TECHNICAL SUPPORT DOCUMENT FOR
IMPORTS OF FLUORINATED GREENHOUSE
GASES (GHGs), N20, AND C02 IN PRODUCTS:
PROPOSED RULE FOR MANDATORY
REPORTING OF GREENHOUSE GASES
Office of Air and Radiation
U.S. Environmental Protection Agency
February 4, 2009
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Contents
1. Source Description 3
a. T otal Inventory 4
2. Review of Existing Reporting Programs and Methodologies 5
3. Types of Products Considered 5
4. Options for Reporting Threshold 5
5. Options for Monitoring Methods 8
6. Procedures for Estimating Missing Data 8
7. QA/QC Requirements 8
8. Options for Reporting Procedures 8
9. References 9
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1. Source Description
A variety of products containing fluorinated greenhouse gases (GHGs), sulfur hexafluoride (SF6), nitrous oxide
(N20), and C02 are imported into the United States. In particular, HFCs and SF6 are used in numerous products,
several of which are imported containing the fluorinated GHG. Table 1 provides the number of refrigeration and air-
conditioning (AC) units that are projected to be imported into the United States in 2010, as well as the total mtC02e
of HFCs projected to be imported inside the equipment in that year. The number of refrigeration and AC units
imported in 2010 was assumed to equal the number of units imported in 2006. The refrigeration and AC units
imported 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 refrigeration and AC units will be charged with HFCs, because imports pre-
charged with HCFCs will not be permitted starting in that year.
Table 1. Projected 2010 Imports of Refrigeration and AC Pre-Charged with HFCs
Product
Number of Units
Estimated Total
Imported (2010)a
GHGs Imported
(mtC02e) (2010)
Dehumidifiers
109,393
28,945
Window ACs
9,028,514
7,379,194
Residential Unitary ACs
359,189
2,556,198
Small Commercial ACs
10,702
121,842
Packaged Terminal AC/Heat Pumps
235,487
250,228
Ice Makers'3
27,292
90,473
Mobile ACs0
2,187,000
2,674,851
Refrigerated Appliances
9,382,646
1,762,530
Small Retail Food
784,281
676,016
Sources: U.S. Department of Transportation (2007) (Mobile ACs)
U.S. Census Bureau (2007) (all other equipment types)
a Number of imports in 2010 is set equal to reported imports for 2006.
bMost recent import data is for 2002; 2006 estimate is estimated by applying the percentage of new units (from
Vintaging Model) supplied by imports (from Census) in 2002 to the number of 2006 new units (from Vintaging
Model).
c Most recent import data available is for 2005; estimate representative of 2005. Motor vehicle import data excludes
imports from Canada and Mexico.
Table 2 provides the estimated amounts of foam containing HFCs and of electrical equipment containing SF6 that
were imported into the United States in 2006, as well as the estimated total mtC02e of fluorinated GHGs imported
inside these products in 2006.
Table 2. 2006 Foam and Electrical Equipment Imports Containing Fluorinated GHGs
Product
Fluorinated
Estimated Number of
Estimated Total
GHG(s)
Units Imported
(2006)
GHG Imported
(mtC02e) (2006)
XPS Boardstock Foam
HFC-134a
20 MM bd-ft.
183,365
XPS Sheet Foam
HFC-152a
2 MM bd-ft.
2,011
PU Rigid Foam: Domestic
HFC-245fa
36 MM bd-ft.
2,420,135
Refrigeration
Commercial Refrigeration Foam
HFC-245fa
5 MM bd-ft.
399,067
PU Rigid Foam: Sandwich Panels
HFC-134fa
3 MM bd-ft.
20,708
Circuit Breakers (72.5 kV to 345 kV)a
sf6
200
30,665
Gas Insulated Substations (GIS)
sf6
67
1,858,268
Source: Russell (2008) (Foams)
Bolin (2008) (Electrical Equipment)
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a This is the only size circuit breaker that is assumed to be imported precharged with SF6. Larger equipment is not imported
with a nominal charge since they are assembled on site in the field; small equipment uses insulators other than SF6.
As shown in Table 1, HFCs are used as refrigerants in a wide range of AC 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 of pre-charged equipment may grow as well. Although the quantities of chemical contained in each
imported 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. (Table 3 below shows the
C02-equivalent charge size for various types of equipment.) This is due to the high GWPs of the HFCs.
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 some fraction of gas-insulated
switchgear may be imported with a holding charge of about one ton of SF6, equivalent to 28,000 mtC02e.
However, the extent to which this occurs in practice is uncertain.)
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 celled and imported as a finished foam
product therefore have potential to emit the blowing agent remaining in the foam after manufacture and import.
Closed cell foams that are imported 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.
Products containing N20 may also be imported into the United States. N20 is used primarily in two major end-use
applications—1) 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 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 imported products containing N20 may include fuel oxidizer canisters for auto
applications and blowtorches containing N20 used by jewelers and others (Heydorn 1997; EPA 2008).
a. Total Inventory
The number of importers importing products containing fluorinated GHGs varies depending on the gas and product
in question. EPA estimates that eight original equipment manufacturers are importing high voltage circuit breakers
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). It is estimated that approximately 50 entities are importing AC and refrigeration
equipment containing a fluorinated GHG refrigerant and foam products containing a fluorinated GHG blowing
agent. However, these products are commonly imported and the number of importers could be higher.
EPA estimates that annually, approximately 16 million mtC02e of HFCs are imported in pre-charged AC and
refrigeration equipment, three million mtC02e of SF6 are imported in pre-charged electrical equipment, and 2.6
mtC02e of HFCs are imported in closed-cell foams. Together, these imports are estimated to constitute between
five and ten percent of U.S. consumption of fluorinated GHGs. The United States reported consumption of 215
MMTC02e of HFCs, PFCs, and SF6 in 2006 (EPA, 2008).
Although EPA does not have data on the amount of C02 or N20 imported 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 are likely to be small both nationally and per importer. 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.
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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 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. 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 equipment or other imported products; however, (1) EPA
has prohibited the introduction into interstate commerce, including import, of certain non-essential products
typically precharged with these chemicals, and (2) EPA is in the process of proposing new regulations to prohibit
import of equipment precharged with HCFCs.
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 in the product nationally and per importer, (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 in products are likely to be small both
nationally and per importer 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 did not identify any programs that quantify or restrict imports of C02 or N20 in
products.
As discussed above, the quantities of fluorinated GHGs imported 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 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 importer 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 would generally be expected to be able to identify and
quantify the amounts in their imports. (The identities and quantities of chemical inside the foam directly affect its
insulating capability.) Since many importers 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.
4. Options for Reporting Threshold
EPA evaluated a range of threshold options for imports of fluorinated GHGs in products, including thresholds based
on the quantity of chemical imported (1,000, 10,000, 25,000, and 100,000 mtC02e) and on the number of pieces of
equipment imported and/or volume of foam imported (cu ft. or tons). Additionally, EPA considered setting no
threshold (requiring reporting of all imports), which is the approach used under the Australian Synthetic Greenhouse
Gas Reporting Program.
Table 3 presents the numbers of pieces of equipment that would trigger reporting at various thresholds, assuming
that equipment was shipped with the usual shipping charge (either holding charge or full charge). 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,
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charge size estimates were taken from EPA's Vintaging Model (VM) (EPA 2008). The average charge size 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 is likely to be more practical and
equitable than one based on the number of pieces of equipment or volume of foam imported. This is because
importers may import 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 importers who imported large quantities of GHGs spread out among multiple types of equipment.
Alternatively, it could require a complicated formula to prevent such exclusions.
Table 4 presents the total masses of HFCs and SF6, in mtC02e, that EPA estimates are contained in imported pre-
charged equipment, both nationally and by importer. The amount of total gas imported was estimated by summing
the product of the average charge size (as detailed above) and the quantity of imports (as detailed in Table 1 and 2)
for each equipment type. Where imported products include foam as well as refrigerant (e.g., household
refrigerators), the fluorinated GHG in the foam was also included. Information on the number of importers was
obtained from ICF (2008a) for HFC equipment and from Phil Bolin (2008) for SF6 equipment. In the absence of
importer-specific data, the analysis below assumes that each importer imports the same quantity of HFC or SF6
equipment. In addition, Table 3 presents the masses of GHGs contained in imported equipment that would be
included under each threshold.
Based on the assumptions outlined above, all importers of equipment pre-charged with HFCs or SF6 would be
required to report all imports of this equipment under all thresholds considered. In reality, imports are likely to be
concentrated among a relatively small number of equipment importers, decreasing the number of reporters and the
imports 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
importers representing successively smaller shares of total national imports are required to report. The drawback of
requiring reporting of all imports (i.e., setting no threshold) is that it could substantially increase the burden of the
rule without substantially increasing the quantity of imports reported.
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Table 3. Equipment Import Threshold Summary: Quantities of Equipment Required to Meet Thresholds (Based on Average Charge Size)
Equipment
Dehumidifiers
Window ACs
Residential
Unitary ACs
Small
Commercial ACs
Packaged
Terminal
AC/Heat Pumps
Ice Makers
Mobile ACs
Refrigerated
Appliances
Small Retail Food
PU Rigid
Sandwich Panels
Commercial
Refrigeration
PU Rigid
(Domestic
Refrigeration)
XPS Sheet
XPS Boardstock
Circuit Breakers
(34 kV to 72.5
kV)
Gas Insulated
Substations (GIS)
Average
Charge Size
(mtC02e)
0.3
0.8
7.1
11.4
1.1
3.3
1.2
0.2
0.9
0.1a
1.0a
0.8a
0.01a
0.1a
153.3
27874
1,000
3,779
1,224
141
88
941
302
818
5,323
1,160
12,073
1,044
1,240
82,881
9,089
7
10,000
37,793
12,235
1,405
878
9,411
3,017
8,176
53,234
11,602
120,727
10,441
12,396
828,805
90,894
65
25,000
94,483
30,588
3,513
2,196
23,527
7,541
20,440
133,085
29,004
301,818
26,103
30,990
2,072,013
227,234
163
100,000
377,931
122,351
14,052
8,783
94,109
30,166
81,762
532,340
116,015
1,207,271
104,410
123,960
8,288,053
908,935
652
a Average charge for closed-cell foam products is provided in cubic feet.
Table 4. Equipment Import Threshold Summary: Masses of GHGs that Would be covered by the Various Thresholds
Equipment Type
Imports
(mtC02e)
Number of
Importers
GHG per
Importer
(mtC02e)
Total Amount Meetin
g Threshold (mtC02e)
1,000
10,000
25,000
100,000
All HFC Equipmenta
18,359,480
50
367,190
18,359,480
18,359,480
18,359,480
18,359,480
All SF„ Equipment
1,888,932
8
236,116
1,888,932
1,888,932
1,888,932
1,888,932
a Includes precharged refrigeration and AC equipment, and foams used in refrigeration equipment (commercial refrigeration foam and PU Rigid Domestic Refrigeration foam).
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5. Options for Monitoring Methods
Options for tracking imports and exports of products include reporting the total amount of each fluorinated GHG
imported inside the products and/or the quantity of the product imported (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 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. Persons 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 importer's imports of each fluorinated GHG inside equipment or
foams:
I = ^St *Nt *0.001
Where:
I = Total amount of the fluorinated GHG imported by the importer annually (metric tons)
t = Type of equipment/foam containing the fluorinated GHG
St = Shipping charge per unit of equipment or foam type t
Nt = Number of units of equipment or foam type t imported annually
0.001 = 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, importers of products containing fluorinated GHGs could report their imports on the
corporate level.
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, importers could be required to submit the following supplemental data to document
and verify their import estimates:
• Quantities of products imported, in appropriate units;
• The name of the fluorinated GHG, charge size (holding charge, if applicable), and number imported for
each type of equipment; and
• The name of the fluorinated GHG, and the quantity imported (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:
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• 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 imported for
each type of equipment; and
• The name of the fluorinated GHG, and the quantity imported (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 fdentification 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.
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
Phil Bolin (2008). Personal Communication between Phil Bolin of Mitsubishi and Paul Stewart of 1CF
International, June 24, 2008.
Heydorn, B. (1997) "Nitrous Oxide—North America." Chemical Economics Handbook, SRI Consulting. May 1997.
EPA (2008) "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006".
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.
Robert Russell (2008) Personal Communication between Robert Russell of RJR Consulting and Marian Van Pelt of
ICF International, April 23, 2008.
U.S. Census Bureau (2007) U.S. International Trade Commission (USITC) Data Web. Available at
. Accessed November 2007.
U.S. Department of Transportation (2007) National Transportation Statistics, 2007. Bureau of Transportation
Statistics. Available at:
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