Aerosol GWP Requirements for 2025 & 2028

The following content was adapted from 3R Review published by Doug Raymond of Raymond Regulatory Resources. Any opinions expressed in this document are solely those of the author and are subject to change as new information is available. To sign up for the full newsletter, or inquire about consultation services, contact Doug at djraymond@reg-resources.com. 

Per the EPA’s American Innovation and Manufacturing (AIM) Act, as of January 1, 2025, the agency is limiting the use of HFCs with a Global Warming Potential (GWP) greater than 150 in aerosol products.

Please note, 152a has a GWP of less than 150 GWP and thus it is not restricted under this rule.

However, there is an exception; aerosol products in the following categories will have until January 1, 2028, to comply. As of January 1, 2028, all aerosols can only use HFCs with a GWP of 150 or less. This includes an extension for the use of HFC-43-10 mee and HFC-245fa in aerosols until January 1, 2028.

Exceptions

Products within these categories will have until January 1, 2028, to comply.

• Cleaning products for removal of grease, flux, and other soils from electrical equipment or electronics
• Refrigerant flushes
• Products for sensitivity testing of smoke detectors
• Lubricants and freeze sprays for electrical equipment or electronics
• Sprays for aircraft maintenance
• Sprays containing corrosion preventive compounds used in the maintenance of aircraft, electrical equipment or electronics, or military equipment
• Pesticides for use near electrical wires or in aircraft, in total release insecticide foggers, or in certified organic use pesticides for which the EPA has specifically disallowed all other lower-GWP propellants
• Mold release agents and mold cleaners
• Lubricants and cleaners for spinnerets for synthetic fabrics
• Duster sprays specifically for removal of dust from photographic negatives, semiconductor chips, specimens under electron microscopes, and energized electrical equipment
• Adhesives and sealants in large canisters
• Document preservation sprays
• Topical coolant sprays for pain relief
• Products for removing bandage adhesives from skin

Sell-Through Period

Products manufactured or imported before their respective effective date of January 1, 2025, or January 1, 2028, have a three-year sell-through period.