On April 10, 2024, the U.S. Environmental Protection Agency ("EPA") filed a complaint for civil penalties against USA Wholesale, Inc. for the illegal import of hydrofluorocarbons ("HFCs"). HFCs are greenhouse gases used...more
On December 26, 2023, the U.S. Environmental Protection Agency (EPA) published an Interim final rule updating its October final rule restricting the use of some hydrofluorocarbons (HFCs), a key substance used in refrigeration...more
On October 19, 2023, the U.S. Environmental Protection Agency (EPA) published a final rule restricting the use of certain hydrofluorocarbons (HFCs) in aerosols, foams, refrigeration, air conditioning, and heat pump products...more
Key Takeaways - • What Happened: EPA proposed a new program that would impose leak detection obligations and requirements to use reclaimed hydrofluorocarbons (HFCs) for certain equipment. The proposed rule also includes...more
The agency’s two recent actions introduce enhanced restrictions on hydrofluorocarbons and provide a series of compliance dates for industry stakeholders. On October 5, 2023, the US Environmental Protection Agency (EPA)...more
Nearly one year after ratifying the Kigali Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer, the Environmental Protection Agency announced two additional actions to further this initiative under...more
REGULATORY ISSUES & UPDATES - New CFTC Enforcement on Carbon Markets Misconduct - The U.S. CFTC publishes a rare alert soliciting tips about potential manipulation in the carbon markets and announces the formation of...more
On June 20, 2023, the United States Court of Appeals for the District of Columbia Circuit, in Heating, Air Conditioning & Refrigeration Distributors Int'l v. Envtl. Prot. Agency, No. 21-1251, (D.C. Cir. June 20, 2023),...more
A new D.C. Circuit opinion addressed the limits of non-delegation doctrine, upheld the U.S. Environmental Protection Agency’s (EPA) authority to regulate HFC/HFO blends, and struck down the agency’s authority to enact...more
In December, the U.S Environmental Protection Agency (EPA) announced a proposed rule under the American Innovation and Manufacturing (AIM) Act to address the impact of hydrofluorocarbons (HFCs), which are potent greenhouse...more
Companies that import, produce, or reclaim HFCs should carefully review – and consider submitting comments on – a new rule proposed by the U.S. Environmental Protection Agency (EPA), which will determine not only the process...more
Ratification of the Kigali Amendment formally commits the U.S. to a global effort to significantly reduce production and use of HFCs and reinforces the aggressive domestic HFC phasedown begun last year by the AIM Act. ...more
As routinely covered at Regulatory Oversight, state attorneys general have assumed an ever-more prominent role in driving national regulatory policy through advocacy and enforcement activities. Underlying many of these...more
In Husch Blackwell’s September 2021 Trade Law Newsletter, you’ll learn about the following updates in international trade and supply chain law: •The Court of International Trade issued an order in the Section 301...more
The U.S. Environmental Protection Agency (EPA) published a final rule on October 5, 2021 establishing an allowance allocation and trading program for hydrofluorocarbons (HFCs). The rule implements certain key requirements...more
The United States Environmental Protection Agency (EPA) has finalized a rule intending to reduce the production and consumption of hydrofluorocarbons (HFCs) in the United States by enforcing a cap and phasedown program under...more
A group of 14 Democratic AGs led by Massachusetts AG Maura Healey sent a comment letter to the U.S. Environmental Protection Agency (“EPA”) to support to Agency’s proposed rule under the American Innovation and Manufacturing...more
EPA to Phase Down HFC Use in Early Step to Advance Biden-Harris Climate, Environmental Justice Agendas Last week, the Biden-Harris administration took action—with some bipartisan backing from Capitol Hill—to reduce the...more
On May 3, 2021, EPA announced its first major climate change rule under the Biden Administration, proposing to phase down the manufacture and import of hydrofluorocarbons (HFCs), which are potent greenhouse gases. EPA...more
On April 30, 2021, EPA Administrator Michael Regan signed the Biden EPA’s first proposed rule to address greenhouse gas emissions and climate change. The nearly 300-page proposal goes into great detail about how EPA proposes...more
Businesses are encouraged to provide input on EPA’s HFC allowance allocation process during the forthcoming public comment period. To achieve the objectives of the American Innovation and Manufacturing Act (AIM), which...more
Industries impacted by the AIM Act’s HFC phasedown must prepare to address the costs and other challenges of complying with a new and emerging regulatory framework. The American Innovation and Manufacturing Act (AIM Act)...more
On April 5, 2019, the D.C. Circuit largely struck down another regulation restricting the use of hydrofluorocarbons (HFCs) in certain products under EPA’s Significant New Alternatives Policy (SNAP). The court held that it was...more
On September 18, 2018, the U.S. Environmental Protection Agency (“EPA”) released an advance copy of a rule proposing to rescind the agency’s 2016 extension (“2016 Rule”) of certain appliance refrigerant leak repair rules to...more
Since 1994, EPA has regulated hydrofluorocarbons (HFCs), which are potent greenhouse gases, through several programs under Title VI of the Clean Air Act (CAA) governing stratospheric ozone protection. In a recent decision,...more