The New York State Department of Environmental Conservation is reminding owners and managers statewide about the upcoming Part 494 registration, due June 1, 2025 for some teams with large commercial equipment.

Here’s what you need to know about this requirement, and whether or not it impacts your building.

What Is Part 494?

Part 494 is a section in Title 6 of the New York Codes, Rules and Regulations – NY State rules, specifically. Title 6 refers to the Department of Conservation, with Part 494 located under Subchapter I (Climate Change).

Part 494 references rules for Hydrofluorocarbon Standards and Reporting. Going forward, we’ll refer to hydrofluorocarbons as HFC/HFCs.

This Part was recently amended and updated, and includes the following items:

• Establishing prohibitions on certain substances in certain products and systems based on their Global Warming Potential
• A “phasedown” in the sale of virgin HFC substances
• A Refrigerant Management Program with controls on the leakage of HFCs in existing equipment
• A Supermarket Refrigerant Program to “phasedown HFC emissions” from the largest sources
• Certain labeling, reporting, and record-keeping requirements for suppliers of HFCs and HFC-containing products

Simply put, Part 494 outlines equipment and substances being phased out, plus registration, inspection, and maintenance requirements for select refrigeration-related equipment.

Updates to Part 494 went into effect on January 9th, 2025. Registration requirements are spaced out based on equipment size, but some general requirements (annual inspections and recordkeeping) are in effect now. We won’t cover the list of equipment and materials that are being phased out, but you can review a list in the DEC’s Fact Sheet. 

What Are Hydrofluorocarbons?

Per the DEC’s Frequently Asked Questions:

(HFCs) are potent greenhouse gases often used in refrigeration and cooling equipment. HFCs have a global warming potential (GWP) – a metric that measures the ability of gases to trap heat in the atmosphere – hundreds to thousands of times higher than carbon dioxide. HFCs and other high GWP substances are used in a variety of home and commercial products and equipment. The Part 494 HFC Standards and Reporting regulation adopted in January 2025 will help control emissions of HFCs and substitutes that contribute to global climate change.

Required Registration For Equipment

Part 494 establishes a Refrigerant Management Program (RMP), with requirements for “commercial entities to register and label covered equipment, conduct leak monitoring, and to address leaks.” This requirement covers refrigeration and air-conditioning equipment with “50 pounds or greater of refrigerant” that is used in commercial facilities or buildings.

Who Can Register?

The operator may complete registration on behalf of the owner, or vice versa. Multiple persons may wish to file for the same facility if the facility has multiple tenants. Per the DEC, “only one registration is required per facility, but you may submit multiple registrations as needed to cover all equipment.”

The DEC cites an example in their FAQs:

For example, the owner of the facility may register a central heating and cooling system, while a tenant separately registers a refrigeration system that the tenant controls. The definitions for owner, operator, and facility are provided in Section 494-1.3. If multiple entities may be considered the “owner” of a facility, register the entity that owns the equipment that is covered by this rule.

Forms and instructions to register can be accessed on the DEC’s site, here. 

If you don’t have the information requested during registration (like the amount of refrigerant contained in equipment), the DEC asks that you provide the best information available and attach a brief explanation.

If you have questions, we recommend reaching out to climate.regs@dec.ny.gov with any specific details.

What Are Registration Deadlines?

Equipment is grouped into the following categories:

• Small: 50 – 199 pounds of refrigerant: registration due June 1, 2028
• Medium: 200 – 1499 pounds of refrigerant: registration due June 1, 2026
• Large: 1500+ pounds of refrigerant: registration due June 1st, 2025

For all of the above categories, there may be additional maintenance and reporting requirements throughout the year that are in effect now. This includes quarterly or annual inspections, as well as specific requirements for leak repairs. Additionally, if new equipment is installed in the future, registration must be done by June 1st following the due date for its size group.

You can view due dates for all the above categories in the Fact Sheet. 

Who Has To Comply?

Per the DEC quote above, HFCs can be found in a variety of products and equipment, especially related to buildings. The refrigerant bans outlined are by sector, including air conditioning (chillers, heat pump systems, etc). This may impact equipment in both commercial and multifamily buildings, depending on the size and output of the systems your team owns and operates.

Also from the DEC, “…any entity that owns or operates covered equipment in New York State or that supplies such equipment or refrigerant may be required to register and report.”

Specifically:

• If you own or operate a facility with “commercial equipment” that contains 50 pounds or more of refrigerant, you may be required to report under the Refrigerant Management Program
• Supermarket chains are required to participate in both the Refrigerant Management Program and the Supermarket Refrigerant Program

While the DEC’s Fact Sheet does say that “Residential users and consumers are not regulated under Part 494,” that generally references individual homeowners, apartment residents, and individual condo and co-op owners utilizing equipment. We confirmed with the DEC that Part 494 does cover companies that own multifamily buildings for commercial purposes; more specifically, teams that own/would be purchasing equipment like central air-conditioning systems that serve the whole building – not equipment used by individual residents.

In those cases, residential management teams may be prohibited from purchasing and installing specific equipment (as outlined in Part 494-1.4(e)), and, depending on the size, may have to comply with registration under the Refrigerant Management Program. That said, equipment containing 50 pounds or more of refrigerant may be uncommon in residential buildings. It’s likely that most requirements may apply to owners and managers of larges spaces like warehouses, institutions, or similar buildings.

Bottom line – if your property has equipment using over 50 pounds of refrigerant, registration requirements may likely apply to your building. 

Importantly, per the fact sheet, Part 494 does not “force any business to replace existing products or equipment prior to the end of their useful life. The regulation phases out the use of new HFCs and HFCs in new products and equipment.”

Details on registration, bulk substances, storage, and more are outlined in the FAQs, and the DEC fact sheet. Industry professionals have expressed a number of challenges with the new rules in its current state, so it’s possible there may be adjustments in the future. We’ll keep you posted on any major changes.

Where Can I Get Help?

You can access instructions, forms, and other resources on the DEC’s website, linked here. You can also sign up to get future notices and updates directly from the DEC through this form.

If you need additional help, we recommend reaching out to the DEC at climate.regs@dec.ny.gov with any specific questions or requests. HVAC experts and specialists like Daikin can also answer equipment-specific questions you have, depending on what you have in your property.