Reporting and Recordkeeping Resources

• Instructions for Reporting
• Petitions to Import HFCs for Transformation and Destruction
• Requests for Additional Consumption Allowances (RACAs)
• HFC Reporting Forms
• HFC Third-Party Audit Guidance

Instructions for Reporting

EPA has issued final rules under the AIM Act to phase down the production and import of hydrofluorocarbons (HFCs).ⁱ The rules include reporting and recordkeeping requirements for entities that produce, import, export, destroy, use as a feedstock, reclaim, package, or otherwise distribute HFCs. EPA provides reporting forms and instructions to assist entities in fulfilling these requirements. With the exception of a few reports, these Microsoft Excel-based reporting forms are required to be submitted to EPA through EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT). To submit a report through e-GGRT, you will first need to register.

Registration

Registration for HFC Allocation program reporting within e-GGRT is by invitation only. If you need to submit data through e-GGRT under the AIM Act but do not have an account, please complete this form to initiate the registration process.

Report Submission Calendar

HFC quarterly reports are due 45 days after the end of the reporting period. A detailed control period calendar (pdf) (132.92 KB) identifying when specific reports are due is also available.

Instructions for Reporting through e-GGRT

• HFC Reporting Instructions (pdf) (2.32 MB)
• Registration and Account Management (pdf) (3.44 MB)
• Petitioning to Import Virgin HFCs for Transformation or Destruction (pdf) (1.95 MB)

Instructions for Reporting through the ODS Program Service in CDX

• Registering as a CDX User
• Submitting Other Documents to EPA through CDX
• Petitioning to Import Used ODS and HFCs for Destruction

Instructions for Report Completion

• Completing the HFC Application-Specific Allowance Holder Biannual Report (pdf) (245.78 KB)
• Submitting Requests for Additional HFC Consumption Allowances (pdf) (283.02 KB)

Instructions for Filing in ACE

• Tips for filing HFCs in ACE

HFC Antidumping and Countervailing Duties One-Time Report for Importers

Companies that import regulated substances who are subject to an antidumping and countervailing duty order issued by the Department of Commerce that are receiving allowances for 2022 or 2023 must provide documentation of cash deposit of and final payment of such duties for the regulated substances imported from January 1, 2017, through May 19, 2021, or provide evidence that those imports were not subject to such duties for those years. An antidumping and countervailing duties form is available on this page. These reports were due to EPA by December 6, 2021, and must be submitted through the ODS Program Service in CDX. Entities will need to register with the ODS Program and submit their application using the Other Documents data flow.

Petitions to Import Used HFCs for Destruction

Companies that import used HFCs into the United States for destruction must submit a petition to EPA at least 30 working days before the shipment is to leave the foreign port of export in order to not expend allowances. Petitions to import used HFCs for destruction have been incorporated into the existing petitions form for ODS, which is available through the ODS Program Service in CDX. Companies will need to register with the ODS Program and submit their petition to import used HFCs for destruction to obtain a non-objection notice from EPA.

Petitions to Import HFCs for Transformation and Destruction

Companies that import virgin HFCs into the United States for use in a process resulting in transformation or destruction of the material must submit a petition to EPA at least 30 working days before the shipment is to arrive at a U.S. port in order to not expend allowances. Petitions to import HFCs for transformation or destruction will need to be submitted to EPA through e-GGRT. A petition to import virgin HFCs for transformation or destruction form is available on this page. More information will be forthcoming on the submission process.

Requests for additional consumption allowances (RACAs)

Companies that export bulk HFCs can request additional consumption allowances equivalent to the quantity of HFCs exported. The grant of the consumption allowances is effective on the date the notice is issued. If granted, these additional consumption allowances are valid for the year the HFCs are exported. They expire at the end of the calendar year in which they are granted.

EPA requires that companies submitting a RACA provide the relevant invoices, bills of lading, electronic export information (EEI) document, and the internal transaction number (ITN) for all shipments regardless of monetary value, destination country, or other characteristics that could otherwise exempt an exporting entity from obtaining an ITN. ITNs can be found on the EEI associated with each export. ITNs allow EPA to efficiently verify reported exports in the Customs’ Automated Export System (AES). Each ITN begins with an X and consists of the year, month, day of acceptance and a 6-digit random number. For example, an ITN for an accepted filing on January 1, 2022, would look like X20220101999999. Additional guidance on how to complete a RACA submission is available in the reporting instructions on Submitting Requests for Additional HFC Consumption Allowances.

Reporting Forms

* Report should be submitted through the Ozone Depleting Substances (ODS) Program Service in CDX.

HFC Third-Party Audit Guidance

To assure compliance with the regulations implementing the HFC phasedown, EPA established a third-party audit provision, in 40 CFR 84.33(a). The provision states:

“Any person producing, importing, exporting, reclaiming, or recycling for fire suppression a regulated substance, as well as any person receiving application-specific allowances, must arrange for annual third-party auditing of reports submitted to EPA except for persons receiving application-specific allowances for mission-critical military end uses.”

Agreed-upon procedures (AUP) engagements, performed by an independent certified public account (CPA) in accordance with the American Institute of Certified Public Accountants (AICPA) Attestation Standards, specifically AT-C section 215 Agreed-Upon Procedures Engagements, should be used to meet the auditing requirement. To assist CPAs and the regulated community, EPA is providing guidance on what records need to be obtained, how they must be reviewed, and what findings will be in the audit report.

• HFC Auditing Guidance Document (updated) (pdf) (738.43 KB, 3/14/2024)
• HFC Third-Party Audit Summary of Findings (xlsx) (19.46 KB, 3/5/2024)

On May 6, 2024, The American Institute of Certified Professional Accountants (AICPA) released the document Technical Question and Answer (TQA) 9510.04, Performing Agreed-Upon Procedures Engagements Related to Third-Party Audit Requirements Under the EPA Hydrofluorocarbon (HFC) Phase Down Program. While not official guidance from the EPA, AICPA consulted with the agency during the development of their guidance. It provides illustrative procedures and is in a format CPAs are familiar with. It remains the responsibility of each third-party CPA and each regulated entity to address all applicable requirements of 40 CFR 84.33. However, the EPA is providing a link to AICPA’s document for the public’s convenience. Access to the guidance is through an AICPA membership, which is free. You can access the resource at TQA Section 9510.04 | Resources | AICPA & CIMA (aicpa-cima.com).

EPA intends to evaluate the effectiveness of this guidance after review of the first audits, which are due by May 31, 2024, and may modify this guidance accordingly in winter 2024/2025 prior to the audits on 2024 records which are due May 31, 2025.

On March 12, 2024, EPA hosted a webinar titled: Attestation Engagements (Audits) for the HFC Allocation Program Guidance for CPAs. The following resources are available:

• Webinar slides:  Attestation Engagements (Audits) for the HFC Allocation Program (pdf) (445.86 KB)
• Webinar video recording
• Frequent Questions on the Phasedown of HFCs