Refrigerants: Ozone-Depleting Substances and Substitutes

In the United States, refrigerants that harm the earth’s ozone layer – commonly called “ozone-depleting substances” or ODS – are regulated by the U.S. Environmental Protection Agency (EPA) and some US states. Regulated refrigerants include substances that EPA has classified as “Class I” or “Class II” ODS, any substance that includes a Class I or Class II ODS, and “Substitutes” for ODS. At a high level:

• Class I and Class II ODS: EPA publishes a complete list of Class I and Class II ODSs. Some of the more common Class I ODS are R-12, halon, and methyl bromide. Some of the more common Class II ODS are Freon (also called R-22 and HCFC-22) and HCFC 142b
• Substitute Refrigerants: EPA publishes lists of Substitute Refrigerants that are acceptable, acceptable with use restrictions, or unacceptable. Substitute Refrigerants are a broad category and generally includes chemicals and products that are used as substitutes for Class I and Class II ODS to cool and transfer heat. Some common Substitutes acceptable with use conditions include R-134a and R-441a

Except for a few very narrow exceptions, Class I ODS, Class II ODS, and Substitute Refrigerantss can only be sold, distributed, or offered for sale or distribution to buyers who have been certified as technicians through EPA-approved certification programs. These products are not permitted for sale on Amazon

The sale and distribution restrictions do not apply to a limited number of exempt substances that can be used for cooling and heat transfer. Examples of Exempt Refrigerants include the following: (1) carbon dioxide (R-744) used as a refrigerant; (2) nitrogen (R-728) used as a refrigerant; and (3) refrigerants used for motor vehicle air conditioners (MVAC) in a container with a self-sealing valve designed to hold two pounds (32 oz) or less.

Examples of permitted listings

• Refrigerants that comply with all federal, state, and local laws and regulations, including the federal Clean Air Act and related Rules and Notices
• Exempt Refrigerants marketed only for permissible uses, including refrigerants for use in a MVAC which are contained in self-sealing containers designed to hold 2 pounds (32 oz) or less if the refrigerant is not a Class I or Class II ODS. These products must clearly state the refrigerant, its use, the container size, and the valve type (for example, R-134a for MVAC use in a 20-ounce self-sealing container) Note: some EPA Exempt Refrigerants may be subject to additional state restrictions due to local laws.
• Refrigerators, freezers, or other assembled products or appliances that include refrigerants
• Empty refrigerant tanks

Examples of prohibited listings

• Any Class I or II ODS
• Substitute Refrigerants that are legal for sale only to certified technicians
• Exempt Refrigerants marketed for impermissible uses

Additional useful information

• EPA guidance on Ozone-Depleting Substances (ODS), which provides details on transportation requirements for some hazardous substances
• EPA Significant New Alternatives Policy (SNAP) Program
• ODS Regulations
• Class I substances
• Class II substances

  Last updated 05/27/2022