Some members of the polyurethanes industry are currently transitioning to low global warming potential (GWP) blowing agents. This transition has been complicated by the U.S. Court of Appeals – D.C. Circuit’s decisions to partially vacate the U.S. Environmental Protection Agency’s (EPA) Significant New Alternatives Policy (SNAP) Rules 20 and 21. SNAP Rules 20 and 21 prohibited the use of certain hydrofluorocarbon (HFC) blowing agents in certain foam sectors. The dates of prohibition for the foam sector varied from January 1, 2017 to January 1, 2021.

Given the partial vacatur of SNAP Rules 20 and 21, there is no federal requirement to transition to low GWP blowing agents in the foam sector – including the SPF industry. The transition to low GWP is now being led by the states. California, New Jersey, Vermont, and Washington have enacted SNAP-like legislation prohibiting the use of HFCs in the foam sector. Several other states are working within existing authority to promulgate regulations implementing SNAP-like restrictions.

*The charts are provided solely as a summary of available information and should not be used as a substitute for up-to-date research should specific questions arise. The charts do not constitute legal advice and are not intended to be a statement of legal requirements.

Additional details on pending regulations will be provided after the State finalizes the restrictions.

  • Effective Restrictions in Place
  • Approved Restrictions, not yet effective
  • Restrictions under Development
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