As the industry shifts towards smaller-diameter tubing to improve heat transfer in heat exchangers,...
The Environmental Protection Agency (EPA) continually sets new targets, challenging industries to adapt swiftly to evolving regulations. In the HVAC/R industry, the transition to alternative refrigerants presents a significant policy shift, reshaping the landscape for Original Equipment Manufacturers (OEMs) and stakeholders alike.
Policy Impacts for Refrigerant Changes
The Montreal Protocol mandates a reduction of 80% HFC refrigerants by 2025 or 87% by 2047. Recently, the U.S. passed the AIM Act, aligning with the Kigali amendment. The target is an 85% HFC reduction over the next 15 years. The EPA now has the power to manage the process of an HFC phase-down through the Significant New Alternatives Policy (SNAP). Over the past two years, several rules — specifically, 23 through 26 — have been passed, with at least three being final. A fourth is still in the proposal stage.
The California Air Resources Board (CARB) has been instrumental in driving refrigerant policy change ahead of other states. California has a history of adopting SNAP before other states. Additionally, the state has established GWP (Global Warming Potential) limits for new facilities and systems.
In Europe, the F-gas Regulation requires a 95% reduction in HFCs by 2030, compared with their 2015 baseline, and a 100% reduction by 2050. This means their phase-down is more aggressive than in the United States, but both work towards the same reduction goals.
The EPA's most recent final rule was in October 2023. The Technology Transitions Restrictions limit the use of certain HFCs under Section (i) of the AIM Act. This rule lists various subsectors, specific products, and applications within the HVAC/R industry sector instead of listing specific acceptable refrigerants, as it has done through other SNAP rules.
This approach allows for new refrigerants that meet the applicable limit. Most of these requirements go into effect in January 2025, while several others become effective in January 2028.
An Eye on the Target
Tracking all of these policy changes is a fast-moving target. Several online resources can help you determine what's happening, what states have adopted, and what policies are in place. For example, the North American Sustainable Refrigeration Council has an excellent free online tracker focusing primarily on commercial refrigeration applications.
Equipment manufacturers often hesitate to embrace changes in refrigerant policy, finding reasons to delay or alter their approach. The transition presents a formidable challenge, whether due to concerns about costs, technical complexities, or regulatory compliance uncertainties.
Overcoming Policy Shifts and Challenges
Changing refrigerants presents various design challenges in heat exchangers, including impacts on system performance and consideration of individual component design and selection. However, there is a mechanism to help resolve some of the challenges.
In this Whirlpool case study, small-diameter copper tubes and heat exchangers can help limit the refrigerant charge if transitioning to a flammable or toxic refrigerant.
Optimizing heat exchangers has the opportunity to help increase capacity or efficiency as well as reduce costs. Ultimately, appropriate redesign can lead to long-term savings and product success.
The Copper Development Association (CDA) and Optimized Thermal Systems R&D support OEMs requiring heat exchanger redesign. CDA and OTS R&D have worked together on various projects for nearly 10 years, partnering with OEMs to transition to a new refrigerant, targeting specific product goals, or developing a new product entirely. The majority of this work focuses on design and simulation.
Still, support is also provided with prototyping and testing individual heat exchangers and whole system assemblies incorporating a new heat exchanger design.
Please do not hesitate to contact the CDA if you have any questions or want to discuss your design challenges. You can learn more about partnering with the CDA here.
