Carolyn Zhong EIA

As voting members of 484 STP, the Environmental Investigation Agency (EIA), GREE and De’Longhi co-submitted a proposal in June 2016 to UL 484 and proposed that UL should either reinstate UL 484’s 8th edition, or UL should harmonize it with the current IEC60335-2-40standard. The reason for the submission is that these three organizations do not think the restriction on A3 refrigerants’ charge sizes in UL484’s 9th edition is appropriate.

Restriction on charge sizes in UL484’s 9th edition is inappropriate

On July 15, 2015, a couple months after the U.S. Environmental Protection Agency (EPA) approved propane and hydrocarbon blend R-441A as acceptable refrigerants in the U.S. market based on UL 484, ‘‘Room Air Conditioners,’’ 8th Edition, UL issued UL 484, 9th Edition, which lowered the charge sizes of Class A3 refrigerants, including propane, from 140 grams to only 114 grams. The new standard made it difficult to apply propane even in window air conditioners. A3 refrigerants refer to flammable refrigerants, including R600a, R290 and R441A.

As one of the standards under UL, UL 484 covers domestic room air conditioners whose rated voltage is no more than 600 volts alternating current (ac). UL, which stands for Underwriters Laboratory (UL), is one of the major institutions that provides safety-related advising services to U.S. policymakers and consumers. Although compliance with UL standards is not mandatory, most stores only sell products that are UL listed so that they limit liability in the event of product malfunctions. At the same time, U.S. consumers also prefer to purchase products that are approved by UL. In other words, although following UL standards is not mandated by law, it is mandated in practice by retailer and consumer behavior.

In addition, the Significant New Alternatives Policy (SNAP) office of the U.S. Environmental Protection Agency (EPA) also defers to UL standards when reviewing new alternative applications. Additionally, UL participates in safety analysis of new technologies, most notably drafting safely standards for the application of new refrigerant technologies in areas such as air conditioning and refrigeration. Therefore, compliance with UL484 standards is crucial for domestic room air conditioners manufacturers to enter the U.S. market.

UL 484 9th Edition’s unscientific small hydrocarbon charge size has become the only barrier preventing Chinese companies from selling their HC air conditioning technology in the U.S.  If the 484 standard remains unchanged, the application of HC refrigerators in the U.S. will be greatly impeded. The Environmental Investigation Agency (EIA) has been working on this issue for a long time. It is under such circumstances that EIA, GREE and De’Longhi (the largest EU manufacturer of hydrocarbon air conditioners) submitted a petition.

Air conditioner manufacturers are ill-represented on UL484’s Standards Technical Panel (“STP”)

Obviously, the tightened restriction on charge sizes of Class A3 refrigerants in UL 484’s 9th Edition is caused in some part by the dominant role of fluorine chemical producers on UL484’s STP. Each UL safety standard has a Standards Technical Panel (“STP”) that both creates the standard that sets what requirements must be met before a product can be sold in the U.S. market as well as determines whether standards should be adjusted due to the development of new technologies, safety devices or other components.

Currently, many STP members that control the sale of refrigeration and air conditioning equipment are largely comprised of members who represent chemical companies that manufacture fluorinated chemicals. These members are primarily concerned about promoting the adoption of fluorinated gas and their alternative refrigerators in air conditioning and refrigeration equipment. By rule, they represent important shareholders and their presence and efforts are appreciated by UL. However, they are not experts in air conditioning and refrigeration equipment and cannot represent the interests of manufacturers. In other words, STP members will come up with proposals based on their respective perspectives and strongly promote the creation of revision of standards to their advantage.

Therefore, it is important for manufacturers, especially companies that import products to the U.S. market to join relevant STPs because members of STP(s) have rights to submit proposals, to create and revise standards and can vote to change outdated and/or protectionist standards. Only when they become members of their respective STP(s) can they both have the ability to influence the creation and the revision of UL standards in a way that is favorable for their own products and companies, as well as the ability to work to make sure that relevant standards won’t be revised to ban the import of their products to the U.S. market.

EIA hopes that the petition will spur significant discussion on hydrocarbon charge sizes and lead to a working group being established to further discuss and determine the charge size. If more experts that understand the air conditioner manufacturers and HC refrigerators can join the working group of UL484’s STP, submit proposals to revise UL484 standards based on the latest research findings on HC technologies, and prevent fluorinated chemicals companies from monopolizing the market, then UL484 will be revised in a more reasonable and scientific manner.