FAQs & resources
Our team receives many questions regarding the hydrofluorocarbons (HFCs) rule, restrictions, and requirements. To best support the transition away from HFCs, we've consolidated educational resources for both the public and those affected by the rule below.
If you're having trouble locating a specific resource or you have a question that isn't listed, please email our team at HFC@ecy.wa.gov for assistance.
Frequently asked questions about compliance
We answer common questions about which businesses are affected by the 2019 law and what they need to do to comply. The answers reflect the current rule.
What HFCs are prohibited in Washington and why?
In 2019, the Washington legislature found that hydrofluorocarbons (HFCs) are air pollutants that pose significant threats to our environment. Although HFCs currently represent a small portion of the state’s greenhouse gas emissions, HFC emissions have rapidly increased and are exponentially more potent than carbon dioxide.
The Legislature required Ecology to reduce HFC emissions by
- transitioning to the use of less damaging chemicals in certain new foam, aerosol, refrigeration, and air conditioning uses.
- establishing global warming potential (GWP) requirements for refrigerants used in refrigeration and air conditioning equipment, including heat pumps.
- applying the same emission control requirements to HFCs that apply to ozone depleting substances (ODSs).
- establishing a refrigerant management program for existing equipment.
Specific information can be found on which substances are restricted in WAC 173-443-040. Information on the Refrigerant Management Program for existing equipment can be found in WAC 173-443-105.
Do the HFC restrictions apply to equipment that are currently installed or in use?
In November 2023, we adopted a rule supporting the transition away from hydrofluorocarbons that's broken down into two parts:
Part I – Prohibitions on the use of certain hydrofluorocarbons
- Part I prohibitions only apply to new products or equipment in Washington state, purchased and installed after the compliance date for each subsector.
- Prohibitions on the use of certain HFCs doesn't restrict HFC use in products and systems installed, and in use prior to compliance date for the relevant subsector.
Part II – Refrigerant Management Program
- The Refrigerant Management Program (RMP) applies to existing refrigeration and air conditioning equipment containing more than 50 pounds of refrigerant with a GWP greater than 150.
- Details for both parts are listed in the rule.
Can I continue to use my air conditioner?
Yes, you can continue to use your air conditioner. The HFC restrictions don't limit the use of any existing product or equipment.
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 only new equipment. When equipment is replaced, the new equipment must meet requirements.
My air conditioner broke. Do I need to buy a whole new system with the lower GWP refrigerant, or can I replace the faulty component?
Homeowners can maintain and repair their systems throughout the life of the equipment, and replace faulty components such as a condensing unit, indoor coil, and other smaller parts. After Jan. 1, 2026, if a whole new system is installed, it must use lower GWP refrigerant.
What counts as a new refrigeration or air conditioning system?
A refrigeration system would be considered new if it's:
- installed in a newly constructed home or business.
- installed as part of new construction in an existing facility not previously used for refrigeration.
- in an existing facility if it's modified by the cumulative replacement of 75% of indoor evaporators and 100% of compressors and condensers.
An air conditioning system would be considered new if it's:
- installed in a newly constructed home or business.
- installed in an existing home or business if both the exterior condensing unit and indoor evaporator unit are replaced together.
- in an existing facility and has more than one condenser and more than one evaporator that have been modified by the cumulative replacement of 75% of its indoor evaporator units and all of its condensing units.
Can replacement components manufactured after the compliance date be used for maintenance?
Replacement components, regardless of manufacture date, can be used for maintenance of existing and new equipment. Please note that if a large percentage of the components are replaced, the system is considered new and would trigger the compliance requirements for new refrigeration equipment or new air conditioning equipment. Specific compliance requirements are listed in WAC 173-443-040.
Is there a point at which replacing components triggers the GWP limits for new systems?
Yes. Replacing 75% or more of the evaporators (by number) and 100% of the compressor racks, condensers, and connected evaporator loads of an existing system would trigger the compliance requirements of new systems. In Washington, all new systems refrigerants must follow the GWP restrictions in Tables 2 and 3 once that threshold is reached. More specific compliance requirements are listed in WAC 173-443-040.
Are any technologies exempt from the prohibitions on the use of certain HFCs?
WAC 173-443-050 lists the exemptions that are applicable for certain end uses.
Which equipment must be reported?
Manufacturers must report equipment if it is listed in WAC 173-443-040, Table 1, and not exempt under WAC 173-443-050.
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.
Is there an online process for manufacturers to disclose their products?
Online disclosure — making the information available on a public website — is one way for manufacturers to disclose their products. Online disclosure must be combined with another disclosure method, such as a symbol or code on the product, or a label required by another agency. Disclosure options differ by product type; check WAC 173-443-060 for the specific product.
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.
Do manufacturers have to label the foam used in their product if they don't manufacture the foam?
If the product is listed in WAC 173-443-040 List of Prohibited Substances, Table 1, the foam needs to be labeled as outlined in WAC 173-443-060(4). The manufacturer of the foam must label the foam, as well as the manufacturer using the foam in their product.
Do the prohibitions on the use of certain HFCs apply to firefighting foam?
No. The current rule covers HFC foams used in insulation and XPS foam products. Firefighting foam isn't covered by this rule.
Do the prohibitions on the use of certain HFCs apply to a product that's manufactured outside of Washington and is only moving through Washington to be sold somewhere else?
No. The current rule doesn't apply to a product that isn't bought or sold in Washington.
What is the Refrigerant Management Program?
The Refrigerant Management Program (RMP) aims to reduce greenhouse gas emissions from refrigeration and air conditioning equipment. This regulation applies to systems containing more than 50 pounds of a refrigerant with a GWP greater than 150, and requires leak inspection, system registration, and regular reporting to Ecology.
Who must comply with the RMP?
Any owner/operator of a facility with a system using more than 50 pounds of a refrigerant with a GWP of more than 150 must comply with the program. The compliance threshold applies to the system with the largest refrigerant charge at the facility, not the total charge of all systems.
Anyone who services equipment subject to the RMP, as well as wholesalers, distributors, and reclaimers of refrigerants above a GWP of 150, are also affected by this regulation.
How can a business determine the refrigerant charge of their refrigeration system?
The full charge weight of a system can be determined by checking the equipment plate, reviewing the service records, or by contacting your service provider or manufacturer. California Air Resources Board provides a charge calculator to calculate the charge from the size components in the system.
When can owners expect to receive their invoice for the annual implementation fee?
Invoices will be sent after the facility is registered. For future compliance, invoices will be sent after the submittal of the annual report. The invoice must be paid within 30 days of receipt.
Can I register multiple, separate facilities in RMP?
Yes, and you have an obligation to pay for each facility each year.
When is the annual reporting due?
Annual reports must be submitted by March 15. Specific dates are listed in WAC 173-443-185.
How long do I have to keep my records?
Records must be kept for a minimum of five (5) years.