Hydrofluorocarbon transition

What is the difference between product disclosure and labeling?

The rule requires manufacturers to disclose the substitutes they've used. Labeling is the main way they can disclose. Refer to WAC 173-443-060(4) for specifics.

Can manufacturers use an existing label? What if there isn't an existing label?

If an existing label is required by another agency and includes the information required by our law, manufacturers can use that label.

If no label is required by another agency, manufacturers must use a label showing the same substitute name that appears in the safety data sheet.

What are the options for online disclosure?

Online disclosure is one way for manufacturers to disclose their products. It means making the information available on a public web site. Online disclosure must be combined with another disclosure method. That can be a symbol or code on the product, or a label required by another agency. Disclosure options differ by product type, so check WAC 173-443-060 for the specific product.

Do manufacturers have to label the foam used in their product if they don't manufacture the foam?

If the product is covered by the rule as listed in WAC 173-443-040 List of Prohibited Substances, Table 1, the foam must be labeled as outlined in WAC 173-443-060(4). The manufacturer of the foam must label the foam.

Why do manufacturers of commercial or household refrigeration equipment and chillers have to disclose the refrigerant and/or foam if they do not manufacture the foam?

Refrigeration equipment and chillers are covered products under the rule. Washington's HFC law requires disclosure of the substitutes used in covered products.

What equipment must be reported?

Manufacturers must report equipment if it is listed in WAC 173-443-040 and not exempt under WAC 173-443-050.

Can a business continue using existing equipment that contains HFC refrigerants?

Yes. A business can continue using existing equipment that contains HFC refrigerants because substance restrictions in the rule regulate new equipment. When equipment is replaced, the new equipment will be required to meet requirements.

Does this rule apply to firefighting foam?

No. The current rule covers HFC foams used in insulation and XPS foam products. Firefighting foam is not covered by this rule.

Does the rule apply to a product that is manufactured outside of Washington, only moving through Washington to be sold somewhere else?

No. The current rule does not apply to a product that is not bought or sold in Washington.

Does this rule apply to firefighting foam?

No. The current rule covers HFC foams used in insulation and XPS foam products. Firefighting foam is not covered by this rule.

Does the rule apply to a product that is manufactured outside of Washington, only moving through Washington to be sold somewhere else?

No. The current rule does not apply to a product that is not bought or sold in Washington.

Where is the reporting form?

The reporting form is available online. If you need help with the form, email HFC@ecy.wa.gov.

Does an importer or distributor of a product that is covered by the rule have to report if the manufacturer has already reported?

No. An importer or distributor doesn't need to report a product if the product has already been reported by the manufacturer. Check the list of manufacturers to verify this.

Who has to report:  The company that charged the refrigerant on-site after the cooling system was assembled or the manufacturer of the cooling system?

A manufacturer of the cooling system should report all suitable substitutes for specific equipment.