HFC Policy Tracker
The HFC Problem
Federal Regulations
State Summaries
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.
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.
To explore our interactive map that tracks the regulatory status of each state, please view the site on a desktop.
The state expressed intentions to introduce legislation to reduce HFC emissions, but no bills have been signed into law.
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 °C. However, the state has not committed to regulating HFC refrigerants.
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.
Federal Regulations
Enacted in 2020, the American Innovation and Manufacturing (AIM) Act gives EPA authority in three main areas:
1. Phase down the production and consumption of HFCs in the United States by 85% by 2036, mirroring the Kigali Amendment. The Final Rule for Allowance Allocation Methodology for 2024 and Later Years was published on July 20, 2023.
2. Facilitate the transition to next-generation technologies, implement restrictions on specific HFC uses, and approve substitutes for regulated HFCs. The EPA’s revised final Technology Transition rule established the following GWP limits and compliance dates for NEW equipment:
- Supermarket systems: 1400 GWP (Jan 1, 2026) 150 or 300 GWP (Jan 1, 2032)
- Cold Storage: 700 GWP (Jan 1, 2026) 150 or 300 GWP (Jan 1, 2032)
- Condensing Units: 1400 GWP (Jan 1, 2026) 150 or 300 GWP (Jan 1, 2032)
3. Manage HFCs and substitutes through refrigerant-management requirements, including refrigerant reclamation and equipment servicing, repair, disposal, or installation. EPA’s Emissions Reduction and Reclamation (ER&R) Program now includes final requirements for leak repair, automatic leak detection, recordkeeping, and other refrigerant-management provisions, with reclaimed HFC requirements phasing in for certain servicing uses starting in 2029.
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.
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.
Since 2020, certain substitutes are prohibited when switching from ozone-depleting substances.
Summary by State
The following states have expressed interest in regulating HFCs or have enacted legislation to curb their use.
Summary by State
To best view the summaries by state, please view the site on a desktop.
Arizona is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
In alignment with the federal EPA SNAP Rules 20 and 21, California enacted SB 1013, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2019
Learn More >>
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 GWP* of less than 1,400
- Attain a 55% or more significant reduction in Greenhouse Gas Potential (GHGp)** 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
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*“Weighted-average GWP” is equal to ∑ (charge x GWP)/ ∑ charge
**“Greenhouse Gas Potential” or “GHGp” is equal to Σ (Charge × GWP)
In August 2022, the state also passed [SB 1206][7], 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, 2033
- 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. [7]: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB1206
In alignment with the federal EPA SNAP Rules 20 and 21, Colorado enacted Regulation 22, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
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Connecticut has expressed intentions to introduce legislation to reduce HFC emissions but no legislative activities have taken place.
Status: Committed
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In alignment with the federal EPA SNAP Rules 20 and 21, 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
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In alignment with the federal EPA SNAP Rules 20 and 21, 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
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In alignment with the federal EPA SNAP Rules 20 and 21, Maine enacted HP 161, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2022
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In alignment with the federal EPA SNAP Rules 20 and 21, Maryland enacted COMAR 26.11.33, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
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In alignment with the federal EPA SNAP Rules 20 and 21, Massachusetts enacted 310 CMR 7.76, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
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Michigan is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
Minnesota is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
Nevada is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
In alignment with the federal EPA SNAP Rules 20 and 21, New Jersey enacted A-5583, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: July 1, 2020
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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 has expressed intentions to introduce legislation to reduce HFC emissions but no legislative activities have taken place.
Status: Committed
Learn More >>
In alignment with the federal EPA SNAP Rules 20 and 21, 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
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New York has also finalized a new rulemaking under NYCRR Part 494 which uses the 20-year GWP value rather than the traditional 100-year GWP value.
Under the final rule, New York retailers would be subject to the following GWP Limits:
- Supermarket Systems (New)):
- GWP (20-year) > 580 for systems ≥50 lbs (Jan 1, 2026)
- GWP (20-year) > 943 for systems <50 lbs (Jan 1, 2026)
- GWP (20-year) > 10 (Jan 1, 2034)
- Stand-alone units (New):
- GWP (20-year) > 10 (Jan 1, 2034)
- New Refrigeration Facility:
- GWP (20-year) > 10 for systems ≥200 lbs (Jan 1, 2026)
For refrigeration, ‘New’ products or equipment are defined as anything that meets any of the following criteria after the prohibition date:
- Manufactured after the effective date
- First installed after the effective date
- Retrofitted after the effective date
- Expanded by the addition of components to increase system cooling or nominal capacity after the effective date
- Refrigeration equipment that has been modified such that 75% or more of its evaporators and 100% of its compressor racks, condensers, and connected evaporator loads (by number) were cumulatively replaced after the effective date
‘New Refrigeration Facilities’ are defined as new refrigeration systems intended for use in any or all of the following:
- New construction of a facility.
- The repurposing of an existing facility into a new retail food facility, cold storage warehouse, industrial process refrigeration facility, or ice rink.
The rule also includes a prohibition on the sale, distribution, or purchase of bulk regulated substances with the following GWP thresholds:
- GWP (100 year) ≥ 2,200 (Jan 9, 2025)
- GWP (100 year) ≥ 1,500 (Jan 1, 2030)
- GWP (100 year) ≥ 750 (Jan 1, 2033)
- GWP (20 year) ≥ 1,600 (Jan 1, 2040)
- Small containers of automotive refrigerant containing virgin substances (Jan 1, 2027)
Additionally, the rule includes a Supermarket Refrigeration Program under which all businesses owning or operating ≥ 20 retail food facilities with a refrigerant charge capacity of ≥ 200 pounds in New York OR that operates > 100 such facilities in the US must meet one of the following conditions by January 1, 2035:
- All refrigerants used in supermarket systems containing ≥ 200 lbs of refrigerant have a GWP20 of < 10.
- Annual refrigerant loss from supermarket systems containing ≥ 200 lbs of refrigerant is ≤ 5%.
- Annual emissions from refrigerant loss from all equipment at each facility does not exceed a comparable emission quantity as would result from meeting either of the above conditions at that facility.
- There is an approved Transition Plan or an approved variance (transition plans must be submitted before Jan 1, 2027).
Finally, the rule also includes the following proposed elements:
- Labeling requirements
- Refrigerant Management Program
- Leak detection/monitoring
- Leak repair requirements
See helpful fact sheet summaries from Refrigerant Management Solutions here.
View a helpful FAQ document from the NYS DEC here.
North Carolina is a member of the US Climate Alliance but has not committed to regulating HFC refrigerants.
In alignment with the federal EPA SNAP Rules 20 and 21, 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
Learn More >>
Pennsylvania has expressed intentions to introduce legislation to reduce HFC emissions but has not yet done so.
Status: Committed
Learn More >>
In alignment with the federal EPA SNAP Rules 20 and 21, 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
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In alignment with the federal EPA SNAP Rules 20 and 21, Vermont enacted S.30, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2021
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In alignment with the federal EPA SNAP Rules 20 and 21, Virginia enacted 9VAC5 Chapter 145, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2022
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In alignment with the federal EPA SNAP Rules 20 and 21, Washington enacted HB 1112, prohibiting certain HFCs in specific stationary refrigeration and air-conditioning end-uses.
Supermarket Effective Date: January 1, 2020
Learn More>>
Washington has Finalized a rulemaking to update Chapter 173-443 WAC for HFCs and other fluorinated greenhouse gases that:
- Established GWP threshold less than 150 for HFCs used in new equipment (Jan 1, 2025)
- Established GWP threshold less than 150 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.
Learn more about prohibitions of certain HFC uses here.
Learn more about the refrigerant management program (RMP) here.
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 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.