Imports and exports of pre-charged equipment
and closed-cell foams containing fluorinated SEPA

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GHGs

United States
Environmental Protection
Agency

Subpart QQ, Mandatory Reporting of Greenhouse Gases

Under the Mandatory Reporting Rule for Additional Sources of Fluorinated Greenhouse Gases (GHGs),
importers and exporters of fluorinated GHGs contained in pre-charged equipment or closed-cell foams
(as described below) must report the quantity of each fluorinated GHG imported or exported. Importers
and exporters of these types of equipment or foams are required to collect data on their products,
calculate the fluorinated GHGs imported or exported within the equipment or foams, and follow the
speci fied procedures for quality assurance, missing data, recordkeeping, and reporting.

How Is This Source Category Defined?

This source category consists of importers and exporters of pre-charged equipment and closed-cell foams
that contain fluorinated GHGs. Importers and exporters have to report if either their total imports or their
total exports of fluorinated GHGs in equipment and foams is greater than or equal to 25,000 metric tons
of carbon dioxide equivalent per year. This threshold is the same as that for bulk imports and exports of
fluorinated GHGs in subpart 00 (Suppliers of Industrial Greenhouse Gases) of the final Mandatory
Reporting of GHGs Rule published on October 30, 2009 (74 FR 56260).

•	Pre-charged equipment is any appliance, appliance component, electrical equipment, or electrical
equipment component that is charged with a fluorinated GHG prior to sale or distribution or offer
for sale or distribution. This definition includes both equipment that contains the full charge
necessary for operation and equipment that contains a partial "holding" charge of the fluorinated
GHG.

o Appliances means any device that contains and uses a fluorinated GHG refrigerant and is
used for household or commercial purposes, such as air conditioners, motor vehicle air
conditioners, refrigerators, chillers, and freezers,
o Electrical equipment includes (but is not limited to) gas-insulated substations, circuit
breakers, other switchgear, gas-insulated lines, and power transformers.

•	Closed-cell foam is any foam product, excluding packaging foam, constructed with a closed-cell
structure and a blowing agent containing a fluorinated GHG. This definition includes (but is not
limited to) to polyurethane (PU) appliance foam, PU continuous and discontinuous panel foam,
PU one component foam, PU spray foam, extruded polystyrene (XPS) boardstock foam, and XPS
sheet foam.

What GHGs Must Be Reported?

The rule requires importers and exporters of fluorinated GHGs contained in pre-charged equipment or
closed-cell foams to report the mass of each fluorinated GHG contained in the equipment or foam that is
imported or exported during the calendar year. Fluorinated GHGs include hydrofluorocarbons (HFCs),
perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and other gases as defined by the final Mandatory
Reporting of Greenhouse Gases Rule. In general, pre-charged appliances contain HFC refrigerants (and
in some cases, HFC blowing agents in insulating closed-cell foams); pre-charged electrical equipment
contains SF6 or PFCs; and closed-cell foams contain HFC blowing agents. However, if a particular piece
of imported or exported equipment or foam contained another fluorinated GHG, the importer or exporter
are required to report that fluorinated GHG.

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How Must GHGs Be Calculated?

Importers and exporters determine the total mass of fluorinated GHG imported or exported in their
equipment or closed-cell foams as follows:

•	For each type of equipment containing a fluorinated GHG used as a refrigerant or electrical
insulator, multiply the fluorinated GHG charge per unit of equipment by the number of units of
equipment imported or exported annually.

•	For each type of equipment with closed-cell foam that contains a fluorinated GHG, multiply the
mass of fluorinated GHG in the closed-cell foam in each unit of equipment by the number of
units of equipment imported or exported annually.

•	For each type of closed-cell foam containing a fluorinated GHG that is imported or exported in
bulk, multiply the fluorinated GHG charge per cubic foot of foam by the amount of foam in cubic
feet imported or exported annually.

When Does Reporting Begin?

Facilities subject to subpart QQ must begin monitoring GHG emissions on January 1, 2011 in accordance
with the methods specified in subpart QQ. For 2012 only, the GHG report must be submitted to EPA by
September 28, 2012. This reporting deadline applies to all subparts being reported by the facility. If your
subpart QQ facility submitted a GHG annual report for reporting year 2010 under another subpart (e.g.,
subpart C for general stationary fuel combustion), then by April 2, 2012 you must notify EPA through e-
GGRT that you are not required to submit the second annual report until September 28, 2012 (the
notification deadline according to 4 CFR 98.3(b) is March 31, 2012, however, because this date falls on a
Saturday in 2012, the notification is due on the next business day).

Starting in 2013 and each year thereafter, reports must be submitted to EPA by March 31 of each year,
unless the 31st is a Saturday, Sunday, or federal holiday, in which case the reports are due on the next
business day.

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), under this rule each
importer and exporter must submit an annual report with the following information summarized at the
corporate level:

•	Total mass of each fluorinated GHG imported or exported in pre-charged equipment or closed-
cell foams.

•	For each type of pre-charged equipment, the identity of the fluorinated GHG used as a refrigerant
or electrical insulator, charge size (including holding charge, if applicable), and the number of
pieces of equipment imported or exported.

•	For closed-cell foams imported or exported inside of appliances, for each appliance type, the
identity of the fluorinated GHG contained in the foam, the quantity of fluorinated GHG contained
in the foam in each appliance, and the number of appliances imported or exported.

•	For closed-cell foams not imported or exported inside appliances, for each foam type, the identity
of the fluorinated GHG contained in the foam, the density of the fluorinated GHG in the foam,
and the quantity of foam imported or exported.

•	Dates when the pre-charged equipment or closed-cell foams were imported and exported.

•	If the identity and mass of the fluorinated GHG within the closed-cell foam is unknown, for each
foam type, the name of the foam manufacturer and certification that the importer or exporter was
unable to obtain information on the identity and mass of the fluorinated GHG.

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For More Information

This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the rule. They are not
intended to be a substitute for the rule.

Visit EPA's Web site (http://www.epa.gov/ghgreporting/index.html) for more information and
additional information sheets, or go to www.regulations.gov to access the rulemaking docket EPA-HQ-
OAR-2009-0927.

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