HFC refrigerant regulations continue to shape HVACR equipment decisions throughout the country — impacting commercial refrigeration, residential and light commercial air conditioning, and heat pump applications. Although a federal framework for the HFC phasedown is in place, some states are adopting their own policies.
In 2024, New York State’s Department of Environmental Conservation (NYDEC) finalized updates to its Hydrofluorocarbon Standards and Reporting regulation — 6 NYCRR Part 494 — which aimed to reduce GHG emissions by imposing limitations on HFCs and other high-GWP refrigerants, while banning the sale of bulk high-GWP HFCs.
NY Part 494 has similar goals to rules established by the Environmental Protection Agency (EPA) under the authority of the AIM Act, which did not include federal preemption. However, it has adopted a different approach to achieving them.
The EPA’s Technology Transitions rule (2023) mandated the transition to lower-GWP alternatives and set sector-based restrictions on HFC usage. Like the EPA’s Technology Transitions rule, NY Part 494 aims to reduce GHG emissions by imposing limitations on HFCs and other high-GWP refrigerants.
Managing compliance with federal and state HFC rules adds complexity for HVACR industry stakeholders. For those operating in New York State, it’s essential to understand the requirements of NY Part 494, pay special attention to definitions and charge limits, and prepare for compliance.
Key Components
There are several key components of NY Part 494, with a major one being the prohibition on bulk HFC sales. Effective January 9, 2025 — with a delay of enforcement until April 9, 2025 — the sale, distribution, or purchase of bulk regulated substances greater than 2,200 GWP is prohibited in New York State. Note: This uses the same 100-year GWP timeframe adopted by the EPA (i.e., GWP100). The enforcement of the ban on virgin refrigerants R-404A and R-507A has been extended through Dec. 31, 2025.
The regulation does not require replacing existing equipment before its useful life ends. Reclaimed refrigerants can be used to service existing equipment.
For HVACR contractors and service technicians, the ban’s timing (i.e., near immediate impact) and initial uncertainty about the availability of reclaimed refrigerants created concerns about the potential for refrigerant shortages. In 2023, 880,000 pounds of reclaimed R-404A refrigerant used by supermarkets and restaurants were available nationally. It’s estimated that New York State alone requires nearly that amount annually.
NY Part 494 also adopts the GWP20 metric, unlike the EPA’s HFC regulations, which use the 100-year GWP (GWP100) measure. This approach focuses on refrigerants’ immediate climate-related impacts to prioritize the urgency of making decisions to protect the environment. It highlights near-term, 20-year implications rather than a 100-year approach, and adds complexity because the relationship isn’t linear. For example:
- R-404A has a GWP20 of 7,208 and a GWP100 of 3,922;
- R-454B has a GWP20 of 1,854 and a GWP100 of 466; and
- R-32 has a GWP20 of 2,690 and a GWP100 of 675.
Although NY Part 494’s GWP20 metric differs from the EPA’s GWP100 preference, the impact on the choice of future ultra-low refrigerant alternatives is expected to be negligible — that is, the same refrigerant alternatives are mostly presently available at these limits.
Future Prohibitions
Another key component of NY Part 494 concerns future prohibitions on HFCs used in new HVACR equipment. Although NYDEC’s near-term prohibitions align with the EPA’s Technology Transitions rule, they will differ between 2027 and 2034. Both rulings adopt the EPA’s equipment classifications for manufacturing and selling self-contained products and installing field-charged systems as the bases of their prohibitions.
Note that applications that were permit-approved before January 9, 2025, have an additional year to comply if the prohibition date is before January 2027 and doesn’t exceed a federal restriction. For example, under the EPA, residential and light commercial split systems can only be installed until December 31, 2025. This would still need to be upheld under NY Part 494. Ultra-low temperature (-50°C or -58°F) systems are exempt from this equipment prohibition.
Per NY Part 494, starting January 2026, new supermarket refrigeration systems and remote condensing units containing more than 50 pounds of refrigerant must use alternatives with a GWP20 of less than 580. For systems with less than 50 pounds of refrigerant, the alternative must have a GWP20 of less than 943.
Beginning January 2034, all new supermarket refrigeration systems, remote condensing units, low- and medium-temperature, stand-alone units, vending machines, and cold storage warehouses will be required to use refrigerants with a GWP20 of less than 10, such as CO2, R-290, and HFOs R-1234yf and R-1234ze — all of which are available today.
From January 2026 through January 2034, all newly installed residential and light commercial air conditioners and heat pumps must use refrigerants with a 700 GWP100 or less. Replacing an outdoor condensing unit is considered an installation of new air conditioning equipment and would require complete system replacement using a lower-GWP alternative.
NY Part 494 also has a one-year, sell-through period on packaged residential air conditioners and rooftop units (i.e., products). This means packaged R-410A equipment manufactured before January 1, 2026, could be installed until January 1, 2027. In contrast, the EPA Technology Transitions rule granted a three-year sell-through period for products.
Starting in 2034 and beyond, this equipment must also use refrigerants with less than 10 GWP20. Each of the currently available alternatives presents unique application challenges in this sector:
- CO2 has much higher pressures and a low critical point, which introduces complexities at higher ambient conditions. These can be overcome, but typically at much higher costs.
- R-290 comes with safety-based charge limits that are restrictive for direct applications; indirect scenarios have inherent efficiency losses and raise concerns for replacement equipment with a fixed footprint and design.
- Today’s HFO options below 10 GWP20 are lower-capacity fluids that require significant equipment redesigns to get an equivalent Btu output.
Per these timelines, lower-GWP A2L refrigerants would enable compliance until 2034; ultra-low GWP A2L, CO2, and R-290 options would be needed to comply with the 10 GWP20 limit beyond 2034.
Additional residential and commercial HVAC subsectors — including heat pump water heaters, clothes dryers, pool or spa heaters, and dehumidifiers — have a compliance date of January 1, 2027. Aside from dehumidifiers, these applications have never been part of the scope of HFC rulemaking at the state or federal level.
HFC Management and Retrofits
NY Part 494 also calls for stricter management of HFCs, including labeling, recordkeeping/reporting, and leak detection and repair requirements. As of January 9, 2025, products and equipment containing HFCs must be appropriately labeled to inform users of their environmental impact, including identifying the type and quantity of HFCs present. For recordkeeping, parties involved in manufacturing, selling, distributing, or using HFCs must maintain detailed records and submit regular reports to the NYDEC.
Operators of equipment containing more than 50 pounds of refrigerant must conduct regular leak inspections. Monthly leak inspections are required for equipment with a charge capacity greater than 1,500 pounds. Detected leaks must be repaired promptly. Large refrigeration equipment greater than 1,500 pounds requires an automatic leak detection system, with initial installations required by June 2025.
Regarding retrofits, until January 1, 2029, systems can be retrofitted to use lower-GWP (GWP20) substitutes without being subject to the prohibitions applicable to new equipment — although they must have the same flammability safety classification. After January 1, 2029, retrofitting systems will be treated and regulated as new equipment. This approach encourages the transition to lower-GWP refrigerants in existing systems, such as supermarkets, before the 2029 deadline. After this date, retrofitted systems are subject to the same regulations as new systems to ensure consistency in environmental standards.
Also included in NY Part 494 is the supermarket “chain” refrigerant program, which applies to businesses that either own or operate 20 or more retail food facilities in New York that contain refrigeration systems with a refrigerant charge of 200 pounds or greater; or operate more than 100 such facilities in the United States, including New York.
By January 1, 2035, supermarket chains must meet one of the following conditions for their refrigeration systems containing 200 pounds or more of refrigerant:
- Ensure that all refrigerants used have a GWP20 less than 10;
- Achieve an annual refrigerant leak rate of 5% or less;
- Demonstrate that the total annual emissions from refrigerant loss across all equipment at each facility do not exceed the emissions that would result from meeting either condition 1 or 2; or
- Operate under an approved transition plan or have an approved variance; transition plans must be submitted before January 2027.
The new regulations under NYDEC Part 494 will significantly impact the HVACR equipment supply chain regarding products sold and installed in New York State. Depending on the sector, compliance will require low-GWP refrigerants in the near term and ultra-low-GWP refrigerants between 2027 and 2034. Copeland is helping New York stakeholders meet current requirements by leading the development of next-gen compression, controls, and leak detection platforms optimized for lower-GWP A2L refrigerants.
We’re monitoring the industry’s responses to these emerging state regulations and advocating for strategies that enable a successful HFC phasedown without posing unnecessary disruptions and hardships to HVACR equipment stakeholders.