Extended Producer Responsibility

What Is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a forward-looking environmental policy approach that emphasizes product system responsibility, rather than focusing only on manufacturing facilities. Originally defined by the U.S. Environmental Protection Agency (EPA), EPR encourages companies to reduce environmental impacts throughout a product’s full life cycle from material sourcing and manufacturing, to use and final disposal or recycling. “The greater the ability of the actor to influence the life-cycle impacts of the product system, the greater the degree of responsibility for addressing those impacts should be.” [Source: U.S. EPA, “Extended Product Responsibility: A New Principle for Product-Oriented Pollution Prevention,” 1998]

Key Principles of EPR

1. Lifecycle Accountability

Assign responsibility for environmental impacts to stages of the product lifecycle that traditionally go unregulated, especially post-consumer. For HVAC, this means recognizing emissions from refrigerant leakage during operation and at system end-of-life.

2. Design for the Environment

Provide feedback loops to designers and manufacturers to prioritize:

Low-GWP or natural refrigerants

Durable, repairable system components

Modular designs for easier reclaim/recycling

Drives innovation in next-gen HVAC systems that are more efficient and lower-emission by design.

3. Shared Responsibility

Acknowledge that responsibility must be shared among manufacturers, distributors, property owners, technicians, and waste handlers. Within HVAC, this can mean:

Manufacturers design for recovery and offer take-back programs.

Technicians and contractors ensure proper recovery and documentation.

Property managers and owners prioritize leak tracking and lifecycle refrigerant tracking.

Waste facilities or refrigerant reclaimers invest in recovery and destruction infrastructure.

EPR and the HVAC Sector

HVAC systems contain high-GWP synthetic refrigerants that, when leaked, contribute thousands of times more warming than CO₂. EPR in this context means aligning each role.

Reduce emissions at every lifecycle stage, especially:

Installation (charge accuracy)

Operation (leak prevention + logging)

Servicing (proper recovery)

End-of-Life (reclaim, recycle, or destroy responsibly)

Shift the mindset from “compliance” to “stewardship.”

Tools & Guidance for Implementation

The U.S. EPA provides several recordkeeping and reporting requirements relevant to HVAC and refrigerants under Section 608 of the Clean Air Act. While many only apply to equipment containing more than 50 lbs of refrigerant, the spirit of EPR encourages these best practices to be adopted voluntarily across all systems, especially in large portfolios. Tools include:

EPA Leak Rate Calculation & Reporting Tool

Recovery, Recycling, and Disposal Guidance for Technicians

Why It Matters

With refrigerant emissions now accounting for a growing share of corporate Scope 1 emissions, HVAC stakeholders are in a unique position to lead with accountability, innovation, and climate impact reduction. EPR aligns with:

American innovation and economic leadership in HVAC technology

Workforce development via clean cooling technician training

Equity goals through safe, sustainable indoor climate systems for all communities