HCFC Phase-down Plan
The EPA recently released its proposed HCFC phase-down plan. To meet its obligations under the Montreal Protocol, the United States will phase out the manufacturing of R-22 based appliances on January 1, 2010. The HVAC industry has considered air conditioners and heat pumps as appliances. As part of the proposal, the EPA redefined appliances as “any device which contains and uses a refrigerant and which is used for household or commercial purposes ... Components such as condensing units, line sets, and expansion valves would not be considered appliances.” As part of the proposed ruling, the EPA has defined the date of manufacture of an appliance as:
- The refrigerant loop is completed,
- The appliance can function,
- The appliance holds the complete and proper charge,
- The appliance is ready for use in its intended purposes.
For split systems, this definition shifts the “appliance manufacturing date” from the date embedded in the manufacturer’s serial number to what the industry has historically considered the installation date. For packaged units, PTACs, and room air conditioners the manufacture date continues to be defined as the manufacture date contained in the manufacturer’s serial number.
Three weeks after the publication of this proposal, the EPA released a “Clarification Statement” that clarified several questions raised by its original proposal. One major question was if dealers could continue to install R-22 air conditioners and heat pumps after January 1, 2010. This clarification document clearly states that R-22 based air conditioners and heat pumps can be installed to service existing R-22 based appliances, “Sale and distribution would also be allowed for pre-charged appliance components that are manufactured before January 1, 2010 and used for the purpose of servicing existing (pre-2010) appliances. This means that components such as condensing units, line sets, and expansion valves that are charged with refrigerant and completely manufactured before January 1, 2010, but not yet installed in an appliance, could be sold and distributed for this purpose.” The clarification statement continues with, “Thus the proposed rules would not prohibit the sale or installation of stockpiled pre-charged condensing units that were manufactured before January 1, 2010, and used to replace a condensing unit in an existing residential split system.”
The following matrix summarizes the EPA’s proposal and clarification statement for residential products:
| R-22 Application | Installed Before 1/01/2010 | Installed After 12/31/2009 |
| New Construction | No restrictions if system is completely installed before 12/31/2009 | 1) Split systems: Prohibited 2) Package Units: No restrictions if manufactured by 12/31/09 |
| Replacement Replace a packaged unit or split system components, i.e. •condensing unit •evaporator coil •line set |
No restrictions | 1) Limited to packaged units and split system air conditioners, heat pumps, air handlers, and furnace coils manufactured before 1/1/2010 |
| Service 1) Repair a leak 2) Replace a compressor, condenser coil, service valve, TXV, SOV, etc. |
No restrictions | 1) No restrictions to adjust refrigerant charge in equipment manufactured before 1/1/2010 2) Can use precharged components manufactured before 1/1/2010 . 3) Can use precharged components manufactured after 1/1/2010 that use reclaimed HCFCs |
It is important to note that this is a summary of the EPA’s proposed plan and clarification statement. The final EPA ruling will not be released for another three to six months. There may be some minor modifications to this matrix with the final ruling. However, it is highly unlikely the EPA will reverse itself on allowing stockpiled R-22 split system air conditioners, heat pumps, coils, and air handlers to be installed in the replacement market after its stance in the Clarification Statement.