On December 28, the Household & Commercial Products Association (HCPA) submitted comments to the NYSDEC on their pre-proposal outline of a draft regulation to adopt the Appendix U (EPA SNAP Rule 20) and Appendix V (EPA SNAP Rule 21) of Subpart G of 40 CFR Part 82 prohibitions on the use of hydrofluorocarbons (HFCs) as substitutes for ozone-depleting substances. The regulation would prohibit specific substances for use in several applications, including the use in aerosol products.

HCPA supports the NYSDEC’s goal of reducing HFC emissions through the adoption of the EPA’s SNAP rules, which ensures consistency with California’s new statues on the topic. It is also important to note that it is critically important that the NYSDEC’s proposed draft regulation be consistent with California so that there is a level of continuity around compliance and future planning, investment, sales, and research and development decisions.

As other states look towards their own rulemaking process to reduce HFC emissions, HCPA will be supportive so long as they remain consistent with other states. Please contact Nicholas Georges, Director, Scientific & International Affairs, at ngeorges@thehcpa.org for any additional comments or questions.


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