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As noted in eInsight in December, the proposed regulations concerning HFCs were published in Canada Gazette Part 1 by Environment and Climate Change Canada (ECCC) on November 26, 2016. This publication included a public comment period that ended on February 8, 2017.

HRAI recently met with representatives of ECCC to discuss responses to the comments filed by HRAI in May as part of the last consultation round. These comments included ensuring the proposed regulations were fully consistent with the Kigali amendment, clarification of the method being used to determine the HFC baseline consumption number for Canada, the need for sector segmentation to assist RMC under the new P2 plan and clarification on the continued practice of importing reclaimed HCFCs and HFCs.

ECCC responses confirmed that

a)  the final draft of the regulation revisions concerning HFCs will be fully compliant with the Kigali amendment including the process for determining the Canadian baseline;

b) sector segmentation will be covered off in the reporting under section 72 of the ODS regulations; and

c) as written in the ODS regulations since 1999, the only restrictions on import of reclaimed refrigerants apply to HCFCs in 2020 when only reclaimed HCFC-123 can continue to be imported into Canada until January 1, 2030. 

Also concerning implementation of the HFC regulations and the allowance system well in advance of the first phase down step in 2019, ECCC noted that based on the current timelines, it does not appear that the HFC amendments will be completed until late 2017 or early 2018 and they will come into force 6 months after the final publication date.

However, the allowance numbers will be able to be worked out by each allowance holder well in advance of the 2019 start of the allowance reduction schedule. ECCC encouraged allowance holders to discuss this matter individually with them.

On February 7th, HRAI forwarded its comments to ECCC which included the association’s agreement with the responses from ECCC listed above and the general direction of the HFC revisions. Also in its submission, HRAI reiterated the association’s lack of comment on the specific GWP limits and timelines for implementation because of the differing opinions amongst members. HRAI encouraged ECCC to look at the comments being submitted by individual companies and other associations on the proposals in these areas and attempt to achieve as level a playing field as possible for all participants in the market.