HFC Policies & Refrigerant Regulations By State
In the U.S., the federal government and several states have enacted legislation to regulate Hydrofluorocarbon refrigerant (HFC) use and production. This interactive map tracks the regulatory status of each state. More information on each state is available below.
How to Use This Map
All of the colored states are part of the US Climate Alliance. Click on a state to learn more about its regulatory status. See the summaries by state below for more details.
+ US Climate Alliance Member
The state is a member of the US Climate Alliance, a coalition of states committed to upholding the Paris Climate Agreement’s goal of keeping temperature increases below 1.5 degrees Celsius. However, the state has not committed to regulating HFC refrigerants.
+ SNAP 20/21 Pending
The state has expressed intentions to introduce legislation to reduce HFC emissions, but no bills have been signed into law.
+ SNAP 20/21 Signed Into Law
The state has enacted legislation that prohibits certain HFCs in specific stationary refrigeration and air-conditioning end-uses in alignment with the federal EPA SNAP Rules 20 and 21.
+ SNAP Plus Additional GWP Limits
In addition to enacting legislation prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses, the state has enacted stricter regulations aimed at curbing HFC emissions beyond EPA SNAP Rules 20 and 21.
The HFC Problem
Hydrofluorocarbon refrigerants (HFCs) are greenhouse gases commonly used in refrigeration. Pound for pound, these super-pollutants trap thousands of times more heat in the atmosphere than carbon dioxide.
Once considered a suitable replacement for ozone-depleting substances, HFCs are now the world’s fastest-growing greenhouse gases. Scientists estimate that HFCs alone could contribute to up to 0.5°C of global warming by the end of the century.
What is SNAP?
Established under the Clean Air Act, the Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) program identifies and evaluates substitutes for ozone-depleting substances by end-use. SNAP Rules 20 and 21 list specific HFC refrigerants as unacceptable and identify acceptable alternatives.
The SNAP rules were vacated at the federal level in 2017 after a lawsuit claimed that the EPA had exceeded its statutory authority (Mexichem Fluor, Inc., v. EPA). In response, member states of the US Climate Alliance began adopting SNAP Rules 20 and 21 at the state level.
In 2020, the SNAP rules were partially reinstated and currently prohibit certain substitutes when switching from ozone-depleting substances.
Federal Regulations
+ American Innovation and Manufacturing (AIM) Act
Enacted in late 2020, the American Innovation and Manufacturing (AIM) Act directs the EPA to address HFC emissions through three main legislative activities:
- Phase down the production and consumption of HFCs in the United States by 85% by 2036, mirroring the Kigali Amendment. Learn more about the phasedown schedule, allowance allocations, and final allocations rule here. Final Rule for Allowance Allocation Methodology for 2024 and Later Years published July 20, 2023
Facilitate the transition to next-generation technologies, implement restrictions on specific HFC uses, and approve substitutes for regulated HFCs. In October, 2023, the EPA released the final Technology Transition rule under the AIM Act. Under the final rule, the food retail sector will be subject to the following GWP limits:
- 150 GWP for new systems with 200 lbs. or more (Jan 1, 2027)
- 300 GWP for new systems less than 200 lbs. (Jan 1, 2027)
- 300 GWP for the high temperature side of new cascade systems (Jan 1, 2027)
Read more here.
- Establish regulatory requirements for the management of refrigerants, including refrigerant reclamation and equipment servicing, repair, disposal, or installation. In October, 2023, the EPA released the proposed 'Management of HFCs and Substitutes' rule. The proposal includes requirements related to leak repair, automatic leak detection, reclaimed HFCs, recovery of HFCs from disposable cylinders, container tracking, recordkeeping, reporting, and labeling. Most notably, this rule would require the use of reclaimed HFCs starting in 2028. Read more here.
+ Clean Air Act: Section 608
Section 608 of the Clean Air Act was established to prohibit intentional venting of ozone depleting refrigerants (CFCs and HCFCs) and their substitutes (HFCs) while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment. Section 608 includes requirements related to:
- Technician Certification
- Refrigerant Recovery & Equipment Recycling
- Refrigerant Leaks
- Refrigerant Sales Restriction
- Recordkeeping
- Safe Disposal
- Reclamation
- Service Practices
Read more about Section 608 requirements here. For more guidance on Section 608 compliance, we encourage you to contact a compliance expert.
+ Significant New Alternatives Policy (SNAP) program
See summary above.
Summary by State
+ California
In alignment with the federal EPA SNAP Rules 20 and 23, California enacted SB 1013, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2019
The state also approved new regulations requiring specific Global Warming Potential (GWP) thresholds for new and existing food retail facilities.
- New Facilities: California food retailers may not use refrigerants above 150 GWP in new facilities with systems containing more than 50 pounds of refrigerant starting January 1, 2022. New facility requirements apply to any of the following conditions:
- New construction
- An existing facility not previously used for cold storage, retail food refrigeration, commercial refrigeration, industrial process refrigeration or ice rinks
- An existing facility used for cold storage, retail food refrigeration, commercial refrigeration or industrial process refrigeration that has undergone replacement of 75% or more of its evaporators (by number) and 100% of its compressor racks and condensers
- Existing Facilities: California food retailers must meet one of the following GWP reduction targets across their existing facilities by 2030:
- Attain a companywide weighted average GWP1 of less than 1,400
- Attain a 55% or more significant reduction in Greenhouse Gas Potential (GHGp)2 below 2019 levels by 2030
Companies operating more than 20 facilities in California must also attain either a companywide weighted average GWP of less than 2,500 or a 25% or greater reduction in GHGp below 2019 levels by December 31, 2026.
Supermarket Effective Date: January 1, 2022
1. "Weighted-average GWP” is equal to ∑ (charge x GWP)/ ∑ charge
2. “Greenhouse Gas Potential” or “GHGp” is equal to Σ (Charge × GWP)
In August 2022, the state also passed SB 1206, which:
- Prohibits the sale, distribution, or otherwise entering into commerce in the state, bulk HFCs or HFC blends that exceed the following GWP thresholds:
- 2,200 beginning January 1, 2025
- 1,500 beginning January 1, 2030
- 750 beginning January 1, 2035
- Prohibits HFCs >750 GWP that are not reclaimed from being used to replenish leaks or otherwise service stationary equipment owned or operated by the state, beginning January 1, 2025.
- Directs CARB to do the following:
- Initiate a rulemaking requiring low and ultra-low global warming potential alternatives to HFC in a sector unless it is not practicable.
- Publish an assessment by January 1, 2025, which will specify how to transition the state’s economy away from HFCs and to ultra-low or no GWP alternatives no later than 2035.
+ Colorado
In alignment with the federal EPA SNAP Rules 20 and 23, Colorado enacted Regulation 22, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
+ Connecticut
Connecticut has expressed intentions to introduce legislation to reduce HFC emissions but no legislative activities have taken place.
Status: Committed
+ Delaware
In alignment with the federal EPA SNAP Rules 20 and 23, Delaware enacted 7 DE Admin Code 1151, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: September 1, 2021
+ Hawaii
In alignment with the federal EPA SNAP Rules 20 and 23, Hawaii introduced HB 2492, which would prohibit certain HFCs in specific stationary refrigeration and air-conditioning end-uses. No further legislative activities have taken place.
Status: Bill Introduced
+ Illinois
Illinois is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ Louisiana
Louisiana is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ Maine
In alignment with the federal EPA SNAP Rules 20 and 23, Maine enacted HP 161, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2022
+ Maryland
In alignment with the federal EPA SNAP Rules 20 and 23, Maryland enacted COMAR 26.11.33, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
+ Massachusetts
In alignment with the federal EPA SNAP Rules 20 and 23, Massachusetts enacted 310 CMR 7.76, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
+ Michigan
Michigan is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ Minnesota
Minnesota is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ Nevada
Nevada is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ New Jersey
In alignment with the federal EPA SNAP Rules 20 and 23, New Jersey enacted A-5583, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: July 1, 2020
In June 2022, New Jersey also enacted the Greenhouse Gas Monitoring and Reporting Rule, which includes new inventory and reporting requirements for refrigerants under N.J.A.C. 7:27E.
+ New Mexico
New Mexico has expressed intentions to introduce legislation to reduce HFC emissions but no legislative activities have taken place.
Status: Committed
+ New York
In alignment with the federal EPA SNAP Rules 20 and 23, New York enacted 6 NYCRR Part 494, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
New York has also initiated a new rulemaking under NYCRR Part 494 which uses the 20-year GWP value rather than the traditional 100-year GWP value. Under the proposed rule, New York retailers would be subject to the following GWP Limits:
- Supermarket Systems
- GWP >580 (20-year) for systems ≥50 lbs (Jan 1, 2025)
- GWP >943 (20-year) for systems <50 data-preserve-html-node="true" lbs (Jan 1, 2025)
- GWP >10 (20-year) (Jan 1, 2034)
- New Refrigeration Facilities: GWP >10 (20-year) for systems ≥50 lbs (Jan 1, 2026)
The rule also proposes a prohibition on the sale, distribution, or purchase of bulk regulated substances with the following GWP thresholds:
- GWP20 ≥4600 (Jan 1, 2025)
- GWP20 ≥4200 (Jan 1, 2030)
- GWP20 ≥3000 (Jan 1, 2033)
- GWP20 ≥1600 (Jan 1, 2040)
Finally, the rule also includes the following proposed elements:
- Refrigerant Management Program: Food retailers with ≥20 sites in NYS or ≥100 sites nationwide must register all equipment ≥50lbs
- Leak detection/monitoring
- Leak repair requirement
- Refrigerant Replacement Program (RRP) by Jan, 2035
- Retail Food Chains to submit optional replacement plan by Jan, 2027
+ North Carolina
North Carolina is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
+ Oregon
In alignment with the federal EPA SNAP Rules 20 and 23, Oregon introduced [HB 4024], which would prohibit certain HFCs in specific stationary refrigeration and air-conditioning end-uses. No further legislative activities have taken place.
Status: Bill Introduced
+ Pennsylvania
Pennsylvania has expressed intentions to introduce legislation to reduce HFC emissions but has not yet done so.
Status: Committed
+ Rhode Island
In alignment with the federal EPA SNAP Rules 20 and 23, Rhode Island enacted 250-RICR-120-05-53, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2022
+ Vermont
In alignment with the federal EPA SNAP Rules 20 and 23, Vermont enacted S.30, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
+ Virginia
In alignment with the federal EPA SNAP Rules 20 and 23, Virginia enacted 9VAC5 Chapter 145, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2022
+ Washington
In alignment with the federal EPA SNAP Rules 20 and 23, Washington enacted HB 1112, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2020
Washington has Finalized a rulemaking to update Chapter 173-443 WAC for HFCs and other fluorinated greenhouse gases that:
- Established GWP threshold <150 data-preserve-html-node="true" for HFCs used in new equipment (Jan 1, 2025)
- Established GWP threshold <150 data-preserve-html-node="true" for existing equipment that undergoes a retrofit (Jan 1, 2029)
- Established a refrigerant management program
- Amended product labeling and disclosure requirements
- Established fees to support the refrigerant management program
New Refrigeration Equipment: The rule prohibits refrigerants above 150 GWP in new stationary refrigeration equipment containing more than 50 pounds of refrigerant in food retail refrigeration starting Jan 1, 2025. The rule defines new refrigeration equipment as:
- New construction in a new facility
- Increased nominal compressor capacity of a system in existing facility
- New construction in existing facility not previously used for cold storage, retail food refrigeration, commercial refrigeration, industrial process refrigeration, or ice rinks
- System in an existing facility with cumulative replacement of 75% or more of its evaporators (by number) and 100% of compressor racks, condensers, and connected evaporator loads.
Retrofit Refrigeration Equipment: The rule also prohibits refrigerants above 150 GWP in retrofit refrigeration equipment containing more than 50 pounds of refrigerant in food retail refrigeration starting Jan 1, 2029.
See fact sheet summary from Refrigerant Management Solutions here.
+ Wisconsin
Wisconsin is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
Please Note: This page is meant to serve as an educational tool and is not intended to provide compliance advice. We encourage you to work with a compliance expert on your specific regulatory strategies.