"Every sector that uses HFC refrigerants will essentially have to adapt and adopt alternatives that are climate friendlier," said Alex Hillbrand, an HFC expert at the Natural Resources Defense Council. "As with other sectors, the automotive industry will be in that position as this phase-down unfolds."
But concerns are minimal, given that the auto industry already has been reducing its use of HFC refrigerants in favor of alternatives thought to have less climate impact, such as a formulation called HFO-1234yf.
"Light-duty vehicles was one of the very first HFC-using sectors to begin an aggressive transition to climate-friendly alternatives," including HFO-1234yf, Hillbrand told Automotive News.
That transition, in part, has been aided by the EPA's greenhouse gas emissions standards for vehicles — an "essential driver" in promoting the widespread adoption of the alternative refrigerants, he explained.
To help with compliance, automakers can earn optional credits for implementing technologies that reduce AC-related emissions, such as switching to a refrigerant with lower global warming potential.
"Because the AC system improvement is one of the low-cost and effective technology pathways, a lot of manufacturers are choosing this," said Zifei Yang, passenger vehicles program lead at the International Council on Clean Transportation, a nonprofit group that provides research, analysis and data to environmental regulators.
Yang said automakers are "quite on track" to having 100 percent of the vehicle fleet switched over to the HFO-1234yf refrigerant.
For the 2019 model year, more than 70 percent of new light vehicles sold in the U.S. had air-conditioning systems operating on the climate-friendly alternative, according to an EPA report issued in January.
For auto dealers and shops that purchase HFCs to service the existing fleet, Hillbrand said there's "certainly no requirement that they stop doing that" in the HFC phase-down rule.
"Presumably, that will actually never come," he said. "It's just a question of the availability and cost of HFCs as we get further into the phase-down. But for now, things should be pretty much business as usual for the servicing sector and for dealers."
In comments submitted to the EPA in July, the Alliance for Automotive Innovation — a group that represents most major automakers in the U.S. — said it "supports EPA's focus on scaling down bulk production of HFCs while still accommodating the technological and logistic challenges industries face in phasing down production and consumption in a timely manner."
The alliance had asked the agency for "sufficient allowances" if automakers were required to use the rule's HFC allowance allocation and trading program, which affects the quantity and types of bulk HFCs that can be produced and imported each year. Under the EPA's final rule, automakers are not required to participate in the allowance program if they're not producing or importing bulk HFCs.
But one thing for the industry to watch, Hillbrand said, is what type of requirements the EPA will place on automakers in additional regulation as the agency seeks to further reduce production and use of HFCs through 2036.
"There may be future regulations that directly require automakers in certain classes of vehicles to use the better alternatives, and those could be coming fairly soon on the heels of this regulation," he said. "That, certainly, is something for the auto industry to keep its eyes on."