Recycle vs Reclaim

By Steve Schaeber, MACS Technical Editor

MACS member shops (and in fact, almost every repair shop in the country that services mobile A/C systems), have been servicing those systems the right way since the 1990s. That’s when EPA (under their authority from the Clean Air Act) first required technicians to use certified recovery-only or recover/recycle equipment to recover refrigerant into a cylinder before opening a system for repairs.

Before the early 1990s, it was common practice to vent the entire refrigerant charge to the atmosphere so that the system could be opened safely. This was done because, at that time, refrigerant was thought to be environmentally benign. But research and testing showed that venting it caused damage to Earth’s protective ozone layer.

The refrigerant we used was dichlorodifluoromethane (R-12), which was replaced with tetrafluoroethane (R-134a). R-12 is bad for the ozone layer and while R-134a is not, it still has a high global warming potential (GWP). Today we use tetrafluoropropene (R-1234yf) which does not deplete the ozone layer and has a very low GWP.

Regardless, we don’t want any of these refrigerants to get out into the atmosphere. Not just because they have unintended consequences for the environment, but because they’re worth money, too! And we can successfully recycle them in the shop using an EPA Certified RRR (recover / recycle / recharge) machine.

Theoretically, these refrigerants have an indefinitely long useful life. Unless they get contaminated, they don’t (really) go bad. In fact, we can continue to recycle these refrigerants over and over again, at very low cost for the consumer, the shop and the environment. It only takes a little bit of time and electricity for an RRR machine to perform this recycling process.

This is how mobile A/C service work has been done for more than 30 years. It’s easy, cost effective and environmentally responsible.

But now there is a possibility that this process may become illegal.

At the MACS 2023 Training Event & Trade Show in Nashville earlier this year, we received an update from our friends at the US EPA. This is something they have done for MACS for decades, and we greatly appreciate the good working relationship we have shared over the years. EPA provided an overview of the AIM Act, including the Technology Transitions Proposed Rule, and their management of HFCs and substitutes (like the current HFC phasedown schedule).

But one of the AIM Act topics caught us a bit off-guard. Specifically, 42 USC 7675 Subsection h says (in brief), “A regulated substance used as a refrigerant that is recovered shall be reclaimed before the regulated substance is sold or transferred to a new owner…”.

You may be thinking, isn’t this basically what we’ve been doing this whole time? Aren’t we “reclaiming” or “recovering” or “recycling” (or whatever you want to call it) the refrigerant?

Yes, kind of. That is, until you read the AIM Act’s definition of “reclaiming”, which says (in brief), “…the reprocessing of a recovered regulated substance to at least the purity described in AHRI standard 700-2016…”.

Ok, again, what’s the big deal? Aren’t our RRR machines “reprocessing” the refrigerant? Aren’t we “purifying” the refrigerant? Isn’t that the whole point of an RRR machine, and the point of the “recycling” process? To recover the refrigerant and clean it up so it can be reused in a mobile A/C system?

Yes, but, it’s a difference (somewhat) in terminology and purity levels.

Our current fleet of RRR machines are required to meet SAE Standards (J2788 for R-134a, J2843 for R-1234yf and J3030 for combination machines), which further require the machines to “purify” the refrigerant to another SAE Standard, J2099. That’s the purity standard for recycled refrigerants. It requires recycled refrigerant to be 98% pure and have no more than 50ppm of moisture and 500ppm of high boiling point residues (oil).

What’s the difference? AHRI 700 is the virgin refrigerant standard, which requires purity of 99.5%, with no more than 10ppm of moisture and 100ppm of oil. There is also an included “purity verification” requirement, which must be performed using laboratory equipment (like a gas chromatograph). This level of purity, and the required verification procedure, simply cannot be achieved in repair shops using the current fleet of RRR equipment.

Does this matter in the real world? Functionally, we know that recycled refrigerant works just fine. And sure, “reclaimed” refrigerant will also work just as good.

So, what’s a potential outcome? If EPA requires all recovered refrigerant to be reclaimed prior to being reused (or resold), that would be a huge additional cost and inconvenience to shops (and to their supply chain). Effectively, that would require shops to recover refrigerant into a tank, which would then need to be sent off to a “certified reclamation facility” where it can be “reclaimed” to the AHRI 700 specification. Then the refrigerant could be sent back to the shop for reuse.

In the meantime, shops would use virgin (or pre-reclaimed) refrigerant to recharge the vehicle’s A/C system. So instead of recycling refrigerant on-site for a relatively low cost, shops would have to send it off to reclamation for a higher cost (and there would of course be an additional environmental cost that’s incurred for having to ship that refrigerant back and forth from a shop to the reclaim facility).

But is the squeeze worth the juice? We don’t think so. We don’t think the 1.5% difference is worth the increased cost to the consumer, and we don’t think that transporting refrigerant from a shop to a reclaimer and back to a shop again, is worth the environmental (diesel truck emissions) cost, either.

Because if this rule is put into place, that’s (legally) what’s going to be required.

We think there is language in the AIM Act that EPA can use to “carve out” refrigerant recycling for mobile A/C service. Reading § 7675 closely, we think that Congress gave EPA some wiggle room in the words they chose to write. Words like, “…where appropriate…”, “…shall consider…” and “…may coordinate…”.

Keep in mind that EPA is not “making this up” on their own. They are doing what the AIM Act (a law written by the US Congress and signed by the President of the United States) requires them to do. EPA is the implementing agency assigned by the federal government to put this new law into effect.

We can voice our opinions, however, and there is a specific time to do that (which should be later this summer). Once EPA writes their proposed rule, they will issue an NPRM (notice of proposed rulemaking), at which time a public comment period will begin, which usually lasts for 45 days.

MACS is actively participating in discussions regarding this topic with AHRI, EPA, SAE and other industry stakeholders. We would prefer it if things did not change for the mobile A/C service sector, and we think that we can provide valuable information to the agency during this rulemaking process.

If you have any questions or comments about recycle vs reclaim, please let us know! You can send an email to Steve at sschaeber@macsmobileairclimate.org and as always, stay tuned to MACS for important updates.

Thanks for reading.