Equipment Manufacturers, Importers, and Exporters Frequently Asked Questions

As the United States continues to phaseout HCFCs, equipment manufacturers, importers, and exporters will need to adapt to the changing market demand for equipment. EPA provides the following answers to frequently asked questions to help you better understand the phaseout and your responsibilities in implementing the regulations.

May I import or export equipment containing R-22 or R-142b from/to other countries?

Yes. Currently, pre-charged equipment containing HCFCs can be imported and exported and does not require specific EPA authorization (i.e., expenditure of allowances). The current provisions at 40 CFR 82.16(c) limit production and import of virgin R-22 or R-142b as of January 1, 2010. However, these provisions apply to bulk shipments only; they do not address products that contain or are manufactured with R-22 or R-142b. EPA is concerned with the environmental impacts that could result from the potential continued imports of HCFC pre-charged products after the phaseout of production and importation of bulk substances. Therefore, EPA is evaluating options for addressing these concerns.

EPA does not restrict the export of equipment containing ozone-depleting substances (ODS). However, exporters should check with the country to which they are shipping, as restrictions vary by country.

Are there labeling requirements for equipment containing R-22?

In the future, EPA will require that equipment containing or manufactured with HCFCs contain a label that warns buyers that the equipment contains a substance that is known to harm public health and the environment by destroying ozone in the upper atmosphere.

Are there any restrictions on other HCFC-containing products, such as packaging foams and pressurized containers?

Yes, under the nonessential products ban, most aerosol products, pressurized dispensers, and foam products containing or manufactured with HCFCs are banned from sale and distribution in interstate commerce in the United States. A few products are exempted by EPA regulations and in some cases also are listed as essential medical devices by the Food and Drug Administration (21 CFR 2.125(e)).

Equipment Manufacturers, Importers, and Exporters Frequently Asked Questions

Other Frequently Asked Questions About the Phaseout of HCFC-22

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