In 2025, the Heating, Air-conditioning & Refrigeration Distributors International (HARDI) successfully opposed legislative efforts across all 50 U.S. states aimed at prohibiting the use of per- and polyfluoroalkyl substances (PFAS) in the HVACR industry. Through advocacy campaigns and industry mobilization, all proposed PFAS bans were either defeated or amended to exempt HVACR products.
One of the most notable legislative challenges was California Senate Bill 682 (SB682), which originally sought to ban PFAS in HVACR systems and refrigerants by 2040. Since many refrigerants fall under California’s broad PFAS definition, this would have severely restricted options to only industrial refrigerants like CO₂, propane, and ammonia. Due to industry resistance, including 216 comments submitted via HARDI’s grassroots campaign, HVACR was removed from the bill. Similar exemptions were secured in states like New Mexico.
HARDI maintains that refrigerants used in HVACR do not exhibit characteristics typically associated with hazardous PFAS—such as bioaccumulation, long-term toxicity, or environmental persistence—and therefore should not be subject to the same regulations.
The organization is monitoring a new wave of potential PFAS policy activity expected in 2026, particularly in California, Connecticut, Hawaii, Maryland, Massachusetts, New Jersey, New York, Oregon, Vermont, and Washington. HARDI is also tracking regulatory developments in the European Union, which influence U.S. policy. Notably, the European Chemicals Agency (ECHA) has proposed PFAS restrictions that specifically exempt HVACR applications until alternatives are legally and practically viable.
Despite these exemptions, environmental groups like ATMOsphere are promoting updates to building codes to permit the use of A3 refrigerants—such as propane—in more applications. In 2024, the first such proposal appeared in Washington State’s mechanical code cycle.
According to HARDI, the PFAS regulatory push is being used to accelerate a shift toward ultra-low global warming potential (GWP) refrigerants, circumventing existing safety and feasibility concerns. The organization argues that this approach is not driven by HVACR-specific environmental risks, but rather by broader climate policy objectives.
HARDI continues to oppose mandatory transitions to ultra-low GWP refrigerants and is currently involved in a lawsuit against New York over its planned 2027 phase-down mandate. The group urges industry stakeholders to engage in advocacy efforts and respond to grassroots calls for public comment.
