HFC-134a Technical Brief

Regulatory Technical Brief:
Federal and State Global Warming Regulations for HFC 134a

New Restrictions imposed by EPA as part of AIM Act:
The AIM Act is a Federal nationwide rule phasing out the use of global warming materials. As part of that effort, EPA is now banning the use of 134a in aerosol products as of 1/1/2025. There are excepted products that are allowed to use 134a until 1/1/2028. The list of excepted products is the same as what the states that ban 134a have allowed. There is a three year sell through for products manufactured prior to the effective dates. By 1/1/2025 all products containing 134a must state the chemical name on the label and must have a date code on the can.

The aerosol industry moved to the use of HFC-134a propellant as a non-flammable alternative to Freon 22, which was being phased out due to ozone-depleting potential. Since then, HFC-134a has been used for many applications that call for a non-flammable propellant, such as air dusters, electronic and electrical cleaners and non-flammable adhesives.

In 2016, the U.S. EPA published the Significant New Alternatives Policy (SNAP) rules that would have severely limited the use of HFC-134a to only uses it considered essential. The Federal SNAP rules were halted due to legal challenges and never became law. Since that time, several states have enacted their own rules that are similar to the EPA SNAP rule. California was the first to do so and other states have also followed suit.

Why are restrictions being imposed?

The short answer is that the Global Warming Potential (GWP) of HFC-134a is significant and there are replacement gases available that have less environmental impact. The EU has banned most uses of HFC-134a.

What is our purpose in providing this information?

This Technical Brief is intended to make sure that our customers are aware of the rules restricting the use of HFC-134a so that measures can be taken to restrict sales where necessary.

Even for products that are allowed under the exempted uses, compliance actions in some states may be required. For example, some of the states require that 134a be listed on the product Safety Data Sheet (SDS) in Section 3. The State of Washington requires that 134a be included on the product label as well as the SDS.

The states of Colorado, Delaware, Maryland and Massachusetts require an explanation of the date coding system be submitted.

Learn More: PLZ-134a-Technical-Brief-Jan2024.pdf