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Equipment Manufacturers, Importers, and Exporters: Frequent Questions

The following information can help equipment manufacturers, importers, and exporters better understand their responsibilities in the phaseout of ozone-depleting substances (ODSHelpODSA compound that contributes to stratospheric ozone depletion. ODS include chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, methyl bromide, carbon tetrachloride, hydrobromofluorocarbons, chlorobromomethane, and methyl chloroform. ODS are generally very stable in the troposphere and only degrade under intense ultraviolet light in the stratosphere. When they break down, they release chlorine or bromine atoms, which then deplete ozone. A detailed list (http://www.epa.gov/ozone/science/ods/index.html) of class I and class II substances with their ODPs, GWPs, and CAS numbers are available.).

Q. May I manufacture equipment containing hydrochlorofluorocarbon (HCFC)-22 or HCFC-142b after January 1, 2010?

A. No, neither appliances nor components pre-charged with HCFC-22 (also called R-22) or HCFC-142b may be manufactured as of January 1, 2010. “Manufacturing” includes the assembly of a new system from its component parts. Thus, pre-charged components produced before 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.

Q. May I use reclaimed or stockpiled HCFC-22 to manufacture my equipment?

A. No, neither stockpiled HCFC-22 produced prior to January 1, 2010, nor HCFC-22 that has been recycled or reclaimed, can be used to manufacture new appliances or components after January 1, 2010.

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

A. 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 HCFC-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.

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

A. No, but 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.

Q. Can existing equipment containing HCFC-22 still be serviced?

A. Yes, existing equipment may continue to be serviced. Servicing may include the replacement of failed components.

Q. Are there labeling requirements for equipment containing HCFC-22?

A. Yes, equipment containing or manufactured with HCFCs must display 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.

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

A. Yes, most aerosol products, pressurized dispensers, and foam products containing or manufactured with HCFCs have been banned from sale and distribution in interstate commerce in the United States since 1994. 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)).

Virgin HCFC-22 and HCFC-142b may only be used to service existing refrigeration and air-conditioning equipment, with a few minor exceptions.

Other Frequent Questions About the Phaseout of HCFC-22