International. The IIAR Education Committee announced that it has created a fact sheet on the phase-out contemplated in the AIM Act, to illustrate the extent of refrigerants currently used, based on their global warming potential.
The IIAR AIM Act fact sheet can be downloaded in PDF format from the IIAR AIM Act website: What is the AIM Act?
The one-page fact sheet lists 33 refrigerants per GWP relative to EPA limits in four categories: all-natural refrigerants; HFO refrigerants; HFC/HFO blends; and HFC refrigerants.
The AIM Act was enacted in 2020, and while it is the primary vehicle for phasing out the production and consumption of listed HFCs, as well as the vehicle for managing these HFCs and their substitutes, there may be other regulations on the horizon that could further restrict the use of these refrigerants.
An increasing number of states and federal regulatory agencies are examining the effects of perfluoroalkyl substances, known as PFAS, and regulatory frameworks are evolving along with the phase-out of HFCs, due to concerns about their persistence in the environment and potential health impacts.
PFAS have been incorporated into some refrigerants to improve their stability and performance, and the refrigeration industry is still waiting for clarity on which refrigerants will be designated as PFAS in the U.S.
According to the North American Sustainable Refrigeration Council, regulations already exist at the state level, and more than 30 states have introduced or adopted PFAS-related regulations. Until recently, refrigerants didn't feature prominently in those discussions, but that's starting to change, and PFAS regulations add to the mix of potential future restrictions on HFCs.
Meanwhile, industry experts believe that PFAS ratings could have a direct impact on refrigerants, including synthetic alternatives that are coming to market.
The U.S. Environmental Protection Agency has implemented several requirements limiting PFAS, including a recordkeeping and reporting standard under the Toxic Substances Control Act (TSCA).
Under the EPA's requirement, all entities, including small entities, that have manufactured, even imported, PFAS in any year since 2011 will be required to report PFAS data to EPA beginning in November 2024. Small manufacturers will have to start reporting in November 2025. Under this law, there are civil penalties and criminal proceedings that can be imposed against those who fail to report.
