics.

Systems using inert gases are available for a wide range of applications including data centers, computer 

control rooms, engine rooms, power generation, and commercial buildings.16 Therefore, the use of HFCs 

 

10 AR4 value, http://www.ghgprotocol.org/files/ghgp/tools/Global-Warming-Potential-Values.pdf

11 https://fireextinguisherdepot.com/fire-extinguishers-1/carbon-dioxide-fire-extinguishers-1.html

12 http://www.mfs-fire-extinguishers.co.uk/types.htm

13 http://www.fire-extinguisher101.com/

14 http://kevtafiresystems.com/wp-content/uploads/2012/01/Doc_Kidde-CO2-DIOM.pdf

15 http://www.fike.com/products/co2-fire-suppression-system/

16 http://www.fike.com/products/proinert2-inert-gas-fire-protection-system/
8

should be restricted to essential applications where the above listed alternatives are not technically 

suitable, for example, in some commercial and military aviation uses where a clean agent fire suppressant 

is needed for an occupied space. For many applications, risks from CO2 to humans occupying a space can 

be mitigated by safety mechanisms such as alarm controls that warn any occupants to evacuate before a 

system is activated. 

For Class B fires where PFC foam suppression has been employed, alternative dry chemical fire 

suppressants are widely proven, used, and available. These chemicals include sodium bicarbonate, 

potassium bicarbonate, monoammonium phosphate, and widely used in products such as Purple K, which 

are the most commonly used fire suppressant in residential and commercial applications.17 Systems such 

as those sold by Ansul18 are suitable for liquid fires involving petroleum in applications such as refineries. 

SF6, HFC-23, HFC-23 blends R-508A and R-508B, should be deemed as unacceptable under the 

SNAP program for use in both total flooding and streaming fire suppression and explosion protection 

applications as of January 1, 2017 or one year following the final passage of a rule. HFC-236fa, HFC227ea, PFC-218 and PFC-410 should be deemed as unacceptable under the SNAP program for use in both 

total flooding and streaming fire suppression and explosion protection applications by January 1, 2019.

HFC-125, HFC-227ea should be deemed as unacceptable under the SNAP program for use in both total 

flooding and streaming fire suppression and explosion protection applications by January 1, 2022. By 

2022, restrictions for the acceptable use of R-134a in key fire suppression and explosion protection end 

uses should be imposed to limit the use of HFC-134a in fire suppression end uses to only those where 

low-GWP substitutes are not yet commercialized. 

Very Low Temperature Refrigeration

Very low temperature refrigeration includes systems that maintain temperatures of -80 degrees 

Fahrenheit (-62 degrees Celsius) or lower, such as some medical freezers and freeze dryers, and some 

industrial refrigeration applications. EPA should list HFC-23 with a GWP of 14,800 and blends 

containing HFC-23, R-508A and R-508B, both with GWPs above 13,000 as unacceptable in new and 

retrofit equipment as of January 1, 2017 or one year following the passage of a final rule. Other 

substitutes with GWPs ranging from approximately 3,000 to 3,985 that should be listed as unacceptable in 

new equipment as of January 1, 2019 are as follows: R-507A, R-404A, R-422, R-422B, and R-422C. 

The above changes of listing status will leave low-GWP substitutes including R-170 (ethane), R290, R-744, and air with GWPs from 0 to 6. The remaining portion of the market will also still be able to 

use R-407C, which has a GWP below 2,000 and should be listed unacceptable at a later date once it is 

determined that the entire market can be supplied by R-744, ethane, or other low-GWP substitutes. 

 

17 http://www.bfpe.com/Dry-Chemical/

18 https://www.ansul.com/en/us/Pages/ProductDetail.aspx?ProductDetail=Twin-Agent+Units
9

Thermo Fisher Scientific recently introduced an ultra-low temperature (ULT) cascade refrigeration 

system for a medical freezer application operating with a combination of ethane (R-170) and R-290.19 The 

use of a variable speed compressor in this system is cited as achieving up to a 50% reduction in energy 

consumption. Panasonic offers a similar product – a large capacity ULT Freezer achieving temperatures 

of -86 degrees Fahrenheit using R-290/R-170 and claiming up to 40% energy efficiency gains.20

Mayekawa’s Pascal Air refrigeration system for low temperature warehouses uses air as the 

working refrigerant fluid and can achieve temperatures as low as -120°C.21 Mayekawa has installed at 

least 54 units of the Pascal Air in a number of applications, including ultra-low temperature warehouses, 

rapid food freezing systems, and in the chemical process cooling industry.22

HFC-23 and blends containing HFC-23, R-508A and R-508B should all be deemed unacceptable 

for use in very low temperature refrigeration in new and retrofit equipment as of January 1, 2017 or one 

year following the passage of a final rule. R-507A, R-404A, R-422, R-422B, and R-422C should be 

similarly be removed from the list of acceptable substitutes in very low temperature refrigeration as of 

January 1, 2019.

Cold Storage Warehouses

The EPA should list the following substitutes with GWPs ranging from around 2000 to 3,990 as 

unacceptable in new and retrofit equipment for cold storage warehouses effective January 1, 2019: R404A, R-507A, R-508A, R-508B, NARM 502, HFC-227ea, R-407A, R-410A and R-410B. Additionally, 

EPA should list R-134a, R-407C, R-407F and R-420A with GWPs ranging from 1,430 to 2,000 as 

unacceptable for new and retrofit equipment as of January 1, 2022. Finally, EPA should list R-513A and 

R-450A as unacceptable for new equipment with immediate effect and for use in retrofits for any 

equipment manufactured after January 1, 2019 where their use results in a substantial reduction in the 

GWP over the current refrigerant.

Ammonia (R-717), with a GWP of 0, is the single most commonly used refrigerant for industrial 

refrigeration, which includes both cold storage and process cooling.23 Low-GWP equipment using 

ammonia and other low-emission technology is more than sufficiently available for a range of equipment 

types used for cold storage warehouses including packaged systems, chillers, and remote condensing 

units. The other low-GWP substitutes include R-744, evaporative cooling, and desiccant cooling, all 

currently available with GWPs of zero or one.

While equipment using ammonia (R-717) is already widely available and in use, systems also 

utilizing R-744 as a secondary refrigerant with ammonia are becoming more common in order to reduce 

 

19 http://news.gnom.es/pr/embraco-presents-innovative-solution-for-the-medical-scientific-area-in-atmosphere-america2015

20 http://www.panasonic-healthcare.com/global/biomedical/ultra-low-freezers/mdf-du700vh

21 http://www.r744.com/articles/6121/pascal_air_environmentally_friendly_ultra_low_temperature_storage

22 Ibid. 

23 http://www.scribd.com/doc/122993371/Industrial-Refrigeration-Best-Practices-Guide#scribd
10

ammonia charge sizes and associated toxicity risks. For example, US Cold Storage, the third largest 

refrigerated warehouse provider in the country has installed 11 systems since 2011 using a combination of 

R-717 and R-744 in either a cascade system or in critical brine systems using R-744 as a secondary 

coolant.24 The use of R-744 to lower the charge size of R-717 systems makes these systems safer from the 

perspective of both human health and environmental risk perspectives, with the added bonus of remaining 

cost-competitive with pure ammonia systems at less than a 5% margin.25 The use of evaporative cooling 

in evaporative condensers or in closed circuit towers using water or a solution of either ethylene or 

propylene glycol is another low-GWP alternative available.

26

Ammonia, ammonia cascade systems, evaporative cooling, and desiccant cooling are all available 

for use in cold storage warehouses. There is no cold storage end use where HFCs or the new high-GWP 

blends are needed. R-404A, R-507A, R-508A, R-508B, NARM 502, HFC-227ea, R-407A, R-410A and 

R-410B should be deemed as unacceptable alternatives as of January 1, 2019. R-134a, R-407C, R-407F 

and R-420A with GWPs ranging from 1,430 to 2,000 should be deemed as unacceptable for new and 

retrofit equipment as of January 1, 2022. Finally, since R-513A and R-450A have just come onto the 

SNAP list on July 2, 2015, and there is no significant uptake of these chemicals to date, they should be 

deemed as unacceptable for use in new equipment immediately following the passage of the final rule 

requested herein and in retrofit equipment manufactured after January 1, 2019 where their use results in a 

substantial reduction in the GWP over the current refrigerant.

Industrial Process Refrigeration

The EPA should list HFC-23 with a GWP of 14,800, and HFC-23 blends R-508A and R-508B as

unacceptable in new and retrofit industrial process equipment as of January 1, 2017 or one year following 

the passage of a final rule. In addition, EPA should list the following substitutes with GWPs ranging from 

around 3,350 to 8,060 as unacceptable in new and retrofit industrial process refrigeration: HFC-236fa, R404A, R-507A, R-508A, R-508B, NARM 502, HFC-227ea. In the same rulemaking, EPA should also list 

R-407A, R-410A, and R-410B, and R-134a with GWPs between 1,430 to almost 3,000 as unacceptable as

of January 1, 2022. Finally, EPA should list R-513A and R-450A, both with GWPs around 600, as 

unacceptable in new equipment with immediate effect, in order to prevent the creation of a market for 

new equipment using these new high-GWP substitutes. These chemicals should be allowed for use as 

retrofits for existing equipment manufactured prior to January 1, 2019 in end uses where there are not 

sufficient commercialized low-GWP retrofits on the market. The EPA should impose policies in the 

proposed rule to ensure that these new high-GWP chemicals do not create emissions for decades, but 

instead ensure that these chemicals are the transitional chemicals they are intended to be, replaced by lowGWP alternatives as soon as practicable.

Proven and available low-GWP alternatives are available for a range of equipment types used for 

industrial process refrigeration uses including cooling towers, rack systems, scroll compressors and 

 

24 http://www.uscold.com/wp-content/uploads/2015/06/Publication_Accelerate-America_Mike_Lynch_sm.pdf

25 Ibid.

26 http://www.baltimoreaircoil.com/english/about-us/who-we-serve
11

condensers, and heat pumps. Manufacturers of equipment that utilize R-717 and R-744, substitutes with 

GWPs from zero to one include: Cimco27, Evapco28, Star Refrigeration29, Mayekawa30, Baltimore Aircoil 

Company31, Johnson Controls32 and some of the other companies listed separately in the following section

on chillers, which are frequently used for process refrigeration and industrial air conditioning uses. In 

order to reduce the potential for workers to be exposed to R-717, R-717/R-744 cascade systems have also 

become much more common in order to reduce the charge size of ammonia. Johnson Controls is one

example of a major manufacturer already producing R-717/R-744 cascade systems.33

HFC-23 and HFC-23 blends R-508A and R-508B should be deemed as unacceptable in new and 

retrofit industrial process equipment as of January 1, 2017 or one year following the passage of a final 

rule. R-513A and R-450A as unacceptable in new equipment with immediate effect, and should be 

allowed for use as retrofits for existing equipment manufactured prior to January 1, 2019.

Centrifugal, Reciprocating, Screw and Scroll Chillers 

The EPA should list the following high-GWP HFC and HCFC substitutes with GWPs ranging 

from approximately 1,4300 to 8,060 as unacceptable in new and retrofit industrial centrifugal, 

reciprocating, screw, and scroll chillers as of January 1, 2019: HFC-236fa, ISCEON 59, R-404A, R-507, 

R-507A, HFC-227ea, KDD6, HFC--134a, HFC-245fa R-410B, R-421A, R-422D, R-424A, R-434A, R422B, R-422C, R-427A, R-423A, R-420A, SP34E, R-414A (GHG-X4), GHG-X5, R-414B (Hot Shot), 

Hot Shot 2, HFC-245fa, FOR12A, FOR12B. Additionally, the EPA should list R-450A and R-513A, both 

with GWPs of around 600, as unacceptable in new chillers with an immediate effective date, while 

continuing to allow their use for retrofit equipment manufactured before January 1, 2019, in end-uses 

where sufficient low-GWP alternatives do not exist and where their use results in a substantial reduction 

in the GWP over the current refrigerant. Finally, the EPA should remove R-410A from the list of 

acceptable substitutes in all chiller applications, effective as of January 1, 2022.

It will be particularly important to send the long term market signal that will incentivize 

development of standards needed to allow for the broader safe use of low-GWP substitutes in these types 

of equipment. While R-717 has already achieved widespread market use, standards for the safe use of 

other low-GWP alternatives that carry flammability risks that must be mitigated are being developed 

under Underwriters Laboratories (UL) and can expect to be completed by 2018. 

The low-GWP substitutes available on the U.S. market include R-717, water, water/lithium 

bromide absorption, evaporative/desiccant cooling, HFO-1233zd, and HFO-1234ze. Manufacturers of 

 

27 http://www.cimcorefrigeration.com/pdf/ECO%20CHILL.PDF

28 http://www.evapco.com/sites/evapco.com/files/hvac_features_bulletin_701b__0.pdf

29 http://www.star-ref.co.uk/star/innovation.html

30 http://www.mayekawa.eu/en/products/special-products/high-pressure-screw-compressor-unit/gh-series

31 http://www.baltimoreaircoil.com/english/about-us/who-we-serve

32 http://www.johnsoncontrols.com/content/us/en/products/building_efficiency/products-andsystems/industrial_refrigeration/york_process_systems/industrial_cooling/screw-compressors.html

33http://www.johnsoncontrols.co.uk/content/gb/en/products/building_efficiency/refrigeration/industrial/applicationssolutions/cold_store_solutions.html
12

chillers using R-717, water and other natural low-GWP substitutes, including for uses in light and large

industrial refrigeration and air conditioning applications, include Star Refrigeration34, Power Partners35, 

Mayekawa36, GEA Refrigeration,

37 Refteco38

, and Beijer Ref39. 

The already deep market penetration of R-717 in chillers, including industrial refrigeration and air 

conditioning end uses should be considered, particularly in light of ongoing technological capacities to 

improve A2 safety through lower charge sizes, automated control systems, and R-717/R-744 brine 

systems.40 In IPCC Assessment Report 3, it was stated that R-717 systems were estimated to have a 90% 

market share in systems of 100kW cooling capacity and above in the USA.41 90% of chillers produced for 

the European market use R-717.42

The uptake of HFO-1234ze (GWP=1), another low-GWP alternative, in both air and water 

centrifugal and screw chillers has also been coming online rapidly over the past year. Trane43, Carrier44, 

Geoclima45, and Airedale46 have all introduced HFO-1234ze chiller equipment to the commercial market. 

HFO-1233zd (GWP <7) is also available as an alternative in centrifugal chillers and requires no standards 

changes to be adopted. Trane has already transitioned an entire line of centrifugal chillers for the 

European market to HFO-1233zd with capacities ranging from 20kW to 14,000kW.47

Finally, the EPA has yet to consider listing R-290 or R-744 as acceptable, or acceptable subject to 

use conditions, as low-GWP substitutes for chillers under SNAP, yet they have been widely proven by 

multiple manufacturers outside of the U.S. Market. Geoclima, for instance has introduced models using 

R-290 in their Greenmiser line of reciprocating chillers.48 Similarly Johnson Controls has a line of aircooled R-290 screw chillers with capacities ranging from 95 to 400 kW.49 Another possibility is double 

combination R-290/R-744 chillers, which Geoclima piloted successfully in 2013.50 R-290 chillers 

manufactured by FT Refrigeration used in an industrial refrigeration setting offered a 24% reduction in 

 

34 http://www.azane-inc.com/products/Azanechiller.aspx

35 http://www.ppiway.com/brands-solutions/eco-max

36 http://www.mayekawa.eu/en/media/brochure-downloads/download/23

37 http://www.gea.com/global/en/productgroups/chillers_heat-pumps/chillers/index.jsp

38 http://www.refteco.com/chillers/ammonia-chiller-cha/

39 http://www.beijerref.ro/en/produse/nh3-brine-chillers-swa/107/

40 http://www.shecco.com/files/news/guide_nh3-final.pdf

http://www.ammonia21.com/articles/6433/guide_china_nh_sub_3_sub_technology_has_significant_growth_potential_in_i

ndustrial_refrigeration

41 http://www.ipcc.ch/ipccreports/tar/wg3/index.php?idp=148

42 http://ec.europa.eu/clima/events/docs/0007/johnson_controls_ammonia_slides_en.pdf

43 http://www.coolingpost.com/world-news/trane-first-with-1233zd-chiller/

44 http://www.coolingpost.com/world-news/carrier-latest-to-install-r1234ze-chiller/

45 http://www.welcomegroup.com.hk/products_subcat.php?id=23

46 http://www.achrnews.com/articles/126828-airedale-chiller-with-low-gwp-hfo-refrigerant-to-cool-new-john-lewis-store

47 http://www.racplus.com/news/trane-launches-european-focused-chiller-range-including-a-centrifugal-version-using-hforefrigerant/8664781.article

48 http://www.geoclima.com/v-range/

49http://www.johnsoncontrols.nl/content/dam/WWW/jci/be/eu_library/refrigeration/netherlands/SABlight_SB3306_Feb_20

13Prt.pdf

50 http://www.geoclima.com/double-combination-cycle-r290-co2/
13

energy consumption compared to an aging ammonia system it replaced.51 Other companies offering 

commercially available chillers using R-290 include Mayekawa screw compressor J series52, HeronHill53, 

Hitema/StastveldBV54, and Bundgaard Koleteknik A/S.55 Mayekawa’s AdRef-Noa adsorption chiller 

using water as a refrigerant is ideal for industrial uses with an available heat recovery source.56

Industrial Process Air Conditioning 

The EPA should list the following refrigerants, with GWPs ranging from 3,900 to 3,985 as 

unacceptable in new and retrofit industrial process air conditioning systems effective January 1, 2019: R404A, R-507, R-507A. Additionally, the EPA should list the following refrigerants as unacceptable in 

new and retrofit industrial process air conditioning systems effective January 1, 2022, with GWPs ranging 

from 1,430 to 2,930: ISCEON 59, KDD6, R-410A, R-410B, R-421A, R-422D, R-424A, R-426A, R434A, R-422B, R-422C, R-427A, R-423A, R-407F, HFC-245fa, FOR12A, FOR12B, and HFC-134a. In 

addition, EPA should list R-450A and R-513A, both with GWPs of around 600, as unacceptable in new 

systems, but allow their limited use in retrofit systems where sufficient low-GWP alternatives have not 

been proven in order to allow for a smooth transition away from high-GWP alternatives in existing 

equipment manufactured prior to 2019 where their use results in a substantial reduction in the GWP over 

the current refrigerant.

As detailed in the above sections on cold storage warehouses and industrial refrigeration, ammonia 

(R-717) is a widely used solution for these types of equipment. If EPA finds that there are certain uses for 

which R-717 or R-717 cascade systems are not proven alternatives or under which toxicity risks cannot be 

reasonable mitigated with the use of safety mechanisms or placement of systems on rooftops or in closed, 

unoccupied spaces, then EPA may consider allowing R-450A and R-513A subject to restrictions for those 

narrow and specific end uses, based on size or capacity of the system or another criteria.

R-404A, R-507, R-507A should be deemed as unacceptable in new and retrofit industrial process 

air conditioning systems effective January 1, 2019. ISCEON 59, KDD6, R-410A, R-410B, R-421A, R422D, R-424A, R-426A, R-434A, R-422B, R-422C, R-427A, R-423A, R-407F, HFC-245fa, FOR12A, 

FOR12B, and HFC-134a should be deemed as unacceptable in new and retrofit industrial process air 

conditioning systems effective January 1, 2022. R-450A and R-513A should be deemed as unacceptable 

in new systems with an immediate effective date, these chemicals could be used in limited instances in

retrofit systems in order to allow for a smooth transition away from high-GWP alternatives in existing 

equipment manufactured prior to January 1, 2019 where their use results in a substantial reduction in the 

GWP over the current refrigerant.

 

51http://www.hydrocarbons21.com/articles/5287/span_style_color_rgb_255_0_0_update_span_r290_watercooled_chillers_replace_existing_dairy_refrigeration_plant

52 http://www.mayekawa.ca/brochures/pdf/J_series_propane_brochure.pdf

53 http://www.heronhill.co.uk/products/331/eko-air-cooled-chiller

54 http://www.hitema.it/marketing/realizations

55 http://www.hitechcr.com.au/wp-content/uploads/2013/07/OzChillNewsletter-June-2013-Web.pdf

56 http://www.mayekawa.com.au/wordpress/wp-content/uploads/2013/07/AdRef-Noa-Brochure-170713.pdf
14

Refrigerated Transport

The EPA should list the following substitutes with GWPs ranging from approximately 1,500 to 

3,985 as unacceptable for new and retrofit equipment as of January 1, 2019: R-507A, R-404A, R-406A,

R407A/B/C/D, R-422C/D, R-421A/B, R-424A, and R-426A. Additionally, EPA should list R-448A, R449A, R-513A, R-450A with GWPs ranging from 600 to 1,400 as unacceptable with immediate effect.

In Rule 20, EPA acknowledged that lower GWP substitutes for refrigerated transport include 

liquid CO2, direct nitrogen expansion, and Stirling cycle, with GWPs in the range of zero to one. A 

number of companies are supplying low-GWP transport refrigeration systems for the U.S. market 

including Carrier57, Johnson Controls58, Ingersoll Rand59, Naturefridge60, and Linde61, with both medium 

and low temperature applications covering marine refrigeration, refrigerated trailers for cargo trucks, and 

refrigerated cargo ships.

The California Air Resources Board (CARB) also recently released a report on the alternatives 

available for refrigerated transport.

62 In the report, CARB found in its conclusions and summary of the 

most promising technologies that cryogenic transport refrigeration systems are the most promising 

technology in the next five to ten years:

“Staff believes cryogenic TRs are promising because WTW GHG and TTW CP emission 

reductions are significant at 59 and 100 percent, respectively. Cryogenic TRs provide 

much faster initial chill-down and temperature recovery after a delivery door opening. 

Also, initial capital equipment costs for a cryogenic TR are close to the cost of a 

conventional diesel TRU and maintenance cost savings are significant enough to at least 

partially offset the significant cryogenic fueling infrastructure costs. Cryogenic TRs are 

commercially available and hundreds of them are in use in Europe.”63

R-507A, R-404A, R-406A, R407A/B/C/D, R-422C/D, R-421A/B, R-424A, and R-426A should be 

deemed as unacceptable for new and retrofit refrigerated transport equipment as of January 1, 2019. R448A, R-449A, R-513A, R-450A should be deemed as unacceptable in refrigerated transport with 

immediate effect.

 

57 Carrier Transicold NaturaLINE CO2 refrigeration systems: http://www.esmagazine.com/articles/96715-

carrier-transicold-honored-for-co2-refrigerant-trailer. 

58 Johnson Controls Marine ammonia/CO2 refrigeration

system:

http://www.johnsoncontrols.com/content/us/en/products/building_efficiency/building/marine/fishery.html.

59 Thermo King’s (Ingersoll Rand) cryotech refrigeration system: http://europe.thermoking.com/cryotech/. 

60 http://naturefridge.com/

61 Linde Frostcruise liquid nitrogen for refrigerated trailers and R744 for refrigerated cargo ships: 

http://www.linde-gas.com/en/products_and_supply/food_chilling_cooling/in-transit-refrigeration.html

62 See: http://www.arb.ca.gov/msprog/tech/techreport/tru_07292015.pdf

63 http://www.arb.ca.gov/msprog/tech/techreport/tru_07292015.pdf, Page IV-2
15

Household Refrigerators and Freezers

EPA should list the following substitute refrigerants as unacceptable in new and retrofit equipment 

as of January 1, 2017, with GWPs ranging from 1,200 to 3,990: R-404A, R-507, R-507A, R-428A, R421B, R-434A, R-401B, R-402A, R-402B , R-409A, R-409B, R-406A, R-407C, R-407F, R-420A, R422B, R-422C, R-422D, R-427A, R-426A, R-424A, R-426A (RS-24), KDD5/R-438A and KDD6. In 

addition, EPA should list R-134a as unacceptable in new and retrofit household refrigerators and freezers 

as of January 1, 2019. Finally, EPA should list R-450A and R-513A, both with GWPs around 600, as 

unacceptable in all new and retrofit household refrigerators and freezers, with immediate effect.

As most household refrigerators and freezers currently manufactured in the United States use R134a, it should be quite feasible to remove the above list of alternatives from the list of acceptable 

substitutes with GWPs of 1200 and above. Similarly, having just been introduced, R-450A and R-513A 

can be easily discontinued as they have not yet been adopted by manufacturers for use in domestic 

refrigerators. A separate date of January 1, 2019 for R-134a will give more than ample time for 

reformation of standards and for producers to transition this end use entirely to proven and available lowGWP refrigerants that are widely used throughout the rest of the world with GWPs approximately 

between 4 to 8 including R-290, R-600a, and hydrocarbon blends.

Household refrigerators and freezers using R-290 and R-600a with a 150 gram charge limit, as 

opposed to the 57 gram charge size in effect in the U.S., have been shown to be safe, efficient, and 

environmentally friendly refrigerants for domestic refrigerators and freezers around the world. As a result, 

100% of equipment sold on the European market and 75% in China are using these alternatives. The U.S. 

EPA should actively engage with Underwriters Laboratories (UL), which permits governmental 

participation to move quickly, and decisively to adopt reasonable and safe charge sizes to safely mitigate 

flammability risks for A2L and A3 refrigerants, based upon modern technologies, safety devices and 

warnings. Doing so will quickly open the U.S. market to the highly available and proven alternatives well 

within the suggested time frame for changing the listing status of R-134a on January 1, 2019. 

R-404A, R-507, R-507A, R-428A, R-421B, R-434A, R-401B, R-402A, R-402B, R-409A, R409B, R-406A, R-407C, R-407F, R-420A, R-422B, R-422C, R-422D, R-427A, R-426A, R-424A, R426A (RS-24), KDD5/R-438A and KDD6 as unacceptable in new and retrofit household refrigerator and 

freezer equipment as of January 1, 2017. R-134a should be deemed as unacceptable in new and retrofit 

household refrigerators and freezers as of January 1, 2019. R-450A and R-513A should be deemed as 

unacceptable in all new and retrofit household refrigerators and freezers, with a date immediately 

following the final rulemaking. 
16

Vending Machines

In Rule 20, the EPA listed a number of refrigerants as unacceptable in new vending machines with 

GWPs from 600 to 3,920: FOR12A, FOR12B, HFC–134a, KDD6, R–125/290/ 134a/600a 

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

422D, R– 426A, R–437A, R–438A, R–507A, RS–24 as of January 1, 2019. Furthermore, EPA has listed 

also R-404A and R-507A as unacceptable in retrofit equipment as of July 20, 2016. 

Given the proven availability and wide use of equipment using alternatives with GWPs ranging 

from 1 to 8, EPA should also list R-450A and R-513A (both also with GWPs of above 600, in the same 

range as other high-GWP refrigerants covered under Rule 20 as unacceptable in new vending machine 

equipment with immediate effect. The rationale for this short timeline is that R-450A and R-513A were 

only recently determined acceptable and therefore these substitutes are not yet in use for vending 

machines according to publically available sources. With the average lifespan of a vending machine being 

about 10-13 years64, eliminating the use of all refrigerants with GWPs above 600 will have a significant 

impact on emissions from new equipment that will be in use for more than a decade to come. These 

chemicals could be used in limited instances in retrofit systems in order to allow for a smooth transition 

away from high-GWP alternatives in existing equipment manufactured prior to January 1, 2019 where 

their use results in a substantial reduction in the GWP over the current refrigerant.

The EPA should also expand the unacceptable listing of additional refrigerants in retrofit vending 

machines with GWPs above 600 as of January 1, 2022, including FOR12A, FOR12B, HFC–134a, KDD6, 

R–407C, R–410A, R–410B, R–417A, R– 421A, R–422B, R–422C, R–422D, R– 426A, R–437A, R–

438A, and RS–24. 

The EPA acknowledged in its proposal for Rule 20 that R-744 is already in use in the U.S. in 

vending machines, and with the publication of Rule 19, R-600a, R-290 and R-441A are now also listed as 

acceptable subject to use conditions. Based on the following examples of wide use of these low-GWP 

refrigerants in vending machines in the U.S. and around the world, there should be ample availability of 

low-GWP substitutes by the delisting date of January 1, 2019. Coca-Cola has also surpassed 1 million 

HFC-free vending machines using R-744.65 Royal Vendors, a supplier of R-744 vending machines to 

Coca-Cola, has four different models available using R-744 refrigerant, including the RVCV-550-6, 660-

8,804-8, and 500-64.66 SandenVendo has supplied at least 1,200 R-744 vending machines in the U.S. to 

date.67 Pepsi has more than 1 million HFC-free vending machines around the world, which use 20 percent 

 

64 https://www.sce.com/NR/rdonlyres/A152092A-9FC5-410C-80DCF19257EC19EA/0/Refrigerated_Vending_Machine_Fact.pdf

65 http://www.coca-colacompany.com/innovation/coca-cola-installs-1-millionth-hfc-free-cooler-globally-preventing-525mmmetrics-tons-of-co2

66 EIA correspondence with Royal Vendors, 8/28/14

67 Accelerate America, Edition 7, http://publication.shecco.com/upload/file/org/55bfa2b198da31438622385WjhMs.pdf
17

less energy than Energy Star requirements, and it plans to phase out HFCs in all vending machines, 

coolers, and fountain soda dispensers by 2020.68

FOR12A, FOR12B, HFC–134a, KDD6, R–407C, R–410A, R–410B, R–417A, R– 421A, R–422B, 

R–422C, R–422D, R– 426A, R–437A, R–438A, and RS–24 should be deemed as unacceptable for use in 

retrofit vending machines. R-450A and R-513A should be deemed as unacceptable in new vending 

machine equipment with immediate effect.

Retail Food Refrigeration

Supermarket systems and remote condensing units 

In Rule 20, The EPA listed a number of refrigerants with GWPs from 2,729 to 3,985 as unacceptable in 

retrofit new supermarket systems and remote condensing units as of July 20, 2016 and in equipment as of 

January 1, 2017: HFC– 227ea, R–404A, R–407B, R–421B, R– 422A, R–422C, R–422D, R–428A, R–

434A, and R–507A.

EPA should list the following substitutes with GWPs ranging from approximately 2,000 to 2,500 

as unacceptable in new and retrofit equipment as of January 1, 2022: R-407A, R-407C, R-407F, R-427A, 

R-421A, R-410A, and R-410B. Additionally, the EPA should list R-448A, R-449A, R-513A, and R-450A

with GWPs approximately ranging from 600 to 1400 as immediately unacceptable in new equipment, 

while these chemicals could be used in limited instances in retrofit systems in order to allow for a smooth 

transition away from high-GWP alternatives in existing equipment manufactured prior to January 1, 2019

where their use results in a substantial reduction in the GWP over the current refrigerant. Finally, the EPA 

should also list HFC-227ea with a GWP of 3,350 as unacceptable in retrofits as well as new equipment 

effective January 1, 2019, as it was the only substitute allowed for retrofits in retail food refrigeration with 

a GWP above 3,000 not covered by Rule 20. 

The EPA also stated in Rule 20 that 70% of U.S. supermarket systems are direct expansion 

systems, while 30% are indirect systems, which include cascade and secondary loop systems. The 

rulemaking also stated that within the context of different types of systems that “EPA recognizes that 

there must be a range of options, and that the decision as to which option to select must remain with the 

owner and operator of the system.”

With the increasing availability and use of cascade and secondary loop systems that offer 

significant refrigerant charge reductions, there are indeed a range of low-GWP options currently available 

to supermarket end users whether retrofitting an existing system or purchasing a new one. Thousands of 

supermarkets around the world have transitioned to R-744 (GWP of 1) and hydrocarbons (GWP of <10), 

 

68 White House Fact Sheet: https://www.whitehouse.gov/the-press-office/2014/09/16/fact-sheet-obama-administrationpartners-private-sector-new-commitments- .Vending Times, PepsiCo to Phase Out HFC in Vending Machines, Coolers and 

Fountains by 2020, 9/19/2014, 

http://www.vendingtimes.com/ME2/dirmod.asp?nm=Vending+Features&type=Publishing&mod=Publications%3A%3AArticl

e&tier=4&id=09D204A3CBE14022AE4E167E7F2634B7 
18

both demonstrating substantial energy savings over traditional HFC systems even in high ambient 

climates.69 R-717, with a GWP of 0, when used as a primary refrigerant in a secondary loop system is also 

available as an alternative. R-717/R-744 cascade systems have been successfully piloted by supermarket 

chains, including Supervalu70 and Whole Foods71. Carnot and others recommend the R-717/R-744

cascade systems as being particularly appropriate for larger stores such as those found throughout the 

United States.72 The use of R-744 and R-717/R-744 cascade has even been employed by the U.S. 

government when it was recently announced that the US Defense Commissary Agency (DeCA), which 

operates 245 commissaries worldwide, would use R-717/R-744 cascade systems as their standard in warm 

climates and is considering transcritical CO2 for other uses.73 The DeCA’s announcement came after a 

successful retrofitting of a R-404A system with a R-717/R-744 cascade system at Lackland Air Force 

Base in San Antonio, TX.74 Wal-Mart has installed HFC-134a cascade systems with dramatically 

reduced charges sizes to retrofit more than 100 of its stores which adds to the variety of options available 

to transition supermarket systems to low-GWP alternatives and to control emissions of high-GWP HFCs 

in existing equipment.

R-407A, R-407C, R-407F, R-427A, R-421A, R-410A, and R-410B should be deemed as 

unacceptable as of January 1, 2022. R-448A, R-449A, R-513A, and R-450A should be deemed as 

unacceptable in new equipment with immediate effect, while these chemicals could be used in limited 

instances in retrofit systems in order to allow for a smooth transition away from high-GWP alternatives in 

existing equipment manufactured prior to January 1, 2019 where their use results in a substantial 

reduction in the GWP over the current refrigerant.HFC-227ea should be deemed as unacceptable in 

retrofits as well as new equipment effective January 1, 2019.

Stand-alone equipment (medium- and low-temperature) 

The EPA took a truly significant step forward in Rule 20 in changing the status to unacceptable for 

a number of high-GWP substitutes in both new medium- and low-temperature stand-alone equipment 

with GWPs ranging from approximately 900 to 3,985, as well as R-404A and R-507A in retrofit 

equipment. In an additional rulemaking, EPA should also list the remaining substitutes with GWPs 

ranging from 900 to 3,985 as unacceptable in retrofit equipment with an effective date of January 1, 2022, 

two years following their last use in new equipment as follows: FOR12A, FOR12B, R–134a, HFC–227ea, 

KDD6, R–125/290/134a/600a (55.0/1.0/ 42.5/1.5), R–404A, R–407A/B,/C, R–407F, R–410A/B, R–

417A, R–421A,/B, R–422A/B/C/D, R–424A, R–426A, R– 428A, R–434A, R–437A, R–438A, R–507A, 

RS-24 (2002 formulation), RS-44 (2003 formulation), SP34E, THR-03.

 

69 https://eia-international.org/wp-content/uploads/Chilling-Facts-VI.pdf

70 http://supermarketnews.com/technology/supervalu-pleased-ammonia-refrigerant

71 http://www.atmo.org/presentations/files/416_1_EILINGER_WHOLEFOODS.pdf

72 http://www.ammonia21.com/articles/6275/nh_sub_3_sub_heat_pumps_and_nh_sub_3_sub_-

co_sub_2_sub_systems_grow_in_popularity_at_iiar_show-part_1

73 http://www.coolingpost.com/features/us-defence-agency-adopts-co2-refrigeration/. 

74 http://www.coolingpost.com/features/us-defence-agency-adopts-co2-refrigeration/. 
19

The EPA should also change the listing status of the four recently listed high-GWP substitutes: R448A, R-449A, R-513A, and R-450A with GWPs ranging from approximately 600 to 1,400 to 

unacceptable effective immediately in both new and retrofit equipment for the medium- and lowtemperature application where they have been listed. There is not yet a market for equipment using R448A, R-449A, R-513A, and R-450A, therefore, their status should be changed immediately. R-448A and 

R-449A were only listed in low-temperature applications, while the R-513A and R-450A were listed for 

both medium- and low-temperature equipment. These sectors have abundant low-GWP alternatives and 

the approval of new high-GWP alternatives is directly contrary to the mandate given to the EPA in the 

CAP.

The above changes in listing status are feasible due to the wide availability of low-GWP 

substitutes in these standalone, factory sealed equipment. In section VC3(a) of the proposed rulemaking 

for Rule 20, the EPA acknowledged that for new stand-alone equipment, R-290 and R-600a could satisfy 

the vast majority of the current market:

“We understand that R-290 is already in use globally, including in the United States, and 

that R-600a is in use outside of the United State as well as in test market trials in the 

United States. We believe that these two refrigerants can satisfy the vast majority of the 

current market for use in stand-alone equipment. We note that there may be a need to 

modify the equipment design in order to meet the use conditions for R-290 and the 

proposed use conditions for R-600a and R-441A (July, 9, 2014; 79 FR 38811).”7576

In Rule 20 and Acceptability Determination 30, EPA sub-divided the stand-alone equipment end 

use between medium and low temperature equipment in response to comments that limited charge sizes 

for hydrocarbon refrigerants restrict their use as alternatives in low temperature equipment. In 

Acceptability Determination 30, EPA listed R-448A and R-449A, with GWPs between 1300 and 1400, as 

acceptable in both new and retrofit equipment for low-temperature standalone applications with the 

following reasoning.

In Rule 20, the EPA stated that:

As with ‘‘large’’ equipment, discussed below, commenters, including Hussmann and 

Hillphoenix, indicated that the charge size limits that apply to the hydrocarbon 

refrigerants could limit their use in low-temperature equipment, although for some 

equipment, it may be possible to redesign equipment to use multiple circuits. In addition, 

these commenters further noted that HFC–134a was not a workable refrigerant for low 

temperature applications, and thus some of the HFC/HFO alternatives, specifically R–

450A and R–513A, which were designed to perform similarly to HFC–134a, would 

likewise not be workable in these applications. However, other HFC/HFO alternatives, 

 

75 http://www.coolingpost.com/features/us-defence-agency-adopts-co2-refrigeration/, see also, 

http://www.epa.gov/ozone/snap/download/DeCA_Commercial_Refrigeration_Case_Study.pdf

76http://www.epa.gov/ozone/downloads/SAN_5750_SNAP_Status_Change_Rule_NPRM_signature_version-signed_7-9-

2014.pdf, p142.
20

such as R–448A and R–449A, designed to perform similarly to R–404A could be 

available for low-temperature uses.

77

The above statement about limited use of hydrocarbons in freezer applications is contradictory to 

the large range of stand-alone equipment that has been introduced to the international market in low 

temperature applications within the 150 gram charge limit. Nor do all stand-alone equipment models use 

multiple circuits to achieve low-temperatures in stand-alone equipment. For example, AHT offers 

integrated commercial display freezers with cooling down to -23°C.78 Liebherr-International offers a 

laboratory freezer using R-600a that cools down to -30°C.

79 Unilever has more than 900,000 Ben & 

Jerry’s ice cream freezers that use R-290, and are 10 percent more energy efficient than HFC models. 

4,588 of these freezers had been used within the U.S. as of the end of 2013.80 Other European companies 

including Lekkerland and Vestfrost, use R-600a for their chest freezers, as cited above. In Europe, 

McDonalds has rolled out R-290 equipment widely, including 3,811 meat freezers and 2,802 frozen dry 

dispensers, and 1,614 blended ice machines.81

R-600a and R-290 can supply the market for new stand-along medium- and low-temperature equipment in 

the 2019 and 2020 dates when substitutes with greater than 900 GWP go off the market. 

Water Coolers

The EPA should change the listing status to unacceptable in new and retrofit equipment as of 

January 1, 2019 for the following substitutes with GWPs above 3,000: R-404A, R-507, and R-507A. 

Additionally, EPA should change the listing status to unacceptable in new and retrofit equipment as of 

January 1, 2022 for the following substitutes with GWPs approximately between 1,430-3,000: R-134a, R421A/B, R-424A, R-426A, R-438A, R-422A/B/C/D, R-407A/B, and R-407F. Finally, R-513A and R450A, with GWPs of approximately 600, should be listed unacceptable in new equipment with immediate 

effect, while these chemicals could be used in limited instances in retrofit systems in order to allow for a 

smooth transition away from high-GWP alternatives in existing equipment manufactured prior to January 

1, 2019 where their use results in a substantial reduction in the GWP over the current refrigerant.. 

Recent developments encouraging market uptake of low-GWP water coolers demonstrate the 

availability of low-GWP substitutes will be achievable by the above proposed delisting dates, provided

the EPA lists R-290 and R-600a as acceptable under the SNAP program for use in water coolers. The 

availability of low-GWP water coolers is wide spread in international markets and could greatly increase 

in the U.S. market once the EPA lists R-290 and R-600a as acceptable. Already in the U.S. several 

companies are poised to provide low-GWP water coolers on a commercially available scale. Blupura, an 

 

77 http://www.gpo.gov/fdsys/pkg/FR-2015-07-20/pdf/2015-17066.pdf, p42914. 

78 http://www.hydrocarbons21.com/web/assets/companybrochure/file/652_paris_hc_cabinet.pdf

79 http://www.hydrocarbons21.com/products/view/liebherr_lab_refrigerators_and_freezers

80http://www.hydrocarbons21.com/articles/6243/atmosphere_europe_2015_end_users_ask_technology_providers_to_clos

e_gap_in_the_natural_refrigerant_market

81http://www.hydrocarbons21.com/articles/6243/atmosphere_europe_2015_end_users_ask_technology_providers_to_clos

e_gap_in_the_natural_refrigerant_market
21

Italian water cooler company that manufactures an array of water coolers using R-290 and R-600a82, 

opened a sales office in the U.S. more than a year ago and has recently obtained UL certification for its 

products.

83 The company already has installations in U.S. hotels, restaurants, tech companies, and 

universities. Blupura’s products are used throughout the European market and are increasing in South 

Africa84, the Middle East, and other parts of the world.85 Recently in February 2015, Elkay, a global 

manufacturer of water coolers based in Illinois, agreed to a partnership with Blupura to distribute Blupura 

products in the U.S. and Canadian foodservice and hospitality markets86, which will have significant 

impact on market availability of low-GWP water coolers in the U.S. and Canadian market. In addition to 

Blupura and Elkay, Oasis, an international company headquartered in Ohio, manufactures water coolers 

using R-600a87 with sales in more than 80 countries.88 Allowing that the EPA lists R-290 and R-600a as 

acceptable in water coolers under the SNAP program in the immediate future, the U.S. market for lowGWP water coolers will experience significant growth making the above recommended delisting dates 

achievable. 

Commercial Ice Machines 

The EPA should remove R-507A and R-404A from the list of acceptable equipment in new and 

retrofit commercial ice machines effective as of January 1, 2019. Additionally, EPA should remove R134a, R-421A/B, R-424A, R-426A, R-438A, R-422A/B/C/D, R-407A/B, R-407F from the list of 

acceptable equipment in new and retrofit commercial ice machines effective as of January 1, 2022. 

Finally, given there is not yet a market for equipment using the, EPA should remove the following 

substitutes from the acceptable list effective immediately: R-448A, R-449A, R-513A, and R-450A.

Given the commercial availability of R-290 and R-744 ice makers on the international market, the 

EPA should move quickly to allow these substitutes in the U.S. market. In the meantime, currently 

acceptable alternatives under SNAP for this sector include ammonia absorption, ammonia vapor 

compression, and Stirling cycle. 

R-717 (ammonia) with a GWP of zero, is a widely used alternative for commercial ice machines. 

Companies currently manufacturing low-GWP technologies available for the U.S. market include Howe 

Corporation’s ammonia ice flaking machines89, Automatic Ice Systems Turbo C-Line Ice Generators90, 

Energy Concept’s ISAAC Solar Ice Maker ammonia-water absorption cycle91, Morris & Associates tube 

ice makers92, and C&R Refrigeration.93

 

82 http://www.blupura.com/en/products-water-purification.asp.

83 http://www.hydrocarbons21.com/articles/6593/chilled_water_anyone_blupura_obtains_ul_certification_in_u_s. 

84 http://www.blupura.com/en/news.asp. 

85 http://www.watercoolerseurope.eu/interview/interview-to-luca-costantini-blupura. 

86 http://www.elkay.com/news-blupura-products. 

87 http://www.oasiscoolers.com/index.php/technology/hydro-carbons.html. 

88 http://www.oasiscoolers.com/index.php/about-us.html. 

89 http://equipment.howecorp.com/viewitems/ice-flakers/ammonia-flake-ice-machines

90 http://automaticice.com/turbo-c-line-ice-generators/

91 http://www.energy-concepts.com/_pages/app_isaac_solar_ice_maker.htm

92 http://morris-associates.com/products/ice-production/tube-cube-ice-maker/
22

Although not yet SNAP approved, many companies are manufacturing ice machines using R-290 

and R-744 for use in other countries. Manitowoc, a Wisconsin based manufacturer, has developed two 

models of under counter commercial ice machines that are cooled using R-290.94 Gram Commercial95, 

Hoshizaki96, and Scotsman97 are among other companies offering R-290 ice cube and ice flaking 

machines for the European markets. Howe Corporation has also introduced model R-744 ice flakers for 

use in subcritical or transcritical direct expansion systems.98 Brema, a European company, is moving to 

transition its entire production line of ice machines to R-744.99 While commercial ice machines were 

considered in a study commissioned by the EPA examining the potential effect of hydrocarbons on 

ground level ozone100, they were not included in the rulemaking as an acceptable sector for additional 

listings under Rule 19. The EPA should promulgate another rulemaking to grant SNAP approval of the 

numerous low-GWP substitutes for these sectors, which are in wide use in the EU and other countries.

III. Conclusion

The EPA has taken a significant step toward implementing the directive in the President’s Climate 

Action plan by implementing Rules 19 and 20, but much more can be done. The EPA should approve this 

petition to remove high-GWP HFC alternatives on a graduated basis to allow for a smooth transition to 

low-GWP alternatives. The high-GWP HFCs which are the subject of this petition were primarily 

approved by the SNAP program during the CFC and HCFC phase-outs, but are now often the most 

damaging of the alternatives listed for particular end-uses. EPA must now remove the above listed highGWP HFCs from the list of acceptable alternatives on a swift and progressive basis.

The EPA risks following a different path than the rest of the world by granting SNAP approval for 

the new high-GWP HFC blends R-448A, R-449A, R-513A, and R-450A for uses in new equipment

where there are abundant low-GWP alternatives. These chemicals should be immediately removed from 

approved alternatives for new equipment. The widespread use of these chemicals in new equipment is not 

necessary in any sector where they have been listed, will undermine the uptake of low-GWP alternatives 

and the related infrastructure, and finally will result in massive emissions of HFCs for decades to come 

given the useful life of the equipment in the sectors for which they have been approved. The EPA should 

conduct a careful review to determine whether there are sectors where these chemicals are really needed 

for retrofits. If such sectors are identified, the use of these products should be limited to equipment 

manufactured before January 1, 2019 where their use substantially reduces the GWP over the existing 

refrigerant, so that use of these chemicals does not become widespread, or a way for the use of HFCs to 

continue beyond the time when they are absolutely necessary.

 

93 http://www.crrefrig.com/c-r-tubular-ice-makers

94 http://refrigerants.danfoss.com/technicalarticles/rc/energy-efficient-hydrocarbon-ice-makers/?ref=17179885516

95 http://gram-commercial.com/gb/en-gb/ice-makers-under-the-gram-name

96 http://www.hydrocarbons21.com/web/assets/companybrochure/file/759_hoshizaki_ice_machines_issue4_gb.pdf. 

97 http://www.scotsman-ice-on-tablet.com/Food_SuperFLAKE_MF.html

98 http://equipment.howecorp.com/viewitems/ice-flakers/co-sub-2--sub--flake-ice-machines

99 http://www.bremaice.it/en/prodotti/cold-flakes/muster/m-split-1000-co2.html See also 

http://www.carel.com/documents/10191/171507/R744,02-03-15.pdf/c12ab59d-336f-4697-8309-3159ae4135ee

100 See ICF 2014a, in docket for proposed Rule 19. 
23

If you or your staff wishes to discuss this petition or have any questions, please contact me or my 

coauthors to this petition at the contact information provided below. 

Very truly yours,

The Environmental Investigation Agency

By: Mark W. Roberts, Senior Counsel

 Lisa Handy, Senior Policy Advisor

 Christina Starr, Climate Policy Analyst

 Lowell Chandler, Climate Policy Analyst 

 

 markroberts@eia-global.org

 lisahandy@eia-global.org

 cstarr@eia-global.org

 lchandler@eia-global.org

 

 
24

Appendix: Summary of EIA’s October 6, 2015 SNAP Petition for Additional Listings of High-GWP ODS Substitutes as Unacceptable

End-Uses New/Retro

fit High-GWP ODS Substitute Approx. GWP-100 Range Date Proven Alternatives GWP-100 Impediments/Use Restrictions/Notes 

Fire 

Suppression 

(Total 

Flooding)

N/A SF6, HFC-23, and HFC-23 

blends (R-508A, R-508B) 13,000-22,800

January 1, 2017 

or one year after 

final rule 

Carbon dioxide, 

nitrogen, argon

0-1

Water, Water mist 

systems 

0

N/A HFC-236fa, HFC-125, HFC227ea, PFC-218, PFC-410

3,000-8,860

January 1, 2019

Powdered Aerosol A 0

Consider narrowed 

use restrictions for 

HFC-134a.

HFC-134a 1430

Fire 

Suppression 

(Streaming 

Agents/Portabl

e 

Extinguishers)

N/A HFC-227ea, HFC-236fa, 

PFC-614 3,350-9,160 January 1, 2019

Carbon dioxide, 

nitrogen, argon 0-1

Dry chemical 

agents are widely 

used for Class B 

fire suppression in 

applications 

including 

petroleum 

refineries and 

aircraft 

Carbon dioxide and 

the other inert 

gases are available 

and sufficient for 

most applications 

requiring a ‘clean 

agent’.

Water 0

Dry chemical (Sodium 

bicarbonate, potassium 

bicarbonate and 

monoammonium 

phosphate)

0

Cold Storage 

Warehouses 

New and 

retrofit 

R-507A, R-404A, HFC227ea, R-407A, R-410A, R410B 2000-3,985 January 1, 2019 R-717 0

New and R-134a,R-407F, R-407C, R- 1,430-2,000 January 1, 2022 R-744 1
25

Industrial 

Process 

Refrigeration

New and 

retrofit

HFC-23, and HFC-23 

blends (R-508A, R-508B) 13,000-14,800

January 1, 2017 or 

one year after 

final rule 

R-290

R-600a

R-1270

<5

New and 

retrofit

HFC-236fa, R-507A, R404A, HFC-227ea 3,350-8,060 January 1, 2019 R-744 1

New and 

retrofit

R-407A, R-410A, R-410, R134a 1,430-3,000 January 1, 2022

R-717 0

Stirling Cycle 0

New R-513A , R-405A 604-700 Immediate Evaporative /Desiccant 

Cooling 0

Very Low 

Temperature 

Refrigeration 

New and 

retrofit

HFC-23, and HFC-23 

blends (R-508A, R-508B) 13,000-14,800

January 1, 2017 or 

one year after 

final rule 

R-170 Ethane

R-1150 Ethene 

<6

New and 

retrofit

R-507A, R-404A, R-422, R422B, R-422C 3,000-3,985 January 1, 2019

R-744, liquid CO2, liquid 

argon, R-728 (liquid 

nitrogen)

0-1

Refrigerated 

Transport

New and 

retrofit

R-507A, R-404A, R-406A, , 

R407A/B/C/D, R-422C/D, 

R-421A/B, R-424A, R426A

1,500-3,985 January 1, 2019

Cryogenic liquids: R744, liquid CO2, liquid 

argon, R-728 (liquid 

nitrogen and direct 

nitrogen expansion)

0-1

January 1, 2022 

effective date 

provides the time 

required to 

develop 

infrastructure for 

cryogenic TR 

refueling. 

New R-448A ,R-449A, R-513A, 

R-450A 604-1,400 Immediate

R-717*101 0

New and 

Retrofit HFC-134a 1,430 January 1, 2022

Industrial New and R-507A, R-404A 3,900-3,985 January 1, 2019 R-717 vapor 0

 

101 e.g. ammonia or ammonia/CO2 cascade systems for marine refrigeration 

retrofit 420A

New R-513A, R-450A 604-700 Immediate Evaporative/ Desiccant 

Cooling 0
26

Process Air 

Conditioning

retrofit compression and 

absorption 

New and 

retrofit

R-407C/F, R-410A/B, HFC-

134a 1,430

-2,230 January 1, 2022

R-744* including in 

ammonia/CO

2 cascade 

1

New R-513A, R-450A 604-700 Immediate Evaporative Cooling 0

Reciprocating,

Screw, Scroll

and 

Centrifugal 

Chillers 

New and 

retrofit 

HFC-236fa, R-417A 

(ISCEON 59), R-404A, R-

507, R-507A, HFC-134a, 

HFC-245fa, HFC-227ea, 

KDD6, R-410B, R-421A, R-

422D, R-424A, R-434A, R-

422B, R-422C, R-427A, R-

423A, R-420A, SP34E, R-

414B (Hot Shot), Hot Shot 

2, FOR12A, FOR12B.

1,430-8,060 January 1, 2019

R-717 Vapor 

compression & 

absorption

0

2019 timeline 

allows time to 

transition 

centrifugal chillers 

to HFO1233zd 

and time for 

revision of

standards for 

GWP<20 

alternatives in 

other chillers

including A2, A2L, 

and A3 

refrigerants. R-410A is only 

widely used in 

scroll chillers and 

if not listed 

unacceptable 

across the board, could be 

restricted only to 

use in scroll 

chillers after 

2019.

Water/Lithium Bromide0

Stirling cycle0

New and 

retrofit 

R-410A January 1, 2022

R-290/R-600a/R-441A* <4

HFO-1234ze (medium 

pressure)

HFO-1233zd (low 

pressure)

1-7

Evaporative Cooling0

New R-513A, R-450A 604-700 Immediate

Household 

refrigerators 

and freezers

 

New 

R-507, R-507A, R-404A, R-

428A, R-421B, R-434A, R-

401B, R-402A, R-402B , R-

409A, R-409B, R-406A, R-

407C, R-407F, R-420A, R-

422B, R-422C, R-422D, R-

427A, R-426A, R-424A, R-

1,200-3,985 January 1, 2017

R-600a

R-290 <4

January 1, 2019

timeline for R-

134a allows 

sufficient time to 

develop revised 

standards for 

GWP<20 
27

426A (RS-24), KDD5/R438A and KDD6alternatives to 

allow safe and 

cost effective 

equipment using 

A2, A2L, and A3 

refrigerants to 

enter the U.S. 

market.

New R-513A, R-450A 604-700 Immediate

New R-134a 1,430 January 1, 2019

Vending 

machines 

New R-450A, R-513A 604-700 Immediate R-744 1

Retrofit 

FOR12A, FOR12B, HFC–

134a, KDD6, R–

125/290/134a/600a 

(55.0/1.0/42.5/1.5), R–

404A, R–407C, R–410A, 

R–410B, R–417A, R–421A, 

R–422B, R–422C, R–422D, 

R– 426A, R–437A, R–

438A, R–507A, RS-24 

(2002 formulation), 

SP34E.

1,100-3,985

R-507A and R404A as of 

January 1, 2019 

and the rest 

January 1, 2022

R-290

R-600a

R-441A

<4

These have 

already been 

listed 

unacceptable in 

new equipment 

under Rule 20. 

Commercial 

ice machines 

New R-448A, R-449A, R-513A, 

R-450A 604-1,400 Immediate R-717 0

New and 

retrofit R-507A, R-404A 3,000-3,985 January 1, 2019 R-290*R-600a* <4

New and 

retrofit 

HFC-134a, R-406A, R407A/B/C, R-411A/B 1,430-3,000 January 1, 2022 R-744* 1

Supermarket 

Systems and 

remote 

condensing 

units 

New R-448A, R-449A, R-513A, 

R-450A 604-1,400 Immediate R-744 1

New and 

retrofit 

R-407A, R-407C, R-407F, 

R-427A, R-421A, R-410A, 

R-410B

2,000-2,500 January 1, 2022

R-717 with secondary 

loop 0

Retrofit HFC-227-ea 3,350 January 1, 2019 R-290, R-600a and R- <4
28

441A in condensing 

units* 

Mediumtemperature 

Stand-alone 

equipment 

New and 

retrofit R-513A, R-450A 604-700 Immediate

R-290

R-600a

R-441A

<4

Lowtemperature 

stand-alone 

equipment 

New and 

retrofit

R-448A, R-449A, R-513A, 

R-450A 604-1,400 Immediate

R-290

R-600a

R-441A

<4

Medium- and 

Lowtemperature 

stand-alone 

equipment

Retrofit 

FOR12A, FOR12B, R–

134a, HFC–227ea, KDD6, 

R–125/290/134a/600a 

(55.0/1.0/ 42.5/1.5), R–

404A, R–407A/B,/C, R–

407F, R–410A/B, R–417A, 

R–421A,/B, R–

422A/B/C/D, R–424A, R–

426A, R– 428A, R–434A, 

R–437A, R–438A, R–

507A, RS-24 (2002 

formulation), RS-44 (2003 

formulation), SP34E, THR03.

900 to 3,985 January 1, 2022

R-290

R-600a

R-441A <4

These have 

already been 

listed 

unacceptable in 

new equipment 

under Rule 20. 

Water coolers 

New R-513A, R-450A 604-700 Immediate

R-290*

R-600a* <4

HCs not SNAP 

listed, but UL has 

certified for sale 

in U.S. 

New and 

retrofit R-404A, R-507, R-507A 3,000-3,985 January 1, 2019 

New and 

retrofit 

R-134a, R-421A/B, R424A, R-426A, R-438A, R422A/B/C/D, R-407A/B, 

R-407F

1,430-3,000 January 1, 2022