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A Strange Silence on Dry-Ship R-22 Air Conditioners

R-22 Air Conditioner Refrigerant

Dry-ship R-22 air conditioners and heat pumps – A term that was new to me 10 days ago. It’s a pretty big story but even the New York Times doesn’t know about it yet. They just published an article about the smuggling of R-22 refrigerant, the HCFC replacement for the CFCs of the pre-Montreal Protocol days. They glossed over the dry-ship R-22 story and seem not to have grasped it completely.

Dry-ship R-22 air conditioners and heat pumps – A term that was new to me 10 days ago. It’s a pretty big story but even the New York Times doesn’t know about it yet. They just published an article about the smuggling of R-22 refrigerant, the HCFC replacement for the CFCs of the pre-Montreal Protocol days. They glossed over the dry-ship R-22 story and seem not to have grasped it completely.

Here’s what they said:

Under an international treaty, the gas, HCFC-22, has been phased out of new equipment in the industrialized world because it damages the earth’s ozone layer and contributes to global warming.


Although it has been illegal to sell new air-conditioners containing HCFC-22 in the United States since 2010, vast quantities of the gas are still needed to service old machines.

The closest they came was this statement:

Many air-conditioning manufacturers have even figured out how to sidestep the 2010 ban on selling new machines containing HCFC-22, by offering unfilled air-conditioning compressors that service workers swap into existing units and then fill with the gas, creating refurbished machines that are as good as new.

It seems they don’t grasp the significance of those replacement components. Brand new air conditioners and heat pumps are still being manufactured, sold, and installed here in the US solely because of the EPA’s loophole…and the EPA’s refusal to close it. It’s mostly done when changing out equipment in existing homes, and I haven’t found evidence of it happening in new homes yet.

I posted my article at Green Building Advisor this past week, and the only comment it got was from my fellow Advisor, Martin Holladay. Lloyd Alter published an article about dry-ship R-22 air conditioners at Treehugger, and it also got no comments. I’m wondering if readers just don’t see this as the same kind of big deal that I do.

hvac air conditioner heat pump dry ship r 22 advertisement 1

This morning, one of our readers forwarded me an email ad he’d gotten from an HVAC dealer. The photo above is part of it, showing the ‘R22 Dry Air Conditioners’ (emphasis added) they’re selling, along with the ‘R410A Air Conditioners.’ Without the EPA’s loophole, that ad wouldn’t include R-22 air conditioners and heat pumps. Notice that the R410A air conditioners aren’t ‘dry.’

Yes, this is really happening! Here’s the section advertising ‘R22 Dry Heat Pumps.’

hvac air conditioner heat pump dry ship r 22 advertisement 2

So, again let me advise you to be careful when buying a new air conditioner or heat pump. This may be the cheaper alternative right now, but it will get very expensive as we get closer to 2020, the year that production of R-22 is supposed to end.


Related Articles

HVAC Secret: An Air Conditioner Loophole the Size of the Ozone Hole

The Science Behind the Phase-Out of R-22 Air Conditioner Refrigerant

Air Conditioner Vendors Keep Selling “Banned” R-22 Based Equipment, Driving Through Loophole the Size of the Ozone Hole by Lloyd Alter at Treehugger

This Post Has 26 Comments

  1. Hi Allison, 
    Hi Allison, 
    Just commenting in the event that no one else does to end the strange silence. Nice article!

  2. Studying the ads shown it
    Studying the ads shown it seems odd that the 2 Ton R-22 AC would be chosen over the R-410A one, since the latter is $120 less and has a warranty of 10/5 years vs. 5/1 years for the R-22 one.

  3. I have a heat pump that
    I have a heat pump that requires R-22. No one has been able to find a slow leak in it so when I inquired about getting it recharged and heard the price that was wanted for the R-22, I switched to another way of cooling my house (that’s another story!). 
    The failure of this loophole to be closed is outrageous, for several reasons. First, the serious damage from R-22 to the atmosphere is well documented. Second, new dry systems sold now will be orphaned 8 years from now, so some modest savings to day purchasing these systems makes no sense.  
    Those of us who are outraged by this failure of rational government action need to make a lot of noise about it. I’m starting by sending out information about this problems to my entire family and friends mailing list. How about everyone reading this doing that.

  4. Milan J.:
    Milan J.: Whew! Thanks for that. :~) 
    Stan K.: Yes, that’s true, but what’s happening is that the contractors are just installing a new R-22 condensing unit so they don’t have to replace the air handler and evaporator coil. As a result, a contractor who comes along and recommends replacing the whole system with an R-410A unit comes in higher because of the extra components. The homeowner thinks the R-22 system is a better deal because it’s so much less expensive and still looks like a whole new AC to them.  
    Also, this ad is from a closeout dealer selling off-brand equipment. The name-brand equipment is going to be at least twice as expensive.

  5. John R.: I
    John R.: I agree that the EPA leaving this loophole open is outrageous. Even Carrier, an air conditioner manufacturer, has asked them to close it. Until it does get closed, the best thing to do is let people know that buying an R-22 replacement condenser is penny-wise and pound-foolish in the extreme.

  6. Allison, I saw your 1st
    Allison, I saw your 1st article and started a little quick research because I wasn’t aware of this either. 
    So far, the installers I have talked to say they are not using them, although all knew of them. That said most of these people are mostly doing new installations. The dry ship units seem to be aimed at the replacement component market. 
    One interesting thing I noticed in the ads you show above; there is a big up-charge on the R22 units. I presume this is offset by not having to replace the entire system, but you have to wonder if manufacturers (and/or distributors) are engaging in a little price gouging. Given the up charge and the 50% reduction in warranty it doesn’t sound like a good deal for the consumer.

  7. Allison wrote:  &lt
    Allison wrote: 
    “They completely missed the dry-ship R-22 story.” 
    Well, not completely. Although the article didn’t mention dry-shipping complete units, it did mention companies are still shipping dry (“unfilled”) components (like compressors) so dealers can continue to refurbish existing R-22 systems.

  8. Bill S.:
    Bill S.: Yes, it’s mostly for existing homes that this is happening. See my response to Stan’s comment above. I don’t know if they’re engaging in price-gouging or not since I don’t know their costs, but those numbers do give the appearance of it, don’t they? 
    David B.: Thanks. I somehow completely missed that when I first read the NYT article. I’ve corrected this article to reflect that.

  9. At the last ACCA National
    At the last ACCA National Conference’s CEO Rountable, the contractors present took all of the manufacturer CEO’s to task about this issue. Their response was that they don’t like it either. But since the EPA left the loophole open, and one manufacturer decided to walk through it (Goodman) they didn’t have any choice but to follow. I think this shows a real lack of vision on the part of the manufacturers, but I have learned not to expect any more from them.  
    The better contractors out there are not advertising these units, and if they are selling any, it is as a replacememt component in a failed system. As an example, of the hundreds of units we have sold since this went into effect, only 2 were dry R22 units, and they were replacement components. When we get asked by consumers about them, because a competitor quoted one, we explain the issue to them, show them the benefits of buying a 410a unit, and for the most part, they make the right choice. Either way, however, we won’t sell them an R22 system.  
    Ultimately, if the manufacturers can not be pressured to change by their own dealers, nothing will change until the EPA closes this loophole. Since every manufacturer except Goodman has asked them to do so, and they still haven’t, I am not sure what it will take to make it happen.But I am with you as you tilt at this windmill!

  10. The article also stated that
    The article also stated that it is NOT illegal in many other countries and is still cheaply manufactured in vast quantities in China and other countries. 
    What I object to is the idea that we as the US should penalize ourselves so it artificaially inflates the profits of third worlders that have no regard for the environment or our economy. 
    If this stuff is so bad, impose a global ban – PERIOD. We all share the same Ozone. 
    Otherwise it’s all talking points and window dressing. 

  11. Adam G.:
    Adam G.: That’s pretty much how I understand things from talking with other HVAC pros. I wasn’t going to mention Goodman as the main culprit among manufacturers because I don’t have evidence beyond hearsay, but I think everyone knows or suspects they’re the ones. Thanks for your support. Now, let me run because that next blade is about to be in reach! 
    Rob S.: Yes, the international trade in R-22 is a problem, and yes, if countries don’t comply with the Montreal Protocol, they gain some economic advantage. I don’t think it’s legal in those other countries, though. They signed the Montreal Protocol, too, as I understand, but they seem to be unwilling to comply. If you look back at the ’90s and the phaseout of CFCs, the same kind of thing happened. Now, 20 years later, CFCs are gone for the most part. The same will be true of R-22 eventually.

  12. The article also stated that
    The article also stated that it is NOT illegal in many other countries and is still cheaply manufactured in vast quantities in China and other countries.  
    What I object to is the idea that we as the US should penalize ourselves so it artificaially inflates the profits of third worlders that have no regard for the environment or our economy.  
    If this stuff is so bad, impose a global ban – PERIOD. We all share the same Ozone.  
    Otherwise it’s all talking points and window dressing.  
    Posted @ Saturday, September 08, 2012 1:04 PM by Rob Susz  
    I agree with some of what Rob says. All I can say is hurry up 2020 if there really will be a ban on producing R22 World Wide. I know our government though. They still use asbestos in break pads for heavy equipment and so I’m wondering if our own government will adhear to the R22 production ban or import the R22 from someplace like China? Point is,… It will be impossible to get everyone in the world to comply, sadly enough. Just like land mines & nuclear weapons.

  13. Even the 13SEER units won’t
    Even the 13SEER units won’t achieve that unless they are installed with their matching coil, kind of defeats the whole point of the 13 minimum SEER requirements for new systems. If it’s a “repair part” why the 13SEER requirement? Then there are the 14SEER dry condensers, what’s the point if it’s only supposed to be a “repair part” not installed with it’s matching coil?

  14. It is an awful story. ACEEE
    It is an awful story. ACEEE weighed in as much as we could to try to stop this, working with the manufacturers. As Bob notes, getting SEER 13 with a SEER 13 condensing unit requires a matched indoor coil. What may be even worse is trying to clean out the old oil to use the old evaporator with a new 410A condensing unit. Today, thermostatic expansion valves (TXVs) are almost universal, and necessary for high temperature performance (EER). Most of the old coils, from 10 SEER and similar units, used short orifice or other fixed expansion devices, and just can’t get to SEER 13 with the undersized coil and fixed orifice. Note the recent announcement that Daikin has bought Goodman, and hope that the corporate culture changes.

  15. Hi Allison, 
    Hi Allison, 
    I added a post to TOD’s Drumbeat here
    And Stuart Staniford of Early Warning had it in his Thursday Links
    This is what he had to say… 
    Dry-ship R-22 units. This sounds appalling. If true, the administration should not be tolerating this, and if you’re buying a heat-pump or an A/C unit, ask if it uses R-22. 

  16. Harvey wrote:  &lt
    Harvey wrote: 
    > What may be even worse is trying to clean out the old oil to use the old evaporator with a new 410A condensing unit. 
    After I bought my home in 2007, I replaced the still shiny two-year-old 10 SEER AC and furnace with an R410a heat pump and air handler (I will never own another home with a furnace!). 
    I wanted to use the existing line-set since replacement would have required expensive stucco repairs. However, removing the oil is non-trivial, and it must be tested since any residuals can damage the new system and void the warranty.  
    Given the hassle factor and risk of getting it wrong, I can’t imagine converting an R-22 evap coil to R410a. On the other hand, it’s not surprising that few homeowners are willing to spring for a complete new system for a compressor failure on a relatively young R-22 system. 
    What concerns me more about dry-shipping is that it perpetuates R-22 on complete change-outs and, no doubt, some new homes as well.

  17. Allison and all,  
    Allison and all,  
    I follow the HVAC-R trade magazines and this has been going on since the new regulations took effect. I did not expect that it was a widely unnoticed item in the energy efficiency world. 
    The cost of changing out a full system to 410A vs just the condenser unit is huge and thus, has spawned a work-around for the replacement industry. 
    I own apartments and considering the cost of a full new 410A unit with coil and condenser and possibly a complete new line set the difference in cost is incredible if all you really need is a condenser replacement. Think of the other x million apartments in the United States that virtually all have R-22 units installed. The economic impact is incredible to the owner’s bottom lines.  
    Back when the regulations were announced and put in place, I predicted that owners would struggle and some properties fail because of the requirements of the new regulations…………until I began to see and understand the Dry-ship workaround. 
    It is a big problem/issue but it is not new and by no means is it a small amount of units being dry-shipped. The consumer/homeowner market may choose the more expensive, long term solution but rental owners and apartment owners rarely will as it is just simple and VERY clear economics. 
    My understanding is that the units are shipped with Nitrogen and the nitrogen is evacuated to add the R-22 upon installation. 

  18. Regarding the NY Times
    Regarding the NY Times article, AHRI fires back: AHRI press release
    For those who want the short version, skip to the 4th paragraph. Essentially, they lay the blame at the foot of the EPA for not prohibiting the manufacture of R22 equipment. Wonder who lobbied the gov’t for that? Methinks the “industry” speaks with more than one voice.

  19. It appears that short term
    It appears that short term economic gain again is overuling the long term benefit to soceity. The cost saving of dry shipping an R22 machine over using an R410a equivalent appears to be externalised in the form of health bills related to the additional exposure to UV radiation and increase in rates of skin cancer.  
    Following this from the UK I noted a recent guardian article mentioned a recent ozone hole over the artic. The article in the first paragraph states there was no man made link but futher on reasons that CFCs were responsible. 
    It appears that what the Montreal Protocol was built to save is failing due to a quick dollar and lax enforcement.

  20. Allison thank you for opening
    Allison thank you for opening the horizon of many individuals and for allowing us to share our own insights about R-22! The environment owed you a lot for showing others the importance of choosing the proper air conditioner. R-22 is good in terms of its price according to my neighbors but they cannot see that it is more costly because of the damage the ozone layer can cause to our lives. The old air conditioner is also harmful to the ozone layer because of its huge energy consumption. The air conditioner is also in need of frequent cleaning. Based on my experience air conditioner with proper maintenance last longer and save much energy. That is why I keep on monitoring it through the assistance of Las Vegas ac repair. Now I am paying almost only a half of my old bills.  

  21. Most of these posts, if not
    Most of these posts, if not all, refer to a residential market. A homeowner upgrading now would be a fool to attach a dry-shipped R-22 condenser to his existing airhandler if the original system is out of warranty. A compressor or other major component change would be the only R-22 choice. 
    However, in commercial and institutional environments, with split sytems from 7.5 tons and up connected by 200+ foot linesets, switching to R-410A is not possible without major structural renovations. I have 7.5, up to 60 ton dx coil air handling stations that are built into the building. I’m not going to go as far as to say changeout is impossible, but nearly so, especially with the interconnecting lineset which MUST be changed no matter who tells you it doesn’t. I install various combinations of Goodman 460 vol, 3 phase, 7.5 to 10 ton straight cool, or heatpump condensers directly to the existing lineset and air handling units. One BIG difference-NO R-22 is used following the installation. I convert these to one of the inexpensive R-22 “drop-in” replacements. Currently I use MO-99 (R-438A)which has very near the same operating caracteristics as R-22, and requires only a liquid drier change, something only a careless technician would not do anyway. I only pray these dry-shipped R-22 units continue to be available. I have heard the residential sized units, under 5 tons will be phased out. From reading these various tech inputs,I know the concern is legitimate when discussing residential equipment. But please consider the enormous impact a loss of R-22 equipment will mean to commercial buildings, schools, universities and manufacturing plants. Let’s support Goodman in their effort, not to circumvent the law, but to provide a viable alternative to costly conversions. 
    One last reminder: Use R-22 to top off systems only! This will help preserve supply for a few more years. Switch to a “drop-in” replacement such as MO-99 whenever repairs require evacuation of R-22. And no, I am not on the Dupont staff.

  22. This is quickly becoming a
    This is quickly becoming a non-issue. With R22 gas at $500 for a 30# jug the cost to fill a dry unit just went way up and so did servicing that leaking old R22 unit. Customers are the ones getting stuck. Even a compressor changeout on an R22 system under warranty is killing the customer who still has to pay for labor and the Freon! Many systems take 7 to 10 pounds of R22. At a competitive rate of $90 per pound for R22 vs. $55 for 410 it can push someone over to a new system faster than you think. 
    All that said…I do feel terrible for people that cannot afford new systems or will not see value in a new system (many Elderly customers) have to take it on the chin. All of us in the HVAC business are getting a black eye over this crazy R22 Freon pricing! 
    More rules and regulation will not help the global enviroment and all it does is hurt those that can’t afford to “swap over”. Many of your post are so one sided it makes me sick. You sound as though the price of a $1200 condenser or a $5000 changeout is like saying Burger King or Outback! 
    Some people do not HAVE a choice. Some are like our government in that they never saved for a new roof or new HVAC system. They do not have the money so they have to finance it or go without.

  23. These dry units are great.
    These dry units are great. People must under stand that there are other refrigerants to use that replace r22 and are as affordable as the 410a. These units provide options . Lets say some one has a newer r22 system thats just out side of warranty and it lost the compresser. The customer had limited funds to work with . Instead of selling him a compressor for 1700 and only has a year warranty . You sell them a condenser for the same price and they get a five year warranty . Most manufactures offer five year compresser and parts warranties if they are name brand. Besides r22 and replacement refrigerants will be around well past 2020.

  24. I live in a multi-story condo
    I live in a multi-story condo building where the heat pump for each unit is on the flat roof, and the refrigerant lines run down through the roof inside the interior walls of the building. The lines are soldered rather than brazed, which is fine for R-22, but often results in refrigerant leaks or complete blowouts if the old lines are flushed and re-used with R410A at the much higher pressures that 410A requires. Running new, brazed refrigerant lines in a building like this would be a costly, destructive, chaotic nightmare, especially since every owner owns and is responsible for their own HVAC system. Dry R-22 units are a must for buildings like this, and there are already ozone-safe drop-in replacement refrigerants that can be used in R-22 equipment after the supply of R-22 is finally gone.

  25. Even 2 years after this was
    Even 2 years after this was published, I received a quote yesterday to install a brand new R-22 Goodman system on my house which has never had central air. I was surprised when I received the quote because the price was in line with what I expected, but I had no idea a dealer would spec an R-22 system with a 5 year warranty (vs 10 with R-410a). I talked to him on the phone and he should have realized that I have a clue about what’s going on but no discussion of refrigerant type happened because I didn’t think it was necessary. After I received the quote, I emailed the guy back saying I didn’t want an R-22 system so we’ll see what he comes back with for R-410a pricing. The positive about this dealer was that he said 2 tons would be too much for my well insulated 1000 sq. foot ranch while two other companies spec’d 2 ton R-410a systems without a second thought. (I’m going to be doing a manual J myself with HVAC Calc to confirm that 2 tons is too much.) 
    Either way, it’s amazing that the loophole still exists. I wonder if they’ll be selling dry R-22 equipment until 2020?

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