Overview

Amazon enforces strict rules around the sale of refrigerants, ozone-depleting substances (ODS), and hydrofluorocarbons (HFCs) on its marketplace. Sellers who list any products containing or related to these chemicals must comply with a complex web of federal EPA regulations and state-level laws. Violations can result in listing removals and potential legal consequences, making it essential for sellers in the HVAC, automotive, and appliance categories to understand these restrictions thoroughly.

Key Points / What Sellers Need to Know

• Most refrigerants cannot be sold to the general public — Federal law requires that Class I ODS, Class II ODS, and substitute refrigerants may only be sold to buyers certified as technicians through EPA-approved programs, with very few exceptions.
• HFCs are being phased down — The EPA is actively reducing the production, import, and consumption of listed HFCs and restricting their use in specific sectors such as household refrigerators, residential air conditioning, and vending machines.
• Bulk HFC sales face additional requirements — HFCs stored in containers designed for transportation or storage (like cylinders or cans) can only be sold if proper EPA allowances have been expended in compliance with HFC regulations.
• State laws add another layer of restriction — States like Washington, California, and New York have enacted their own laws banning or restricting the sale of certain high global warming potential (GWP) HFC refrigerants and related consumer products.
• Some exempt refrigerants are permitted — A small number of substances, including carbon dioxide (R-744) and nitrogen (R-728) used as refrigerants, are exempt from federal sale restrictions and may be listed on Amazon.

How Refrigerant Classifications Work

The EPA categorizes ozone-depleting substances into two tiers. Class I ODS includes the most harmful chemicals such as R-12, halon, and methyl bromide, which have been largely phased out of production. Class II ODS includes substances like hydrochlorofluorocarbons (HCFCs), with HCFC-22 (also known as R-22) being among the most widely recognized. Beyond these traditional categories, the EPA also regulates substitute refrigerants — chemicals developed to replace Class I and Class II ODS for cooling and heat transfer applications. These substitutes are evaluated under the EPA's Significant New Alternatives Policy (SNAP) program, which classifies them as acceptable, acceptable with use restrictions, or unacceptable.