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Equipment Manufacturers, Importers, and Exporters Frequently Asked Questions

As the United States continues to phase out HCFCs, equipment manufacturers, importers, and exporters will need to adapt to the changing market demand for equipment. EPA provides the following answers to frequently asked questions to help you better understand the phaseout and your responsibilities in implementing the regulations.

May I manufacture equipment containing R-22 or R-142b after January 1, 2010?

No. Neither appliances nor components pre-charged with HCFC-22 or HCFC-142b may be manufactured as of January 1, 2010.

In addition, for these purposes the term manufacture to include the assembly of a new system from its component parts. Thus, pre-charged components produced prior to January 1, 2010, may not be assembled to create new appliances as of January 1, 2010. However, these components may be used to service existing appliances.

What if I use reclaimed or stockpiled R-22 to manufacture my equipment?

Neither stockpiled HCFC-22 produced prior to January 1, 2010, nor HCFC-22 that has been recycled or reclaimed, can be used in manufacturing new appliances or components on or after January 1, 2010. Thus, self-contained, factory-charged appliances such as pre-charged window units, packaged terminal air-conditioners (PTACs), and some commercial refrigeration units may not be manufactured with R-22 as of January 1, 2010, regardless of whether the R-22 was virgin or reclaimed.

May I sell equipment containing R-22 or R-142b after January 1, 2010?

The answer to this question depends on when the equipment was manufactured and what type of equipment it is.

Self-contained, factory-charged appliances that are pre-charged with R-22 or R-142b may be sold if they were manufactured before January 1, 2010. The same is true for pre-charged appliance components (e.g. condensing units, line sets, and coils that are charged with refrigerant) if those components are used to service existing appliances.

May I import or export equipment containing R-22 or R-142b from/to other countries?

No. EPA regulates U.S. interstate commerce, which includes both the domestic sale and distribution of any appliance imported into the United States, and the domestic sale or distribution of any appliance intended for ultimate export from the United States. Both 1) imports of appliances for sale and distribution in the U.S. and 2) the sale and distribution of any appliance intended for export from the U.S. are acts of interstate commerce.

EPA is not restricting the export of appliances that are shipped without refrigerant or with a holding charge of nitrogen. Thus, U.S. manufacturers are not precluded from responding to the demand for HCFC appliances in Article 5 countries.

Can existing equipment containing R-22 still be serviced?

Yes, existing equipment may continue to be serviced. Servicing may include the replacement of failed components. Thus, pre-charged components (e.g. condensing units, line sets, and coils produced prior to January 1, 2010, may be sold and installed to service an existing R-22 system that is in need of repair. For example, an existing R-22 split air-conditioning system (i.e., appliance), undergoing service in 2010 or later, may have individual components of the system replaced with pre-charged R-22 components that were manufactured prior to January 1, 2010.

What do I do if I am currently working on a project containing R-22 systems but I cannot install the system by January 1, 2010?

EPA understands that some contractors that manufacture vehicles, mobile homes, and buildings are under contract to install R-22 systems and construction has commenced but are unable to install (i.e. complete the manufacture of) the R-22 system by January 1, 2010. EPA is providing a limited exception to the prohibition on the manufacture of new systems. EPA is allowing appliances containing HCFC-22 to be installed for a particular project between January 1, 2010, and December 31, 2011, if the components have been specified for use at that project under a building permit or a contract dated before January 1, 2010.

Are there labeling requirements for equipment containing R-22?

Section 611 of the Clean Air Act requires that by 2015, equipment containing or manufactured with HCFCs contain a label that warns buyers that the equipment contains a substance that is known to harm public health and the environment by destroying ozone in the upper atmosphere.

Are there any restrictions on other HCFC-containing products, such as packaging foams and pressurized containers?

Yes. Under the nonessential products ban, since 1994 most aerosol products, pressurized dispensers, and foam products containing or manufactured with HCFCs are banned from sale and distribution in interstate commerce in the United States. A few products are exempted by EPA regulations and in some cases also are listed as essential medical devices by the Food and Drug Administration (21 CFR 2.125(e)).

As of January 1, 2010, virgin HCFC-22 and HCFC-142b may only be used to service existing refrigeration and air conditioning equipment, with a few minor exceptions. Thus, HCFC-142b, which prior to January 1, 2010, was primarily used to blow foam, is now limited after that date solely to use as a refrigerant. One exception relevant to equipment manufacturers is that EPA is allowing the continued production and use of thermostatic expansion valves (TXVs) after January 1, 2010, but no later than December 31, 2014, provided that the HCFC-22 was produced prior to January 1, 2010. A similar exception is for medical equipment that uses HCFC-22.

Products that use HCFCs other than HCFC-22 or HCFC-142b may continue to be manufactured and sold until December 31, 2014, so long as all other relevant restrictions are met.

Other Frequently Asked Questions About the Phaseout of HCFC-22

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