California’s SB 1206 bans the sale and distribution of bulk virgin hydrofluorocarbons in three stages tied to global warming potential: a GWP cutoff of 2,200 took effect January 1, 2025; the threshold drops to 1,500 on January 1, 2030; and it tightens again to 750 on January 1, 2033. Signed in September 2022, the law amends Health and Safety Code Section 39734 and preserves a pathway for reclaimed refrigerants that meet purity standards.1California Air Resources Board. SB 1206 and AB 663 If you sell, distribute, or buy refrigerant in cylinders in California, the rest of the compliance picture (scope, exemptions, reporting, and penalties) follows from those three dates.
The Three GWP Cutoffs
- January 1, 2025: No bulk virgin HFC with a GWP of 2,200 or higher may be sold or distributed in California.
- January 1, 2030: Threshold drops to 1,500.
- January 1, 2033: Threshold tightens to 750, which clears most legacy HFC blends out of the bulk-virgin market.
Some early summaries mention only the first two stages. The 2033 step at GWP 750 is in the enacted statute and in CARB’s own assessment report, and missing it can leave a business with inventory that is legal in 2030 and illegal three years later.2California Air Resources Board. Senate Bill 1206 Assessment Report – Request for Information
The statute uses 100-year GWP values from the IPCC’s Fourth Assessment Report (AR4). If a substance isn’t in AR4, values from the Fifth Assessment (AR5) may be used, or CARB can determine the value by regulation.3California Legislative Information. California Health and Safety Code HSC 39735 For a refrigerant near a threshold, that choice of source can decide whether it’s legal.
What “Bulk” Means and Who Is Covered
“Bulk” tracks the federal EPA definition in 40 CFR Section 84.3: refrigerant that has been removed from equipment or was never in it. Gas already charged into an air conditioner or refrigeration unit is not bulk and is not the target of the sales ban. The rule reaches the supply chain: wholesalers, distributors, and service technicians buying pressurized cylinders for installation or maintenance.4California Legislative Information. California Health and Safety Code HSC 39734
Which Refrigerants Get Caught at Each Stage
Already Banned (GWP 2,200+)
The 2025 stage removed the highest-GWP products from the bulk-virgin market:
- R-404A, GWP 3,922, common in supermarket refrigeration.
- R-507A, GWP 3,985, common in low-temperature commercial systems.
- HFC-143a, GWP 4,470, a component of several blends.
- R-508B, GWP 13,396, used in ultra-low-temperature scientific and medical equipment.
These GWP values come from EPA’s reference table for the federal Technology Transitions Rule.5U.S. Environmental Protection Agency. Technology Transitions GWP Reference Table
Banned Starting 2030 (GWP 1,500+)
The biggest name in this bucket is R-410A, GWP 2,088, the standard residential air-conditioning refrigerant for the past two decades. Bulk-virgin sales remain legal through the end of 2029. R-448A (GWP 1,386) and R-449A (GWP 1,396) sit below 1,500 and survive this stage.5U.S. Environmental Protection Agency. Technology Transitions GWP Reference Table
Banned Starting 2033 (GWP 750+)
The final phase clears nearly every legacy blend. R-448A and R-449A get caught here. HFC-134a (GWP 1,430) does too. Refrigerants built to survive all three stages include R-32 (GWP 675), R-454B (GWP 466), and natural options like R-290 propane (GWP 3).
The Reclaimed Refrigerant Exemption
SB 1206 draws a hard line between virgin and reclaimed HFCs. Reclaimed refrigerant can still be sold in California even above the GWP thresholds, provided it meets AHRI Standard 700 purity benchmarks.1California Air Resources Board. SB 1206 and AB 663 Servicing an existing supermarket rack with reclaimed R-404A is fine; buying a new cylinder of virgin R-404A is not.
The exemption is conditional. Reclaimed product has to come from an EPA-certified reclaimer, and it has to be accompanied by documentation showing it meets AHRI 700. EPA publishes a list of certified reclaimers, with the territory each one serves, that buyers can check before a purchase.6U.S. Environmental Protection Agency. EPA-Certified Refrigerant Reclaimers Reclaimed material without a valid reclamation certificate is not covered.
Practically, the reclaimed market is what keeps older equipment running as the industry moves to low-GWP systems. Reclaimed R-410A is likely to become especially valuable once virgin supply is cut off in 2030.
How SB 1206 Interacts With Federal Rules
The federal American Innovation and Manufacturing Act of 2020 phases down HFC production and consumption nationwide. From 2024 through 2028, the AIM Act caps allowances at 60 percent of the historical baseline.7Federal Register. Phasedown of Hydrofluorocarbons – Allowance Allocation Methodology for 2024 and Later Years
The AIM Act does not preempt California. States can go further, and where the two sets of rules differ, both apply and the stricter standard controls.8U.S. Environmental Protection Agency. Frequent Questions on the Phasedown of Hydrofluorocarbons A refrigerant still available under federal rules can be entirely banned for bulk-virgin sale in California. If you operate across state lines, both regimes apply.
Registration and Annual Reporting
Sales limits are only part of the compliance picture. CARB also runs the Refrigerant Registration and Reporting system (R3). Facilities with at least one refrigeration system holding more than 50 pounds of a high-GWP refrigerant must register, along with distributors, wholesalers, and certified reclaimers.9California Air Resources Board. Refrigerant Registration and Reporting System (R3)
Annual reports covering the prior calendar year are due March 1. The reporting duty applies to facilities with a full charge of 200 pounds or more, plus distributors, wholesalers, and certified reclaimers.10California Air Resources Board. Refrigerant Management Program (RMP) R3 Tool Frequently Asked Questions The two thresholds trip people up. A 75-pound system triggers registration but not annual reporting. A 200-pound system triggers both.
Federal EPA rules add a separate obligation: any appliance containing 50 or more pounds of ozone-depleting refrigerant that leaks 125 percent or more of its full charge in a calendar year must be reported, also by March 1.11U.S. Environmental Protection Agency. Recordkeeping and Reporting Requirements for Stationary Refrigeration A supermarket or cold-storage operator can easily hit both in the same year.
Records to Keep
A defensible file for each cylinder or system needs the refrigerant type, its GWP value, the purchase date, the vendor, and the storage location. For reclaimed material, add the reclamation certificate showing AHRI 700 compliance. Use GWP values from AR4, since that’s what the statute requires; a number pulled from a newer report or a spec sheet can create a mismatch with the legal standard.3California Legislative Information. California Health and Safety Code HSC 39735
California requires at least five years of retention. That covers invoices, purchase and sale records, deposits collected or returned, quantities recovered or reclaimed, and analytical results verifying purity of reclaimed refrigerant. Paper or electronic is fine, but records must be produced on CARB’s request.12Legal Information Institute. California Code of Regulations Title 17 Section 95369 – Recordkeeping Requirements
Penalties for Violations
CARB enforces SB 1206. Inspections look at purchase logs, inventory, reclamation certificates, and R3 records. Section 39734 makes violations subject to the penalties in Health and Safety Code Article 3 starting at Section 42400.4California Legislative Information. California Health and Safety Code HSC 39734 Under Section 42400.1, a negligent violation is a misdemeanor carrying a fine of up to $25,000, county jail time of up to nine months, or both. Each day a violation continues is a separate offense, so a month of prohibited inventory on a distributor’s shelf can produce 30 separate violations.13California Legislative Information. California Health and Safety Code HSC 42400.1
CARB can also pursue administrative penalties under Section 42410 without going through a criminal prosecution. Penalties collected go to the Air Pollution Control Fund.
Contesting a Citation
If CARB issues a citation or notice of violation, procedures for review sit in Title 17 of the California Code of Regulations, starting at Section 60075.1 for citations and Section 60065.1 for complaints.14California Air Resources Board. Enforcement Administrative Hearing Procedures CARB’s framework generally gives 45 calendar days to respond. Missing that window can forfeit the right to contest the penalty, so a notice of violation should not sit in a stack.