CARB GWP Refrigerants Ban – Frequently Asked Questions

By Published On: July 29, 2020

The California Air Resource Board (CARB) passed a ruling to ban certain high GWP refrigerants, effective JANUARY 1st 2020. Many food retail companies have questions regarding these regulations. The following Q&A should help clarify the type of equipment effected and the timelines involved.

If you need more information email us at info@hillphoenix.com or call us at 770-285-3264.

Q1: What is the effective date for this regulation?
A: The original ruling went into effect on 1/1/2019. The effective dates provided in the table above refer to the date a Purchase Order was received for the equipment.

Self-Contained Medium-Temperature Units with a compressor capacity equal to or greater than 2,200 Btu/hour and Self-Contained Medium-Temperature Units containing a flooded evaporator (New): FOR12A, FOR12B, HFC-134a, HFC-227ea, KDD6, R125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, 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.

Self-Contained Low-Temperature Units (New): HFC-227ea, KDD6, R-125/290/134a/600a (55.0/1.0/42.5/1.5), R-404A, R-407A, R-407B, R-407C, R-407F, R-410A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-437A, R-438A, R-507A, RS-44 (2003 formulation)

Q2: Does this regulation apply to only new equipment?
A: This regulation applies to new equipment. The type of refrigerant prohibited is different in each situation and is outlined in the list above.

Q3: What is the definition of “new” equipment?
A: This regulation is applicable to “new” equipment and the following what is considered “new”:
1) Any refrigeration equipment that is first installed using new or used components (i.e. a new installation); or
2) Any refrigeration equipment that is modified such that it is:
(i) Expanded after the January 1st effective date, to handle an expanded cooling load by the addition of components in which the capacity of the system is increased, including refrigerant lines, evaporators, compressors, condensers, and other components; or
(ii) Replaced or cumulatively replaced after the January 1st effective date, such that the capital cost of replacing or cumulatively replacing components exceeds 50 percent of the capital cost of replacing the entire refrigeration system.

Q4: Does it impact me if I am doing a remodel or replacing existing units during service/repair?
A: The regulation is for “new” equipment – ie an entire case – regardless of where that case is being used – ie a new store or a remodel of an existing store. If a case is being installed in its entirety it must meet the regulation. If only components of the case are being replaced the regulation does not apply.

Q5: Can I replace the condensing unit in an existing self-contained case under this regulation?
A: Yes. If an existing self-contained case needs a replacement condensing unit then the condensing unit can be replaced, even if the refrigerant is prohibited under the new regulation.

Q6: If these are requirements for the state of California, do they impact me in other states?
A: For 2020 only California and Washington was impacted. However, many states that are part of the US Climate Alliance are actively making plans to follow California’s lead. New York, Maryland, Washington & Connecticut are the front runners in this effort. We will send out additional information in regards to other states activities, once they are published.

Q7: What refrigerant will Hillphoenix be using for self-contained cases?
A: Although this set of CARB regulation impacts product shipped to California and Washington, in 2020 Hillphoenix will start using R448A or R290 for all self-contained cases.

Q8: What other regulations go into effect in 2020?
A: Canadian regulations on refrigeration systems will become effective in 2020. Summary listed below

EQUIPMENT: Stand-alone medium temperature commercial refrigeration systems
GWP LIMIT: 1,400
EFFECTIVE DATE: Prohibited as of January 1, 2020.

EQUIPMENT: Stand-alone low temperature commercial refrigeration systems
GWP LIMIT: 1,500
EFFECTIVE DATE: Prohibited as of January 1, 2020.

EQUIPMENT: Centralized refrigeration system
GWP LIMIT: 2,200
EFFECTIVE DATE: Prohibited as of January 1, 2020.

Q9: For the Canadian regulation, what refrigerants would be permitted under this change?
A. Refrigerants under 2200 GWP include C02 (R744), R448A/R449A, and R407A/C/F, among others. R404A , R403B, and R507 would be prohibited under this regulation.