Legislation/budget actions needed to cut refrigerant emissions

Climate Action California, 350 Humboldt, and partners have submitted these suggestions to the California Air Resources Board (CARB). Still, they are likely to require legislation in order to take effect.


  • Require elimination of F-gases by 2035, with HFCs to be eliminated, except in special circumstances, by 2030. Require that replacement gases must not have significant or long-term effects on the climate or the environment, i.e., refrigerants may not be PFAS. CARB should adopt regulations to this effect by 2025. The legislation would include milestones to be reached in different sectors in consecutive years.
  • Make California’s definition of PFAS the same as the definition adopted by the intergovernmental Organization for Economic Co-operation and Development (OECD) published in 2021. [êffectera]
  • Create a CPUC pilot in CalEnviroScreen communities to help transition independent supermarkets to natural refrigerants using Avoided Refrigerant Calculator-based benefits.
  • Bring California’s refrigerant safety standards in line with internationally approved standards, as with the International Electrotechnical Commission’s IEC 60335-2-40. Requirement that these standards be acceptable for building codes.
  • Require extended producer responsibility (EPR). Such a law might be used for HFC-134a in MVAC systems and for equipment that typically has refrigerants that are vented rather than reclaimed. CalRecycle has extensive EPR programs and a checklist for proposing new ones. Also see budget proposal on EPR below.
  • Legislation or regulations must establish standards for ultra-low-GWP refrigerants, and give priority to refrigerants that do not use F-gases. Include the goal of eliminating most HFCs by 2030.
  • Require vending machines and convenience stores to transition to natural refrigerants.
  • Require all HFC-134a to be reclaimed and to include in the R4 reclamation requirements all HFCs of over 150GWP.
  • Change the definition for when major repairs of an existing refrigeration system make the system subject to the regulations that apply to new refrigerant systems.
  • Require CARB to include non-HFC refrigerants, foam-blowing agents, propellants, termite fumigants, etc. in its assessment—as these are part of the existing banks of high-GWP gases that will be emitted over the coming decades and continue to make a large collective contribution to the overall carbon footprint of F-gases. These gases include CFC, HCFC, PFC, NF3, SF6, and SO2F2, many of which are already part of CARB’s emission inventory, reporting requirements, and regulatory programs. Like HFC, however, they were not addressed in the 2022 Scoping Plan Update.
  • CARB collects a wealth of F-gas sales, equipment sales, and commercial refrigerant leakage data each year, and has access to atmospheric measurements of all major F-gases from the NOAA monitoring network and its own monitoring program, but this data is neither shared publicly nor analyzed on a consistent basis. Legislation should require more frequent (and public) tracking of overall progress toward the 2030 HFC reduction target using this data. Comparison with CARB’s emission inventory projections could help identify areas of success, remaining challenges, and mitigation opportunities for both the overall F-gas mitigation program and individual sectors and gases.
  • Require CARB to identify and address individual high emissions sources of F-gases, using data from the non-profit Federally Funded Research and Development Center (FFRDC) Aerospace Corporation in El Segundo, CA. The Center has demonstrated rapid detection of F-gas high-emitters in airborne surveys over Los Angeles, San Francisco, and New York City using longwave-infrared hyperspectral imaging (LWIR-HSI) sensor systems.
  • Amend CARB’s Refrigerant Management Program (RMP) to include air-conditioning (AC) and heat pump (HP) systems. Even though the South Coast Air Quality Management District has an RMP-like rule for AC systems, we believe it is important to have statewide rule apply to the AC/HP systems (as is now being proposed by the state of Washington).


  • Align funding for HFC mitigation efforts (which have historically received less than 0.001 percent of the state’s climate mitigation budget) with their climate impacts (5 percent using 100-year GWPs, nearly 10 percent using 20-year GWPs).
  • Continue to provide financial incentives for transitions to natural refrigerant systems in existing facilities and include technical support to help the facilities that lack knowledge and experience of working with natural refrigerants. Incentive programs should use multiple criteria such as “to qualify for CARB’s incentives, refrigerant alternatives must meet the following criteria: “zero Ozone Depletion Potential, < 10 GWP, and not considered PFAS under the OECD definition.” No project in which refrigerants exceed 10GWP should be incentivized.
  • Support CalRecycle in administering an extended producer responsibility (EPR) program for all F-gases with a GWP of 150 or higher. The EPR program would cover producers, distributors, and service technicians. By charging a fee to the producers and distributors, the programs can provide a bounty to incentivize service technicians to recover and return refrigerant to the distributor, who in turn receives rebates or incentives to ensure reclamation or destruction. The fee structure could include eco-benefits such that a price of CO2e is fixed to the sale or distribution of bulk refrigerant (i.e. volume of refrigerant X GWP). To incentivize the collection of all fluorinated gases, bounties paid to technicians would be based only on the total volume returned to the distributor. In contrast to current operations, no fee could be charged to the technician for returning the refrigerant. [EIA]
  • Fund incentives to increase sales of propane heat pumps that heat or cool water rather than air ducts.
  • Fund incentives directed toward adopting natural refrigerants.
  • Fund research on safety on natural refrigerant EV MVAC systems, perhaps with Tesla or other industry partners.
  • Fund widespread initiatives to increase the number and skills (related to heat pumps and natural refrigerants) of HVAC technicians. An example is the newly formed Cal Fleet Advisor which is a free technical assistance program available to owners and operators of medium- and heavy-duty vehicles and aims to provide help in transitioning to zero-emission vehicles and fleets. A similar program incentive by CARB, administered by a third party would be ideal for commercial and industrial refrigeration facilities. Require that the state work in partnership with the industry, existing training entities, and HVAC trade school and community college programs to develop and launch a state-wide training program for technicians. [NASRC] These trainings need to be available in multiple languages. [SF Department of the Environment.]
  • Fund widespread initiatives to increase the salvage and reclaiming of HFCs from the existing bank using incentives.
  • Fund a conference of HVAC/MVAC experts on what the greatest research needs are; fund multiple follow-up RFPs.
  • Fund, and include language requiring CARB to work with other relevant federal and state agencies to create a test market and associated funding window for proposals for limited pilot and demonstration projects that can be rapidly expedited, even if utilizing refrigerants that may not yet be SNAP-approved or permitted by current industry safety standards and building codes. Such a program should provide funding and grants to support pilot and demonstration projects such as window units, PTACs, mini-splits, multi- splits, ducted air conditioners, and hydronic or indirect systems employing A3 refrigerants in outside installations. [EIA]