Wednesday, December 26, 2012

Advocacy: R-22 Update
Submitted by Vanessa Spates on December 21, 2012
Because the EPA will not have finalized its rule pertaining to the allocation and production rights for R-22 by the end of the year, distributors should prepare for circumstances similar to those faced in the early part of 2012. Specifically, it will be illegal for producers to manufacture or import R-22 after the 1st of the year until they (suppliers) receive a "no action assurance" letter or waiver from EPA which will allow a resumption of normal business practices while the rule is being finalized.
In 2012, suppliers received the "no action assurance" letter from EPA in the third week of January with a mandated reduction in the amount of R-22 available for production or importation. Distributors should prepare for both another delay in the issuance of "no action assurance" letters by the EPA and a further reduction in the amount of R-22 which will be allocated. In 2012, approximately 55 million pounds of R-22 were allowed for production/importation in the United States and it is the recommendation of HARDI that distributors plan for another significant reduction in R-22 availability, likely to 45 million pounds nationally.

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