Public Comments on EPA's Proposed Refrigerant Management Rules

December 18, 2023

Managing the installed refrigerant bank is a critical policy priority.

The American Innovation and Manufacturing (AIM) Act of 2020, which phases down the production and consumption of climate-polluting hydrofluorocarbon (HFC) refrigerants, is one of the most significant pieces of environmental legislation in recent US history. In addition to upstream controls, the AIM Act grants the Environmental Protection Agency (EPA) the authority to implement rules that accelerate the transition to climate-friendly cooling technologies and improve management of the installed refrigerant bank.

Earlier this fall, EPA published a final rule on technology transitions (under AIM Act Subsection (i)) and a proposed rule on refrigerant management (under AIM Act Subsection (h)). 

We strongly support all the proposed requirements advanced by EPA -- including those for technology transitions, leak detection and repair, use of reclaimed refrigerant, recovery of refrigerant from disposable cylinders, and container tracking.

Our in-depth response to the proposed rules under Subsection (h) is available for download below. 

Read our full response

Carbon Containment Lab's Comments on Proposed Refrigerant Management Rules


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