For the auto care industry, the major impact will occur in the vehicle air conditioning sector where HFC-134a is found in most vehicle a/c systems. Although many vehicle manufacturers have moved to the use of R-1234yf in newer vehicles due to its much lower impact on greenhouse gas emissions, there is still a significant number of vehicle on the road today that use HFC-134a and that will require it for servicing well into the future.

The Agency rulemaking would implement the phasedown through the issuance of transferrable production and consumption allowances, which producers and importers of HFC would need to possess in quantities equal to the amount of HFC they produce or import each year. The new rule issued by EPA establishes production and consumption baselines which will serve as the basis for the phasedown of HFC’s. Beginning Jan. 1, 2022, it will be prohibited to produce HFC’s without the appropriate allowances issued by EPA.

Also included in the new rule is a prohibition beginning in 2025 of HFC’s in non-reusable containers, known as DOT-39 containers. According to the new rule, EPA believes that the prohibition is “strong component within the suite of enforcement compliance tools that will deter illegal activity in the HFC market and allow EPA to enforce the program as directed by Congress.” Of importance to the auto care industry, the new rule does provide an exemption from the non-reusable container prohibition for the sale of refrigerants in small containers (less than 20 pounds) if they are equipped with a self-sealing valve now required for the sale of small refrigerant containers.

The rule also will require beginning on January 1, 2025 that HFC producers include QR codes on all containers sold or distributed or offered for sale or distribution. The requirement would expand to re-packagers and cylinder fillers in the U.S on Jan. 1, 2026 and to all containers of HFC’s on Jan. 1, 2027.