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A2L Essentials Issue 2: Regulatory Overview 

article Published on 2024-08-02
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New regulatory changes are fast approaching! The Environmental Protection Agency (EPA) is taking steps to limit the use of refrigerants with a high Global Warming Potential (GWP). Don’t be caught off guard by these changes! To make sure your unit remains in compliance, it is critical that you are familiar with the details surrounding this change. 

The EPA calculates a refrigerants GWP by examining how much energy one ton of gas releases over a select period and compares it to the amount of energy released by Carbon Dioxide (CO2) in that same amount of time. The higher a refrigerant GWP rating, the more greenhouse gases that refrigerant releases into the atmosphere. Greenhouse gases trap infrared thermal radiation in the atmosphere, leading to global warming.

As a part of the EPA Technology Transition, the EPA is regulating these changes by releasing Significant New Alternative Policies, or SNAPs. SNAP regulations specifically target the HVACR industry and have been established in the hopes to limit the role HVACR plays in climate change. SNAP regulations are rapidly limiting refrigerant use in the cold storage and chiller air conditioning industry. These refrigerant changes will accompany many modifications to unit design and equipment, allowing new installations to handle these new refrigerants safely and effectively.

This chart outlines the most important SNAP decisions and how they have impacted commercial refrigeration so far:

 SNAP Establishes/Rejects Refrigerant Effected For  Effective
 SNAP 20  Rejects  R-404A and R-507A  Retail Food Refrigeration July 20, 2015 
 SNAP 21   Rejects  R-404A and R-507A  Cold Storage Warehouses  December 1, 2016
 SNAP 23 Part 1  Establishes  R-448A, R-449A, and R-449B  Refrigeration and Air Conditioning Sector  January 1, 2022
 SNAP 26   Establishes  HFC-32, HFO-1234yf, HFO-1234ze(E), R-454A, R-454B, R-454C, R-455A, R-457A, and R-51 A  Refrigeration and Air Conditioning Sector  July 15, 2024

 SNAP 26 is the most recent regulatory document. It outlines specific applications and use cases for ten separate refrigerants. You can view a quick summary of the details below.

Commercial Ice Machines HFC 32*, HFO 1234yf, R-454A*, R-454B*, R-454C, R-455A, R-457A, R-516A 
Industrial Process Refrigeration HFC 32*, HFO-1234yf, HFO-1234ze(E), R-454A, R- 454B*, R-454C, R-455A, R-457A, R-516A
Cold Storage Warehouses HFO-1234yf, HFO-1234ze(E), R-454A*, R-454C, R-455A, R-457A, R-516A
Retail Food Refrigeration (depending on application) HFO-1234yf, HFO-1234ze(E), R-454A*, R-454C, R-455A, R-457A, R- 516A, R-290
Commercial Ice Machines—Self-Contained Units R-290*
Retail Food Refrigeration—Stand-Alone Units R-290*/td>

*additional specifications depending on circumstance.


Many states are rushing to adopt SNAP regulations into legislation, especially states that are members of the United States Climate Alliance (USCA).

The members of the USCA include:

  • Arizona
  • California
  • Colorado
  • Connecticut
  • Delaware
  • Guam
  • Hawaii
  • Illinois
  • Maine
  • Maryland
  • Massachusetts
  • Michigan
  • Minnesota
  • New Jersey
  • New Mexico
  • New York
  • North Carolina
  • Oregon
  • Pennsylvania
  • Puerto Rico
  • Rhode Island
  • Vermont
  • Washington
  • Wisconsin

For more information on how these regulations are specifically affecting your state, head to Heatcraft’s Regulatory Page Online. An important distinction to be aware of when understanding the effects SNAPs have on you and your state, is the EPA’s definition of both products and systems. The EPA Technology Transition clarifies that a product is equipment that is completed or functional (e.g., self-contained refrigeration) upon leaving the factory. Meanwhile, a system is an assemblage of separate components that are typically connected and charged in the field. Want to know more about A2L’s and Low GWP regulations? Subscribe to Heatcraft TV to never miss a blog post. Stay tuned for more information on Low GWP options, mitigation details, and best practice methods so that you and your business can stay competitive and in compliance!

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