TECHNICAL SUPPORT DOCUMENT FOR
IMPORTS AND EXPORTS OF FLUORINATED
GREENHOUSE GASES (GHGs) IN PRE-
CHARGED EQUIPMENT AND CLOSED-CELL
FOAMS
MANDATORY REPORTING OF GREENHOUSE
GASES: ADDITIONAL SOURCES OF
FLUORINTED GREENHOUSE GASES
REVISED - SEPTEMBER 2010
Office of Air and Radiation
U.S. Environmental Protection Agency
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Subpart QQ Technical Support Document
Table of Contents
1. Source Description 3
a. T otal Inventory 5
2. Review of Existing Reporting Programs and Methodologies 6
3. Types of Products Considered 6
4. Options for Reporting Threshold 7
5. Options for Monitoring Methods 8
6. Procedures for Estimating Missing Data 9
7. Q A/QC Requirements 9
8. Options for Reporting Procedures 9
9. References 10
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Subpart QQ Technical Support Document
1. Source Description
A variety of products containing fluorinated greenhouse gases (GHGs), sulfur hexafluoride (SF6), nitrous oxide
(N20), and carbon dioxide (C02) are imported into and exported from the United States.
HFCs are used as refrigerants in a wide range of air-conditioning and refrigeration equipment. In this application,
HFCs serve as substitutes for ozone-depleting substances (ODSs), which are being phased out under the Montreal
Protocol. Because some ODSs (i.e., HCFCs) are only beginning to be phased out, the use of HFCs in equipment
such as window and residential air-conditioners is expected to grow very quickly over the next decade. Imports and
exports of pre-charged equipment may grow as well. Although the quantities of chemical contained in each unit are
small in absolute terms (i.e., a few pounds or less), they are more significant in C02-equivalent terms, ranging up to
eleven mtC02e per unit for pre-charged commercial air-conditioners. This significance is due to the high GWPs of
the HFCs.
HFCs are also used as blowing agents during the manufacture of foams. Open-cell foams are assumed to emit 100
percent of the blowing agent in the year they are manufactured, whereas closed-cell foams emit only a fraction of
their total HFC content upon manufacture. Foam products that are closed-cell and imported or exported as a
finished foam product therefore have potential to emit the blowing agent remaining in the foam after manufacture.
Closed cell foams that are imported or exported include: polyurethane (PU) rigid foam used as insulation in
domestic refrigerators and freezers; commercial refrigeration foam; PU rigid sandwich panel continuous and
discontinuous foam; extruded polystyrene (XPS) sheet foam; and XPS boardstock foam.
SF6 is used as an electrical insulator and arc-quenching gas in electrical transmission equipment, including circuit
breakers and gas-insulated substations. Again, the quantities of SF6 in each unit are often small in absolute terms
(around 14 pounds per circuit breaker), but are larger in C02-equivalent terms (around 150 mtC02e per circuit
breaker). (Discussions with manufacturers of electrical equipment indicate that one-fifth of gas-insulated
switchgear may be imported with a partial "holding" charge of about one ton of SF6, equivalent to 28,000 mtC02e.
However, the extent to which this occurs in practice is uncertain.)
Products containing N20 may also be imported into or exported from the United States. N20 is used primarily in
two major end-use applications1) as a carrier gas with oxygen to administer more potent inhalation anesthetics
and as an anesthetic in various dental and veterinary applications, and 2) as a propellant in pressure and aerosol
products, the largest application being pressure-packaged whipped cream. As such, imported or exported products
containing N20 may include pre-charged anesthetic equipment for medical applications and in aerosol cans such as
pressure-packaged whipped cream products. Other potential products precharged with N20 may include fuel
oxidizer canisters for auto applications and blowtorches containing N20 used by jewelers and others (Heydorn 1997;
EPA 2008).
Table 1-1 provides the number of refrigeration and air-conditioning (AC) units that are projected to be imported into
and exported from the United States in 2010, as well as the total mtC02e of HFC refrigerant projected to be inside
the equipment in that year. This equipment may also include closed-cell foams, which are quantified in Table 1-2.
The number of refrigeration and AC units imported or exported in 2010 was assumed to equal the number of units
imported or exported in 2006 (the most recent year for which data was available). The refrigeration and AC units
traded in 2006 were pre-charged with both HFCs and HCFCs. (HCFCs are ozone-depleting substances that are
regulated under the Montreal Protocol and are exempt from the proposed definition of fluorinated GHG.) However,
by 2010 EPA expects that all imported or exported refrigeration and AC units will be precharged with HFCs,
because many imports or exports pre-charged with HCFCs will not be permitted starting in that year.
Table 1-1: Projected 2010 Imports and Exports of Refrigeration and AC Equipment Precharged with HFCs
Product
Number of
Units Imported
(2010)a
Estimated Total
GHGs Imported
(mtC02e) (2010)
Number of
Units Exported
(2010)a
Estimated Total
GHGs Exported
(mtC02e) (2010)
Dehumidifiers
109,393
28,945
14,427
3,817
Window ACs
9,028,514
7,379,194
298,075
243,623
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Subpart QQ Technical Support Document
Product
Number of
Units Imported
(2010)a
Estimated Total
GHGs Imported
(mtC02e) (2010)
Number of
Units Exported
(2010)a
Estimated Total
GHGs Exported
(mtC02e) (2010)
Residential Unitary ACs
359,189
2,556,198
120,187
855,321
Small Commercial ACs
10,702
121,842
56,975
648,660
Packaged Terminal AC/Heat
Pumps
235,487
250,228
55,461
58,933
Ice Makers'3
27,292
90,473
22,446
74,408
Mobile ACs0
3,374,740
4,127,538
557,631
682,021
Refrigerated Appliances
9,382,646
1,762,530
1,867,901
350,885
Small Retail Food
784,281
676,016
167,250
144,162
Sources: Ward's (2010) (Mobile ACs); U.S. Census Bureau (2009) (all other equipment types)
aNumber of imports/exports in 2010 is set equal to reported imports/exports for 2006. Mobile AC data is for 2008.
bMost recent data is for 2002; 2006 estimate is estimated by applying the percentage of new units (from Vintaging Model)
supplied by imports/exports (from Census) in 2002 to the number of 2006 new units (from Vintaging Model).
cMotor vehicle import data excludes Canada and Mexico. Export data includes Canada.
Table 1-2 provides the estimated amounts of foam containing HFCs and of electrical equipment containing SF6 that
were imported into or exported from the United States in 2006, as well as the estimated total mtC02e of fluorinated
GHGs imported or exported inside these products in 2006. This table includes foams inside refrigerators.
Refrigerant contained in these products is accounted for in Table 1-1.
Table 1-2: 2006 Foam and Electrical Equipment Imports and Exports Containing Fluorinated GHGs
Product
Fluorinated
GHG(s)
Estimated
Number of
Units
Imported
(2006)
Estimated
Total GHG
Imported
(mtC02e)
(2006)
Estimated
Number of
Units
Exported
(2006)
Estimated
Total GHG
Exported
(mtC02e)
(2006)
XPS Boardstock Foam3
HFC-134a
20 MM bd-ft.
183,365
20 MM bd-ft.
183,365
XPS Sheet Foam3
HFC-152a
2 MM bd-ft.
2,011
2 MM bd-ft.
2,011
PU Rigid Foam: Domestic
Refrigeration3
HFC-245fa
36 MM bd-ft.
2,420,135
7 MM bd-ft.
484,027
Commercial Refrigeration
Foam3
HFC-245fa
5 MM bd-ft.
399,067
5 MM bd-ft.
399,067
PU Rigid Foam: Sandwich
Panels3
HFC-134fa
3 MM bd-ft.
20,708
3 MM bd-ft.
20,708
Circuit Breakers (72.5 kV
to 345 kV)b
sf6
200
30,665
1,000
153,323
Gas Insulated Substations
(GIS)
sf6
67
1,858,268
0
0
Source: Jeffs (2010) (Domestic Refrigeration); Russell (2008) (Foams); Bolin (2008) (Electrical Equipment)
aIn the absence of detailed data, exports were assumed equal to imports. This is probably not the case.
bThis product is the only size circuit breaker that is assumed to be imported or exported precharged with SF6. Larger equipment
is not imported or exported with a full charge since they are assembled on site in the field; small equipment uses insulators other
than SF6.
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Subpart QQ Technical Support Document
a. Total Inventory
The number of importers and exporters shipping products containing fluorinated GHGs varies depending on the gas
and product in question. Based on conversations with multiple industry experts, EPA estimates that eight original
equipment manufacturers are importing high voltage circuit breakers or gas insulated substations that contain a
holding charge of SF6 (i.e., estimated as a charge of about 5 psig, which translates into approximately 20-25% of
nameplate capacity). There are also 10 entities exporting high voltage circuit breakers, an upper bound estimate
based on EPA's knowledge of 10 equipment manufacturers operating in the U.S. It is estimated that there are
approximately 50 entities importing and 25 entities exporting refrigeration and AC equipment containing a
fluorinated GHG refrigerant and foam products containing a fluorinated GHG blowing agent. Entities trading pre-
charged equipment and foam products are assumed to be distinct, although the possibility for overlap exists.
Similarly, exporters are assumed to be distinct from and approximately half the number of importers (ICF 2008a).
EPA estimates that annually, approximately 17 million mtC02e of HFCs are imported in pre-charged refrigeration
and AC equipment, three million mtC02e of HFCs are imported in closed-cell foams, and two million mtC02e of
SF6 imported in pre-charged electrical equipment. EPA also estimates that there are approximately three million
mtC02e of HFCs exported in pre-charged refrigeration and AC equipment, one million mtC02e of HFCs exported in
closed-cell foams, and 150 thousand mtC02e exported in pre-charged electrical equipment.
Table 1-3 compares imports and exports of fluorinated GHGs in pre-charged equipment and foams to other U.S.
supply flows of these gases, while Table 1-4 compares imports and exports in pre-charged equipment and foams to a
bottom-up estimate of U.S. consumption of these gases from the Inventory of U.S. Greenhouse Gas Emissions and
Sinks: 1990-2006 (EPA 2008). As shown in Table 1-3 and Table 1-4, imports in pre-charged equipment and foam
are estimated to account for between seven and 10 percent of the net U.S. supply or consumption of fluorinated
GHGs, while exports in pre-charged equipment and foam are estimated to account for one to two percent of the U.S.
net supply or consumption.
Table 1-3: Imports and Exports of Pre-Charged Equipment and Foams as Share of U.S. Fluorinated GHG
Supply (Top-Down, 2006)
Supply Flow
Quantity (mtC02e)
Domestic Production
350,000,000
Imports in Bulk
110,000,000
Exports in Bulk
175,000,000
Imports in Pre-Charged Equipment, Foams
22,000,000
Exports in Pre-Charged Equipment, Foams
4,000,000
Net supply (all flows)
303,000,000
Equipment, Foam Imports as Share of Net Supply
7%
Equipment, Foam Exports as Share of Net Supply
1%
Table 1-4: Imports and Exports of Pre-Charged Equipment and Foams as Share of U.S. Fluorinated GHG
Consumption (Bottom-Up, 2006)
Consumption Component
Quantity (mtC02e)
Total U.S. Consumption (2006, US Inventory)
215,000,000
Equipment, Foam Imports as Share of Consumption
10%
Equipment, Foam Exports as Share of Consumption
2%
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Although EPA does not have data on the amount of C02 or N20 imported or exported in products (e.g., carbonated
sodas and cans of whipped cream), the relatively small quantities of C02 or N20 contained in each unit and the
relatively low GWPs of these gases (compared to those of the fluorinated GHGs) imply that the C02-equivalent
quantities imported or exported are likely to be small both nationally and per entity. This conclusion is supported by
the fact that 2006 production and bulk imports of C02 and N20 were one percent or less of those of the fluorinated
GHGs in C02-equivalent terms (see Technical Support Documents EPA-HQ-OAR-2008-0508-012 and EPA-HQ-
OAR-2008-0508-042.
2. Review of Existing Reporting Programs and Methodologies
Protocols/guidance reviewed for this analysis include the 2006IPCC Guidelines, Title VI of the Clean Air Act
(CAA), Part 75 Appendix D (measurement requirements for oil and natural gas), the Toxic Release Inventory (TRI),
the Toxic Substances Control Act (TSCA) Inventory Update Rule, and the Australian Commonwealth Government
Ozone Protection and Synthetic Greenhouse Gas Reporting Program.
These programs vary in their treatment of products containing chemicals whose bulk import or export must be
reported. The Australian program requires reporting of all ODSs and GHGs imported in pre-charged equipment,
including the type of equipment, the identity of the refrigerant, the number of pieces of equipment, and the charge
size. However, the program does not cover the export of this equipment. The TSCA Inventory Update Rule
requires reporting of chemicals contained in products if the chemical is designed to be released from the product
when it is used (e.g., ink from a pen). EPA's ozone protection regulations do not currently require reporting of
ODSs contained in imported or exported equipment or other products; however, (1) EPA has prohibited the
introduction into interstate commerce, including import, of certain non-essential products typically pre-charged with
these chemicals, and (2) EPA has prohibited the sale or distribution in interstate commerce, including import, of
equipment pre-charged with HCFCs (74 FR 66450, December 15, 2009).
For the full review of existing programs, please refer to (EPA-HQ-OAR-2008-0508-054).
3. Types of Products Considered
In determining which products should be subject to reporting, EPA believes it is appropriate to consider three
criteria: (1) the quantity of GHGs likely to be imported or exported in the product nationally and per importer or
exporter, (2) the ease with which the GHG in the product can be identified, and (3) the ease with which the GHG in
the product can be quantified.
As noted above, the C02-equivalent quantities of C02 and N20 imported or exported in products are likely to be
small both nationally and per entity due to the relatively small quantities of C02 and N20 contained in each unit and
the relatively low GWPs of these gases (compared to those of the fluorinated GHGs). EPA's review of other
protocols and guidance affecting imports and exports did not identify any programs that quantify or restrict trade of
C02 or N20 in products.
As discussed above, the quantities of fluorinated GHGs imported or exported in equipment are potentially
significant both overall and per product type. For example, EPA estimates that 7 million metric tons C02e are
imported inside pre-charged window air-conditioners. Other types of equipment that are imported or exported
containing significant quantities of fluorinated GHGs include mobile air-conditioners, refrigerated appliances,
residential air-conditioners, and gas-insulated switchgear. The identities and amounts of fluorinated GHGs
contained in equipment are generally well known; this data is typically listed on the nameplate affixed to every unit.
The information is also available in servicing manuals and other paperwork that the entity would be expected to
have on file.
Closed cell foams, such as polyurethane (PU) appliance foams (used to insulate refrigerators and freezers) and
extruded polystyrene (XPS) insulation boardstock (used to insulate buildings), also contain significant amounts of
fluorinated GHGs. Again, manufacturers and importers or exporters would generally be expected to be able to
identify and quantify the amounts in their products. (The identities and quantities of chemical inside the foam
directly affect its insulating capability.) Since many importers or exporters of refrigerators would already be
required to report based on the refrigerant contents of the equipment, the additional effort required to track and
quantify the GHGs contained in the foam would probably not be excessively burdensome.
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4. Options for Reporting Threshold
EPA evaluated a range of threshold options for imports or exports of fluorinated GHGs in products, including
thresholds based on the quantity of chemical imported or exported (1,000; 10,000; 25,000; and 100,000 mtC02e)
and on the number of pieces of equipment or volume of foam imported or exported. Additionally, EPA considered
setting no threshold (requiring reporting of all imports or exports), which is the approach used under the Australian
Synthetic Greenhouse Gas Reporting Program.
Table 4-1 and Table 4-2 present the total masses of HFCs and SF6, in mtC02e, that EPA estimates are contained in
imported and exported pre-charged equipment, both nationally and by entity. The amount of total gas imported or
exported was estimated by summing the product of the average charge size (as detailed below) and the quantity of
imports or exports (as detailed in Table 1-3 and Table 1-4) for each equipment type. Where products include foam
as well as refrigerant (e.g., household refrigerators), the fluorinated GHG in the foam was also included in the
closed-cell foam category. Information on the number of entities was obtained from ICF (2008a) for HFC
equipment and from Phil Bolin (2008) for SF6 equipment. In the absence of entity-specific data, the analysis below
assumes that each entity imports or exports the same quantity of HFC or SF6 equipment.
In order to calculate an average C02-equivalent charge size for each equipment type, data on gas-specific charge
sizes were first collected from three separate sources, depending on the equipment type. For refrigeration and AC
equipment, charge size estimates were taken from EPA's Vintaging Model (VM) (EPA 2008). The average HFC
density of each foam type was estimated based on engineering judgment (ICF 2008b). For SF6-containg equipment
(i.e., circuit breakers and gas insulated substations), the average charge size was calculated using the assumption
provided by Phil Bolin (2008) that the average shipping charge is 20 percent of the equipment's total nameplate
capacity. These data were then weighted by the percentage of new units in 2010 using the relevant gas, as estimated
by EPA's VM, for each equipment type. Finally, the charge sizes were converted in mtC02e using SAR GWPs and
summed to develop an average C02-equivalent charge size for each equipment type. The numbers of pieces of
equipment to trigger reporting at various thresholds is simply the threshold divided by this calculated average charge
size.
EPA believes that a threshold based on the total quantity of chemical imported or exported is likely to be more
practical and equitable than one based on the number of pieces of equipment or volume of foam imported or
exported. This conclusion is based on the fact that entities may import or export multiple types of equipment and/or
foam, which may contain different quantities of refrigerant and/or blowing agent per unit. If a threshold based on
numbers of pieces of equipment were established, it could exclude entities that imported or exported large quantities
of GHGs spread out among multiple types of equipment. Alternatively, it could require a complicated formula to
prevent such exclusions.
Based on the assumptions outlined above, all importers or exporters of equipment pre-charged with HFCs or SF6
would be required to report all imports or exports of this equipment under all thresholds considered. In reality,
imports or exports are likely to be concentrated among a relatively small number of entities, decreasing the number
of reporters and the amount reported. This is the pattern that EPA has seen for bulk imports of fluorinated GHGs,
where approximately 40 percent of the importers import almost 100 percent of the imports at an import threshold of
25,000 mtC02e (Technical Support Document EPA-HQ-OAR-2008-0508-042). In general, as thresholds decrease,
smaller entities representing successively smaller shares of total national imports or exports are required to report.
The drawback of requiring reporting of all imports or exports (i.e., setting no threshold) is that it could substantially
increase the burden of the rule without substantially increasing the quantity of imports or exports reported.
Table 4-1: Import Threshold Summary: Masses of GHGs that would be covered by the Various Thresholds
Product Type
Imports
(mtC02e)
Number of
Importers
GHG per
Importer
(mtC02e)
Total Amount Meeting Threshold (mtC02e)
1,000
10,000
25,000
100,000
Pre-charged Equipment
HFC
Refrigeration / AC
Equipment
16,992,965
50
339,859
16,992,965
16,992,965
16,992,965
16,992,965
SF6 Electrical
Equipment
1,888,932
8
236,117
1,888,932
1,888,932
1,888,932
1,888,932
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Product Type
Imports
(mtC02e)
Number of
Importers
GHG per
Importer
(mtC02e)
Total Amount Meeting Threshold (mtC02e)
1,000
10,000
25,000
100,000
Closed-cell Foams
3,025,285
50
60,506
3,025,285
3,025,285
3,025,285
Table 4-2: Export Threshold Summary: Masses of GHGs that would be covered by the Various Thresholds
Product Type
Exports
(mtC02e)
Number of
Exporters
GHG per
Exporter
(mtC02e)
Total Amount Meeting Threshold
(mtC02e)
1,000 10,000 25,000 100,000
Pre-charged Equipment
HFC Refrigeration /
AC Equipment
3,061,830
25
122,473
3,061,830
3,061,830
3,061,830
3,061,830
SF6 Electrical
Equipment
153,323
10a
Variesb
153,323
107,326
0
0
Closed-cell Foams
1,089,177
25
43,657
1,089,177
1,089,177
1,089,177
0
includes five importers that also export.
bBased on data from Rich York (2008), five manufacturers are assumed to account for a majority of the exports.
5. Options for Monitoring Methods
Options for tracking imports and exports of products include reporting the total amount of each fluorinated GHG
imported or exported inside the products and/or the quantity of the product imported or exported (e.g., number of
pieces of equipment), along with information on the identity and quantity of the fluorinated GHG in each unit or
piece. EPA has reviewed existing reporting programs and methodologies that take one or both of these approaches,
as described above.
The quantities of fluorinated GHGs contained in imported or exported products could be reported by chemical in
tons or in mtC02e. Reporting in tons of chemical would provide more transparency and reduce mistakes such as
arithmetic errors or the use of inappropriate GWPs. Entities importing equipment that contained both a fluorinated
GHG refrigerant and a foam blown with a fluorinated GHG (e.g., household refrigerators) could separately report
these GHGs (which are generally different). Similarly, total exports of chemical actually contained in exported
equipment, foams, or other products could be reported by exporters, by chemical in tons or mtC02e.
The equation below could be used to estimate each entity's imports or exports of each fluorinated GHG inside
equipment or foams:
i = Zs,*Nt*o.ooi
t
where,
I is the total amount of the fluorinated GHG imported or exported by the entity annually (metric tons)
t is the type of equipment/foam containing the fluorinated GHG
St is the shipping charge per unit of equipment or foam type t
Nt is the number of units of equipment or foam type t imported or exported annually
0.001 is the factor converting kg to metric tons
As is the case for bulk imports, any trans-shipments (i.e., products containing GHGs that originate in a foreign
country and enter the United States en route to an ultimate destination in another foreign country) could be exempt
from reporting. Similarly, entities could report their imports or exports on the corporate level.
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6. Procedures for Estimating Missing Data
A complete record of all measured parameters used in the GHG emissions calculations would be required; no data
should be missing as the data are required for importing and exporting in the United States.
7. QA/QC Requirements
Options for QA/QC requirements includes reviewing inputs to the annual submission against the import and export
transaction records to ensure that the information submitted to EPA is being accurately transcribed as the correct
chemical or blend in the correct units and quantities (metric tons).
8. Options for Reporting Procedures
Along with their formal report, entities could be required to submit the following supplemental data to document
and verify their import or export estimates:
Quantities of products imported or exported, in appropriate units;
The name of the fluorinated GHG, charge size (holding charge, if applicable), and number imported or
exported for each type of equipment; and
The name of the fluorinated GHG, and the quantity imported or exported (cu. ft and kg/ft2 or tons) for each
type of foam.
Importers could be required to keep the following records to document and verify their import estimates:
The information reported (as indicated above);
The port of entry through which the fluorinated GHGs passed;
The country from which the imported fluorinated GHGs were imported;
The importer number for the shipment;
A copy of the bill of lading for the import;
The invoice for the import; and
The U.S. Customs entry form.
Along with their formal report, exporters could be required to submit the following supplemental data to document
and verify their export estimates:
Quantities of products exported, in appropriate units;
The name of the fluorinated GHG, charge size (holding charge, if applicable), and number exported for
each type of equipment; and
The name of the fluorinated GHG, and the quantity exported (cu. Ft and kg/ft2 or tons) for each type of
foam.
Exporters could be required to keep the following records to document and verify their export estimates:
The information reported above;
The names and addresses of the exporter and the recipient of the exports;
The exporter's Employee Identification Number;
The date on which, and the port from which, the products containing the fluorinated GHGs were exported
from the United States or its territories;
The country to which the products containing the fluorinated GHGs were exported; and
The invoice for the export.
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Persons who transship products containing fluorinated GHGs could be required to maintain records that indicated
that the products originated in a foreign country and was destined for another foreign country and did not enter into
commerce in the United States.
9. References
Bolin, Phil (2008) Personal Communication between Phil Bolin of Mitsubishi and Paul Stewart of ICF
International, June 24, 2008.
EPA (2008) "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006". Available online at
.
Heydorn, B. (1997) "Nitrous OxideNorth America." Chemical Economics Handbook, SRI Consulting. May 1997.
ICF (2008a) Potential Importers and Exporters of Pre-Charged Refrigeration and Air Conditioning Equipment
Memorandum, June 18, 2008.
ICF (2008b) Personal Communication between Robert Russell of RJR Consulting and Marian Van Pelt of ICF
International, June 13, 2008.
Jeffs, Mike (2010) Personal Communication between Mike Jeffs of ISOPA and Caroline Cochran of ICF
International, June 14, 2010.
Russell, Robert (2008) Personal Communication between Robert Russell of RJR Consulting and Marian Van Pelt of
ICF International, April 23, 2008.
U.S. Census Bureau (2009) U.S. International Trade Commission (USITC) Data Web. Available at
. Year 2006 data Accessed October 2009.
Ward's (2010) Ward's AutoInfoBank.
York, Rich (2008) Personal Communication between Rich York of ABB and Paul Stewart of ICF International, June
24, 2008.
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