The latest refrigerant transition is well underway, with the 10% cut in the production of HFC refrigerants that went into effect last year. A much steeper cut happens next year, when production of HFCs must be reduced to 60% of the baseline established by the Environmental Protection Agency (EPA). There is no question that this stepdown will be a challenge for the HVACR industry.

As most know, these production cuts are a result of the AIM Act, which became law in December 2020. Under this legislation, Congress gave the EPA the authority to phase down the consumption and production of high-GWP HFC refrigerants in the U.S. by 85% over the next 15 years. Unlike the last refrigerant transition, in which HCFCs such as R-22 were phased out due to their ODP, this transition is due to the fact that HFCs such as R-410A and R-404A are considered to be contributing to global warming.

In addition to ODP and GWP, however, there are growing concerns about some of the chemicals used in certain synthetic refrigerants. For example, PFAS (Per- and polyfluoroalkyl substances) are a group of man-made chemicals that have been used in many consumer products, including nonstick cookware, clothing, and furniture since the 1940s. They are highly resistant to heat, water, and oil, making them useful for a variety of applications, including refrigerants used in air conditioning and refrigeration equipment. However, their ubiquitous presence in water, soil, and air samples has raised concerns about their potential impacts on human health and the environment.

One of the main concerns with PFAS is that once they are released into the environment, they do not break down easily and can remain there for long periods of time. They can also accumulate in the human body over time and have been found in blood samples from people tested all over the U.S. Another concern is that some types of PFAS may be linked to a range of health effects, including increased cholesterol levels, decreased birth weights, and liver damage.

Due to the concern over the potential health risk, EPA and several states are looking at restricting the use of PFAS in certain products. Maine, for example, passed a law in 2021, stating that as of January 1, 2030, “any product containing intentionally added PFAS may not be sold in Maine unless the use of PFAS in the product is specifically designated as a currently unavoidable use by the Department [of Environmental Protection].”

For now, Maine is not considering the prohibition of refrigerants containing PFAS; however, “closer to 2030 the Department may undertake an investigation to determine if refrigerants are, at that time, a currently unavoidable use.” Even though the ban on certain substances listed in Maine’s legislation does not go into effect until 2030, the first phase of the legislation went into effect January 1, 2023, and requires manufacturers to label certain goods and components that fall under Maine’s definition of PFAS.

EPA has not yet proposed any regulations concerning the use of PFAS in refrigerants; however, the Agency has published its “PFAS Strategic Roadmap,” which outlines the schedule it will undertake in conducting specific measures regarding these chemicals. According to the Roadmap, which runs through 2024, EPA plans to invest in research to increase understanding of PFAS exposure; proactively prevent PFAS from entering air, land, and water at levels that can adversely impact human health and the environment; and broaden and accelerate the cleanup of PFAS contamination to protect human health and ecological systems. Regulations and enforcement actions will likely follow.

In other parts of the world, PFAS are under fire as well. Five European countries, for example, have proposed restricting around 10,000 different kinds of PFAS across the European Union (EU). This would affect single component refrigerants such as R-125, R-134a, and R-1234yf, which are used in many lower-GWP HFC/HFO blends. If approved later this year, the proposal would become effective in 2025, with a transition period of 18 months for switching to alternative options — a timeline that many EU OEMs say is impossible to meet. (The proposal does include an exemption of “refrigerants in HVACR equipment in buildings where national safety standards and building codes prohibit the use of alternatives.”)

The story of what will happen in the U.S. to refrigerants containing PFAS is still unfolding, so it remains to be seen how or if this will impact the HVACR industry. However, it is evident that PFAS will remain a significant concern for federal and state governments, which means that further regulations or restrictions related to refrigerants could be introduced in the not-so-distant future.