In December 2024, the New York Department of Environmental Conservation (DEC) completed one of the actions it was assigned under New York’s Climate Law when it published updates to Part 494, regulations for refrigerants. Unfortunately, the DEC did little to publicize and educate the stakeholders about this important and positive work. The essay below undertakes explaining what all is involved and why it is so important.  

Highly potent greenhouse gases

The synthetic chemicals we use as refrigerants are extraordinarily powerful greenhouse gases—many of them thousands of times more powerful at trapping heat in our atmosphere than carbon dioxide. Most of the existing refrigerants in use today are hydrofluorocarbons (HFCs), and in New York State, HFCs account for 6 percent of our gross greenhouse gas emissions, a percentage that is growing. 

Unlike fossil fuels, HFCs are not as problematic as greenhouse gases while they are being used in functioning equipment; they become problematic only when they escape to the atmosphere—either due to accidental leaks, intentional (illegal) venting during servicing, or at the end of the equipment’s working life. 

Improved refrigerant management—curtailing leakage, replacing high Global Warming Potential (GWP) refrigerants with climate-friendlier alternatives and diligently recovering refrigerants at end of life—are essential actions to successful climate change mitigation.

In broad strokes, Part 494 implements four main measures:

1. Technology transition requirements

As of January, manufacturers can no longer use the refrigerant R410A in new air conditioners. Both a federal EPA regulation and now a Part 494 regulation in New York, this example illustrates a technology transition that moves us from a high GWP technology to a lower GWP technology. Part 494 has other rules, similar to this one, that apply to nine subsectors of air conditioning equipment and 22 subsectors of refrigeration equipment. 

Many of the rules adopted in Part 494 act as a backstop to federal regulations. Manufacturers understand that even if federal lawmakers and regulators waver on these rules, the states of New York, California, Washington and others will still implement them. This backstop function helps reduce uncertainty for manufacturers and will contribute to positive environmental outcomes for the rest of us.

Part 494 also adopted some rules that go beyond federal requirements, mostly requiring the future adoption of technologies that are currently in widespread use throughout Europe and other developed countries, yet still not approved for use here.

2. Prohibitions on bulk refrigerants 

Part 494 also adopted regulations that do not allow the use of brand new refrigerants; rather, they require reclaimed refrigerants to be used. These rules follow the example California has set, and they incentivize reclaimers to develop their reclamation capacity and will help to increase end-of-life refrigerant recovery.

3. Refrigerant Management Program

This program requires large users of refrigerant not just to keep records about their refrigerant use and alert authorities when something goes wrong; they now need to regularly report their refrigerant use and confirm ongoing monitoring.Think of a full-size grocery store that uses refrigerant R404A in its rack system. This chemical has a 20-year GWP that is 7,208 times greater than CO2. When a single pound of R404A leaks from equipment, its impact on climate instability over a 20-year horizon is about the same as that of burning 368 gallons of gasoline. Large systems can hold 2,000 pounds or more of R404A and have a tendency to leak refrigerants because of the complexity of the systems. There is a huge public benefit to making sure those chemicals are being properly handled, as well as a financial benefit to the companies from reducing leaks of very expensive refrigerants. The new refrigerant management program requires companies to adopt best practices that will reduce leaks and benefit everyone. 

4. Supermarket Refrigerant Program

 This program, which only applies to large chain stores, requires them to invest in natural refrigerant systems when their legacy refrigeration systems are upgraded. These systems typically have a higher upfront cost, yet a lower overall cost of ownership. There is friction with industry from this requirement, but by moving beyond the status quo, store owners will have lower energy costs, reduced refrigerant expenses, and huge reductions of greenhouse gas emissions.

The bottom line

The finalized Part 494 update that NYSDEC announced in December 2024 incorporates sound refrigerant management practices into state law. The new rules implement recommendations from the Climate Action Council Scoping Plan, establishing clear responsibilities for refrigerant producers, equipment manufacturers and end users to play their roles in helping achieve New York’s climate goals. It is vitally important for stakeholders—including New York State agencies, the governor and legislature, and citizens supporting climate action—to actively support the successful implementation of the new Part 494 standards.