EPA Wants to Relax, Delay Limits on Production & Consumption of Hydrofluorocarbons (and How You Can Push Back)

We need to start with a little science lesson so we can drive home an air quality issue that probably isn’t on your radar. The subject? Hydrofluorocarbons (HFCs), which are a family of chemicals used mostly in refrigerators and air conditioners.  

For such uses, they have replaced chlorofluorocarbons (CFCs), which were phased out worldwide by the so-called Montreal Protocol, an international agreement struck in 1989. CFCs damage the stratospheric ozone layer, which protects us from harmful ultraviolet rays. 

HFCs, on the other hand, do not affect the ozone layer, but (and this is a big but) due to their potency as greenhouse gases are themselves subject to an international phase-down agreement, the Kigali Amendment, which was reached in 2016, and ratified by the United States in 2022.

How potent are they, you ask? They can be hundreds – and in some cases thousands – of times as potent as carbon dioxide (CO2).

Although HFCs are a potent greenhouse gas, they linger in the atmosphere for a much shorter time than CO₂ so reducing emissions of HFCs could have a relatively immediate and significant impact on global warming.  

They are, so to speak, low-hanging fruit (which is where we come in).

Here’s what’s going on: Just before the federal government shut down on Oct. 1, the EPA proposed a rule that would relax and delay limits on the production and consumption of HFCs used for refrigeration in transport, cold storage warehouses, and retail food stores, as well as in semiconductor manufacture, based on industry petitions that claimed that the original deadlines and limits were either impossible or impractical.  

Those original limits were set by regulations that EPA promulgated in 2023 (known as the Hydrofluorocarbon Technology Transitions Rule) under authority of the American Innovation and Manufacturing Act of 2020. That Act requires that the production and consumption of HFCs in the United States be reduced by 85 percent (relative to 2011-13 levels) by 2036.

“EPA estimated that the 2023 regulations would result in a cumulative reduction in emissions of HFCs of between 83 and 876 million tons of CO₂ equivalent between 2025 and 2050,” GASP Senior Attorney John Baillie said. “Should the recently-proposed changes become effective, EPA estimates that the regulations would result in a smaller cumulative reduction, of between 82.59 and 710.42 million tons of CO₂ equivalent between 2025 and 2050.  As you will note, there is a lot of wiggle room in both of those estimates.” 

EPA is accepting comments on its proposed revisions to the Hydrofluorocarbon Technology Transitions Rule through Nov. 17. 

You can submit comments at https://www.regulations.gov under Docket ID No. EPA-HQ-OAR-2025-0001.