The new year has come and passed and 2025 is in full swing! This also means the next stage of the HFC refrigerant phase-out is here, so let’s review what that means for us architects, engineers, and contractors.
As a reminder, from our 2023 blog here, the AIM act was passed in 2020. The American Innovation and Manufacturing (AIM) Act gives the Environmental Protection Agency (EPA) the authority to regulate and phase down the production and use of hydrofluorocarbon (HFC) refrigerants. HFCs are known greenhouse gases, most of which are rated with a global warming potential (GWP) several thousand times that of carbon dioxide (which is the baseline of the scale, with a GWP of 1). The EPA has thus banned HFCs by setting limits to the allowable GWP of refrigerants manufactured or imported for use in the U.S. To Implement this ban, the EPA has implemented phase-out dates for the manufacturing and installation of different types of HVAC equipment, see below:
- 1/1/2025: The manufacturing and import stop date for direct expansion (DX) and heat pump systems such as rooftop units, water source heat pumps, and split systems (including mini-split and multi-split heat pump systems)
- This equipment has 1 year to be sold and installed until (1/1/2026).
- 1/1/2026: The manufacturing and import stop date for Variable Refrigerant Flow (VRF) systems.
- This equipment has 1 year to be sold and installed (until 1/1/2027)
- If the construction project was issued an approved building permit prior to 10/5/2023, then installation is allowed until 1/1/2028.
This means that the DX and Heat Pump equipment that we select and specify on our projects (other than VRF) can no longer be manufactured or imported with R-410A refrigerant. Going forward we must design and specify DX and Heat Pump equipment with refrigerants that meet the GWP limitations set by the EPA, which will mostly be R-454B and R-32 in our industry.
The biggest impact of these new refrigerants is the change in refrigerant classification. R-410 is classified as an A1 refrigerant that has low toxicity and no flame propagation (the lowest flammability). The newly used R-454B and R-32 refrigerants are classified as A2L refrigerants. A2L refrigerants have a low toxicity, with low flammability. This increased refrigerant classification from an A1 to an A2L refrigerant has increased code requirements to ensure the safety of the occupants, which must be considered in our designs going forward.
With the transition to these new A2L refrigerants in full swing, the following should be considered for projects in varying stages of the design and construction process:
- Projects in design should only be specifying equipment with low GWP refrigerants (other than VRF equipment). Code calculations shall be completed throughout design to implement any requirements needed to meet all code requirements. This could require transfer openings between rooms, refrigerant detection systems, or refrigerant exhaust systems.
- If projects that had been put on hold or had a long break between phases are coming back to life, the current mechanical system design shall be discussed with the mechanical engineer to confirm the implication of the new refrigerants on the project and what changes may be required. This may require some redesign of the mechanical systems, which could include changing the mechanical system type, reselecting DX equipment, completing refrigerant calculations, and implementing design changes to meet the requirements of the code. The time to make these changes should be considered between the engineer, the architect, and the owner.
- Projects in the beginning stages of construction shall be coordinated with the contractor to confirm if the DX equipment has been ordered or can still be ordered, received, and installed by the EPA-required dates. If the specified equipment with the old refrigerant cannot be ordered and/or installed, the engineer will need to complete the code-required refrigerant calculations to ensure the new refrigerants work with the design or implement design changes to meet the code.
With the shift to the newest refrigerants, one of our biggest restrictions as the selecting and specifying engineers over the past several months has been the ability to actually select the equipment with the new refrigerants and attain the refrigerant charges, equipment capacities, and efficiency ratings. Over the last month, a majority of manufacturers have confirmed the availability to select equipment with the new refrigerants, which allows us to finalize equipment selections and calculations. While there are still some minor restrictions in the availability of equipment specifics as the manufacturers continue to get the new equipment tested, the major equipment information is mostly available to move forward with selections.
In summary, the new refrigerant changes are upon us and will require additional calculations and coordination for DX systems that should be considered for projects in various stages of design and construction. The equipment manufacturers have made big strides to provide us, as the engineers, the information we need to get equipment selections, but there may be some minor lagging information we may need to wait for confirmation on. Overall, 360 Engineering is excited to move away from the limbo between two refrigerant types and start moving toward a more sustainable future.