Q390. How do I report imports and exports of refrigerant blends that contain both HCFCs and HFCs?
A390. If you import or export a blend that contains HFCs as well as HCFCs, you may be required to report the import or export under EPA's Greenhouse Gas Reporting Rule (40 CFR Part 98) as well as under EPA's Stratospheric Protection Regulations (40 CFR Part 82). Specifically, you are required to report the HFC portion of the import or export under the Greenhouse Gas Reporting Rule if your total annual imports or exports exceed the threshold discussed below. You are required to report the HCFC portion of the import or export under the Stratospheric Protection Regulations regardless of your total annual imports or exports.
For HFCs: Under the Greenhouse Gas Reporting Rule, importers and exporters are required to annually report their bulk imports and exports of HFCs and other greenhouse gases if their total combined bulk imports of fluorinated greenhouse gases (fluorinated GHGs), nitrous oxide (N2O), and carbon dioxide (CO2) exceed 25,000 metric tons of carbon dioxide equivalents (mtCO2e) per year. They are also required to report if their total annual bulk exports of these gases exceed 25,000 metric tons of carbon dioxide equivalents (mtCO2e) per year. For blends of HFCs and HCFCs, HFCs and other fluorinated GHGs (for example, PFCs) count toward the threshold, but HCFCs do not. You can visit the following website for a tool to help you calculate the CO2-equivalents of your imports and exports of HFCs and common refrigerant blends: http://www2.epa.gov/ghgreporting/subpart-oo-suppliers-industrial-greenhouse-gases (Click the link under "Implementation Information")
For HCFCs: Under the Stratospheric Protection Regulations, importers and exporters of HCFCs must report detailed information on all HCFC imports and exports on an annual or quarterly basis. This reporting requirement applies both to pure HCFCs and to HCFCs contained in blends, regardless of the total annual imports or exports of the importer or exporter. HCFC importers are also required to comply with the other applicable provisions of EPA’s Stratospheric Protection Regulations. Special petitioning provisions apply to imports of used HCFCs.
You can find more information on EPA's stratospheric ozone protection recordkeeping and reporting regulations (which cover CFCs and HCFCs) at http://www.epa.gov/ozone/record/index.html.