November 28, 2018
NAFEM members have raised questions regarding the California Air Resources Board’s (CARB) plans to enforce EPA’s original SNAP 20 & 21 rules, beginning Jan. 1, 2019.
According to CARB, enforcement is strictly on the date of manufacture, not first installation. For example, let’s say R-404A is banned in new equipment produced on or after January 1, 2019. The thousands of equipment units manufactured through Dec. 31, 2018 with R-404A are compliant. Because “new equipment” refers to the date of manufacture, all R-404A units manufactured before Jan. 1, 20109 could theoretically sit in a warehouse for 10 years, first be installed in California 10 years later, and the equipment would comply with the regulation.
CARB reports there is no “sell through” period of time mentioned, so there’s no time limit on first installation of the older equipment. In this example, if the same R-404A equipment was manufactured Jan. 1, 2019 or later, it could not be installed or used in California ever.
For more information, contact Charlie Souhrada.