Co-Authored by: Drew Kennedy and Bryan Lord


As environmental concerns continue to shape industries worldwide, the use and regulation of refrigerants have come under increasing scrutiny. In Canada, recent and upcoming regulatory changes are set to transform industries that use refrigerants, including the built environment.   Past regulations have focused on the protection of the ozone layer, new regulations focus on mitigating global warming and reducing greenhouse gas emissions. In this blog post, we’ll explore what refrigerants are, their environmental impacts, and the significant regulatory milestones that have shaped their use. We’ll also delve into the future of refrigerant regulations in Canada, outlining the upcoming changes and what they mean for industries and building owners. 


What are Refrigerants? 

Refrigerants are substances used in various cooling and heating applications, such as air conditioning, refrigeration, and heat pumps. These chemicals absorb heat at low temperatures and release it at higher temperatures, making them crucial for temperature regulation.  

Refrigerants work by cycling through phases of evaporation and condensation. In an evaporator, they absorb heat from the environment, causing the refrigerant to evaporate. This gas is then compressed, raising its temperature before it releases the absorbed heat in a condenser, turning back into a liquid. 

Despite refrigerants being crucial to many industries, including building comfort, they have environmental repercussions. Regulations have been created around two primary properties of refrigerants:

    1. Ozone Depletion Potential (ODP): Relative amount of degradation to the ozone layer it can cause, where ODP is measured from 0 – 1. For reference, R-11 has an ODP of 1.0.   
    2. Global Warming Potential (GWP): GWP is an index to measure how much infrared thermal radiation a greenhouse gas would absorb over a given time frame after it has been added to the atmosphere. It is expressed as a multiple of the radiation that would be absorbed by the same mass of added carbon dioxide, which is used as a reference gas. The GWP of CO2 is 1. 

There are several families of refrigerants, each with different properties and uses: 

Chlorofluorocarbons (CFCs) Once widely used but now phased out due to their high ozone-depleting potential (ODP).
Hydrochlorofluorocarbons (HCFCs) Transitional replacements for CFCs, less harmful but still ozone-depleting. Phased out in the HVAC industry.
Hydrofluorocarbons (HFCs) Widely used after the phase out of CFCs and HCFCs. No ozone depletion but significant global warming potential (GWP).
Hydrofluoro-olefins and Hydrochorofluoro-olefins (HFOs & HCFOs) Next generation of refrigerants that are non-ozone depleting with ultra-low GWP.
HFO Blends Blends including an HFO, feature lower GWPs.   
Natural Refrigerants Include ammonia, carbon dioxide, and hydrocarbons.


Regulatory Background 

Refrigerant regulations have been put in place to address these environmental concerns. Key Regulatory Milestones include: 

  • Montreal Protocol (1987): This international treaty aimed to phase out ozone-depleting substances. This included CFC and HCFC refrigerants.  This led the transition to HFC refrigerants in the HVAC industry.   
  • Kigali Amendment (2016): This amendment to the Montreal Protocol specifically targeted the phase down of HFCs to use lower GWP refrigerant alternatives, to global warming.  
      • Canada committed to phased reductions starting in 2019.  
      • Each country has its own regulations to meet the amendment phase down requirements given the diverse use of refrigerants in different industries and the state of the country’s development.   
      • The US did not sign the Kigali Amendment, the US Environment Protection agency (EPA) requirements will phase down HFCs on the same schedule as the Kigali Amendment.  Prior to the EPA, the state of California implemented regulations to restrict the use of HFCs, which some other states adopted. 

Upcoming Regulatory Changes – HVAC Industry

Below is a summary of the regulatory changes shaping the refrigerants used in new equipment in the HVAC industry.  

Jan. 1, 2025
Chillers to have refrigerants with GWP less than 750

Despite Canada only having upcoming regulations for chillers, we will see other equipment change refrigerants due to the US governance. Manufacturers are transitioning their products to meet US regulation timelines.  

Jan 1, 2025  Jan. 1, 2026 

Chillers stationary AC < 700 GWP 

New Ice Rink Chillers < 700 GWP 

VRF < 700 GWP  

EPA allowing additional time for installation 

US California
Jan. 1, 2025  Jan. 1, 2026 

Stational AC < 750 GWP 

New ice rink Chillers < 150 GWP 

VRF < 750 GWP  


Refrigerant Replacements + Flammability 

The development of low GWP refrigerants introduces a new refrigerant safety group A2L refrigerants.  These are considered “Lower Flammability”.  The two common refrigerants previously used in HVAC equipment, R-134a and R-410a, are A1 refrigerants that are identified as having “no flame propagation”.  

The different safety classification changes the design requirements outlined in the codes and standards that are enforced.  

Below is a list of refrigerant replacements for the two most common HFCs in HVAC equipment, R134a and R410a.  

Medium Pressure Refrigerants 
Refrigerant  Flammability Class  GWP 
R-134a  A1  1300 
R-513A  A1  630 
R-515B  A1  298 
R-1234yf  A2L 
R1234ze(E)  A2L 


High Pressure Refrigerants
Refrigerant  Flammability Class  GWP 
R-410a  A1  1924 
R-454B  A2L 467
R-32 A2L  677 

CSA B52 Mechanical Refrigeration Code

The CSA B52 Mechanical Refrigeration Code outlines the design requirements for equipment using refrigerants.

Currently, the CSA B52 2013 version is referenced by the BC Safety Standards Act and does not include A2L refrigerants. The CSA B52 2018 version, which is enforced by the Alberta Boiler and Pressure Vessels Code and referenced by provincial building codes, introduces A2L refrigerants but does not cover all refrigerants.

The latest version, CSA B52 2023, has yet to be adopted at the time of writing. This version further aligns with ASHRAE 15 Safety Standard for Refrigeration Systems and ASHRAE 34 Designation and Safety Classifications of Refrigerants, and changes the design requirements for some equipment using A2L refrigerants.

Given the differences between the 2018 and 2023 versions, it is crucial to communicate with local authorities for upcoming projects during the transition period. This ensures that the best solutions are provided for the owner, potentially requiring alternate solutions to be accepted in order to use the latest version of CSA B52 when advantageous.

Technical Safety BC has recommended adopting the 2023 version into the Power Engineer, Boiler, Pressure Vessel, and Refrigeration Safety Regulation. However, the Alberta Boiler and Pressure Vessels Code currently enforces CSA B52 2018 and has not indicated any timeline for adopting the 2023 version.

Impact on the Built Environment & Building Owners 

Both new construction and existing building equipment replacement projects may see the impact of the new regulations.

New Construction  

  • Buildings with chillers, heat recovery chillers, and water to water heat pumps located indoors may see design requirements not experienced in the past, specifically for equipment now using A2L refrigerants.  
  • Machinery rooms may be required for some equipment, where similar equipment using A1 refrigerants, these were not previously required.    
  • A review of equipment and CSA B52 will be required along with close coordination with the design team and authority having jurisdiction.  
  • Changes in refrigerants for other equipment may drive design decisions to use different systems than what have been used in the past.  

Existing Buildings 


  • Existing equipment may continue to operate to the end of its useful service life. Currently existing equipment can still be recharged with the current HFC refrigerants (R-134a or R-410a). 
  • HFCs are being phased down, not phased out. HFC production will continue as there are other critical industries that require these refrigerants. 
  • There currently are no requirements to replace refrigerants for existing equipment.  
  • Some medium pressure equipment could switch refrigerants; however there could be performance impacts. Full review of the equipment would be required if this was desired.  
  • Building operators may want to review their equipment as they determine their refrigerant management plans for equipment servicing.  
  • Equipment replacement or new heat recovery equipment projects located within the building will require a full review of building infrastructure.  This is most important when new equipment uses A2L refrigerants. A2L refrigerants have different safety requirements than A1 predecessors of similar equipment. This may result in updates to architectural layouts to accommodate machinery rooms or upgrades to existing ventilation systems.  AME will work with owners and the local authority having jurisdiction to find the best solution for the project.  


In conclusion, new equipment will be supplied with new GWP refrigerants, reflecting the HVAC industry’s commitment to reducing its impact on global warming. Although Canada’s regulations currently apply only to chillers, U.S. regulations will influence equipment availability. Close attention to CSA B52 requirements will be essential, and working with local authorities (AHJs) will ensure the best solutions for projects involving A2L refrigerants. While existing equipment using HFCs may continue to be used, the shift toward decarbonization and electrification means more buildings will incorporate heating equipment, such as heat pumps, using these new refrigerants.