During an audit, someone asks a simple question:

“Which refrigerant is used in this chiller?”

Maintenance says it may be R-22.

Procurement says refrigerant is handled by the HVAC contractor.

Stores has a few cylinders, but the labels are not clear.

EHS has service invoices, but no equipment-wise refrigerant record.

This is where ODS compliance usually begins.

Not with a complicated legal issue. With a simple information gap inside the plant.

The Ozone-Depleting Substances Rules, 2000 are often treated as rules relevant only to refrigerant manufacturers, chemical companies and importers.

However, ozone-depleting substances may still be present inside:

• Old chillers
• Cold rooms
• Process-cooling systems
• Refrigeration equipment
• Special fire-suppression systems
• Foam and insulation systems
• Older imported machinery

The important point is simple.

The restriction on manufacturing new HCFC-based equipment from 1 January 2025 does not automatically make every existing R-22 chiller illegal.

At the same time, plants should not ignore old HCFC equipment.

They should identify the refrigerant, investigate repeated gas top-ups, check contractor practices and prepare a practical replacement plan.

What Are Ozone-Depleting Substances?

Ozone-depleting substances, commonly called ODS, are chemicals that can damage the ozone layer when released into the atmosphere.

The ozone layer protects life on Earth by absorbing a large portion of harmful ultraviolet radiation from the sun.

Several chemicals once widely used in refrigeration, air-conditioning, fire protection, foam manufacturing, fumigation and industrial cleaning were later found to damage this protective layer.

The Ozone-Depleting Substances (Regulation and Control) Rules, 2000 control the production, import, export, sale, purchase, consumption and specified uses of these substances in India.

The Rules were notified under the Environment (Protection) Act, 1986 as part of India’s implementation of the Montreal Protocol.

Read more about Environmental Laws in India (Complete Guide)

Which Ozone-Depleting Substances May Be Found in Industry?

Most factories do not manufacture these chemicals.

However, they may still be present in old equipment, old cylinders, imported machines or specialised systems.

Where Can ODS Be Present Inside a Plant?

Do not limit the review to office air conditioners.

Refrigeration and Air-Conditioning Equipment

Check:

• Central air-conditioning plants
• Water-cooled and air-cooled chillers
• Cold rooms
• Freezers
• Refrigerated warehouses
• Process chillers
• Laboratory cooling systems
• Refrigerated dryers
• Older window and split air conditioners
• Imported equipment with built-in cooling systems

Fire-Suppression Systems

Some older specialised fire systems may contain halons.

These may be found in:

• Old control rooms
• Data rooms
• Aviation-related facilities
• Defence-related installations
• Special electrical installations
• Older imported fire-suppression systems

Do not assume that every fire extinguisher contains an ozone-depleting chemical.

Normal water, foam, dry chemical powder and carbon-dioxide extinguishers should not be classified as ODS equipment without checking the actual extinguishing agent.

Confirm the agent from:

• Cylinder labels
• System drawings
• Manufacturer documents
• Service reports
• Contractor confirmation

Foam and Insulation Systems

ODS may historically have been used in:

• Polyurethane foam
• Cold-room panels
• Sandwich panels
• Pre-insulated pipelines
• Appliance insulation
• Foam-filled doors
• Building insulation

Old Cleaning and Solvent Applications

Some older processes may have used controlled substances for:

• Metal degreasing
• Precision cleaning
• Electronics cleaning
• Laboratory work
• Chemical processing

Old containers can remain unnoticed when only a trade name is written on the label.

What Changed on 1 January 2025?

From 1 January 2025, HCFCs cannot be used in the manufacture of new equipment covered by the phase-out schedule introduced through the 2014 Amendment Rules.

This may affect manufacturers of:

• Air-conditioning units
• Refrigeration equipment
• Chillers
• Cold-chain equipment
• Process-cooling systems
• Other HCFC-dependent equipment

The date was not introduced through a new rule in 2025.

It had already been prescribed through the 2014 Amendment Rules.

Our LinkedIn Post explaining Ozone Depleting Substances (Regulation and Control) Rules, 2000

Is an Existing R-22 Chiller Illegal After 1 January 2025?

The 1 January 2025 restriction does not automatically stop an existing R-22 or HCFC-22 chiller from operating.

The practical position is:

An old R-22 chiller does not need to be shut down only because the calendar crossed 1 January 2025.

However, the plant should know:

• How old the equipment is
• How much refrigerant it contains
• How often gas is added
• Where leakage is occurring
• Whether spare parts are available
• Whether competent technicians are available
• Whether retrofit is technically possible
• When replacement should be planned

This is an asset-management issue as much as an environmental issue.

India’s HCFC Phase-Out Schedule

India is reducing HCFC production and consumption in stages.

The limited servicing tail after 2030 should not be understood as normal or unrestricted HCFC availability until 2040.

It is a restricted provision for eligible servicing needs.

Plants should not plan long-term operations on the assumption that R-22 will remain easily available and affordable.

What Happened to HCFC-141b?

HCFC-141b was widely used as a foam-blowing agent.

India completed its phase-out in the foam sector from 1 January 2020.

Import licences for HCFC-141b were also prohibited from that date under the 2019 Amendment Rules.

This is relevant to:

• Polyurethane foam manufacturers
• Cold-room panel manufacturers
• Insulation manufacturers
• Appliance manufacturers
• Sandwich-panel manufacturers
• Chemical formulators
• Refrigeration equipment manufacturers

Even factories that do not directly handle HCFC-141b may encounter the transition through suppliers of insulation materials, cold-room panels and foam products.

Read more about Chemical Accidents Rules, 1996: A Practical Guide for Indian EHS Officers

A Five-Step ODS Review for an Operating Plant

Step 1: Prepare an Equipment Inventory

List every machine or system that may contain a refrigerant, foam-blowing chemical or specialised fire-suppression agent.

Record at least:

• Equipment identification number
• Department
• Location
• Equipment type
• Manufacturer
• Model
• Year of manufacture
• Year of installation
• Rated refrigerant charge
• Actual refrigerant used
• Current operating status
• Service contractor

Do not depend only on memory.

Verify the details from:

• Nameplates
• Equipment manuals
• Compressor labels
• Service reports
• Refrigerant cylinders
• Purchase invoices
• Contractor records

In many plants, the equipment nameplate says R-22, but the latest service report only says “gas charging – 18 kg.”

There is no leak location, no recovery quantity and no record of what happened to the old refrigerant.

During an audit, this information gap creates more questions than the presence of the old equipment itself.

Step 2: Identify the Exact Refrigerant

Descriptions such as “AC gas,” “Freon,” “cooling gas” or “fire gas” are not enough.

Record the actual refrigerant or chemical designation.

Examples include:

• R-22
• R-123
• R-134a
• R-404A
• R-407C
• R-410A
• R-32
• Ammonia
• Carbon dioxide
• Specific halon type, where applicable

Trade names can create confusion because one brand family may contain different chemicals.

Always confirm the chemical designation.

Step 3: Classify the Refrigerant Correctly

Each refrigerant should be checked for:

• Ozone-depletion potential
• Global-warming potential
• Flammability
• Toxicity
• Operating pressure
• Equipment compatibility
• Safety requirements
• Future regulatory direction

This prevents one common mistake.

A plant may replace an ozone-depleting refrigerant with another refrigerant that creates a future climate, safety or engineering problem.

Step 4: Track Refrigerant Movement

Maintain an equipment-wise refrigerant register.

Also record:

• Opening cylinder stock
• Quantity purchased
• Quantity issued
• Quantity returned
• Quantity recovered
• Quantity reused
• Quantity sent for reclamation
• Equipment decommissioned
• Leak location
• Corrective action
• Closing cylinder stock

A controlled spreadsheet reviewed every month is often enough to identify repeated leaks and unexplained consumption.

The purpose is not to create paperwork.

The purpose is to know where the refrigerant went.

Step 5: Prepare an Equipment-Transition Plan

Not every old HCFC asset needs to be replaced immediately.

Replacement priority should be based on actual plant conditions.

A planned replacement is usually easier than an emergency replacement after a compressor failure during peak production.

Refrigerant Top-Ups Are Not Normal Consumption

In many plants, refrigerant top-up is recorded like grease, oil or filters.

This is not the right way to understand it.

A refrigeration system is normally a closed system.

Refrigerant should not be repeatedly consumed like diesel or furnace oil.

Small losses may happen during repairs, component replacement or servicing. However, repeated top-ups need investigation.

Refrigerant loss may occur because of:

• Leakage during operation
• Poor-quality joints
• Damaged seals
• Corroded coils
• Release during servicing
• Incomplete recovery
• Component replacement
• Incorrect charging
• Unrecorded handling

Whenever gas is added, ask two questions:

1. Where did the earlier refrigerant go?
2. What repair was completed before fresh refrigerant was added?

A top-up entry should be treated as:

• An equipment-health signal
• A possible leakage indicator
• An environmental performance indicator
• A maintenance-control issue

One top-up does not automatically prove non-compliance.

But repeated top-ups without investigation should not be accepted as routine maintenance.

What Should Plants Check During HVAC Servicing?

EHS and utilities teams should occasionally observe actual servicing work.

Do not depend only on the final invoice.

Ask the contractor:

• Which refrigerant is present?
• What was the equipment condition before servicing?
• How much refrigerant was recovered?
• What recovery equipment was used?
• Was the recovered refrigerant reused?
• Was it returned or sent for reclamation?
• How much fresh refrigerant was charged?
• Where was the leak found?
• Was the leak repaired before charging?
• Was pressure testing completed?
• Was proper vacuum maintained?
• What happened to refrigerant remaining in the cylinder?

The service report should clearly show:

• Quantity recovered
• Quantity reused
• Quantity returned
• Quantity sent for reclamation
• Quantity newly charged
• Leak location
• Repair completed

The contractor performs the technical work.

The plant still needs visibility over what chemical was handled, how much was used and what corrective work was completed.

Who Should Be Involved in ODS Management?

ODS management should not remain only with EHS.

A common pattern is:

Procurement buys the refrigerant.

Stores receives the cylinder.

Maintenance gives it to the contractor.

The contractor charges the system.

Finance clears the invoice.

EHS sees the record only during an audit.

A common refrigerant register connects these activities.

Can an HCFC System Be Converted to Another Refrigerant?

Possibly.

But changing the refrigerant is an engineering modification. It is not simply a gas replacement.

The change may affect:

• Compressor compatibility
• Lubricating oil
• Seals and gaskets
• System pressure
• Cooling capacity
• Heat exchangers
• Expansion devices
• Electrical safety
• Flammability
• Toxicity
• Control settings
• Warranty
• Energy consumption

Some low-global-warming refrigerants are flammable.

Ammonia can be suitable for many industrial applications, but it requires proper design, ventilation, leak detection and emergency controls.

Carbon dioxide systems may operate at much higher pressures than conventional systems.

Be careful with claims such as “direct replacement” or “drop-in gas.”

Compatibility should be confirmed for the specific equipment by a competent refrigeration professional.

ODS and HFCs Are Not the Same

This distinction is important when selecting replacement equipment.

CFCs and HCFCs

CFCs and HCFCs can damage the ozone layer.

Their ozone impact is commonly measured through ozone-depletion potential.

HFCs

HFCs generally do not damage the ozone layer.

However, many HFCs have high global-warming potential.

They are being phased down internationally under the Kigali Amendment.

India’s HFC baseline is calculated using average production and consumption during 2024, 2025 and 2026.

India’s scheduled pathway is:

This means a refrigerant may have zero ozone-depletion potential but still have a high climate impact.

Do not replace an old HCFC machine only by checking whether the new refrigerant has zero ODP.

Also check:

• Global-warming potential
• Energy efficiency
• Safety class
• Future availability
• Equipment life
• Technician capability

Otherwise, the plant may solve today’s ozone issue and create another replacement problem later.

How Should a Plant Select a Replacement Refrigerant?

There is no single refrigerant suitable for every plant.

The selection should consider:

• Ozone-depletion potential
• Global-warming potential
• Energy efficiency
• Refrigerant availability
• Flammability
• Toxicity
• Operating pressure
• Equipment compatibility
• Technician capability
• Initial cost
• Lifecycle cost
• Required temperature
• Process criticality
• Plant layout
• Emergency preparedness
• Future regulatory direction

A pharmaceutical cold room, an office air-conditioning system and a large dairy refrigeration plant may need completely different solutions.

The objective is not to promote one refrigerant.

The objective is to make the next equipment purchase with a longer-term view.

What Records Should an Operating Plant Keep?

Even when a normal equipment owner does not have the same reporting requirements as a producer or importer, internal records are still useful.

Equipment Records

• Equipment master list
• Nameplate photographs
• Refrigerant type
• Rated refrigerant charge
• Installation date
• Current condition

Procurement Records

• Purchase invoices
• Supplier details
• Cylinder identification
• Quantity received
• Safety data sheet
• Product specification

Maintenance Records

• Service reports
• Quantity recovered
• Quantity charged
• Leak location
• Repairs completed
• Pressure-test details
• Vacuum details
• Technician details

Inventory Records

• Opening stock
• Purchases
• Issues
• Returns
• Recovered refrigerant
• Reused refrigerant
• Reclaimed quantity
• Closing stock

Decommissioning Records

• Equipment decommissioning report
• Refrigerant recovery record
• Cylinder return record
• Reclamation or disposal evidence
• Scrap handover documents

Project Records

• Alternative refrigerant assessment
• Safety review
• Energy comparison
• Capital approval
• Replacement schedule

These records can support:

• Environmental audits
• ISO 14001 audits
• Engineering reviews
• Insurance inspections
• Contractor evaluations
• ESG data collection
• Equipment-replacement decisions

Who May Need Registration or Formal Reporting?

Formal obligations depend on what the organisation actually does.

A closer review may be needed where the organisation:

• Produces a controlled substance
• Imports or exports refrigerants
• Sells or distributes controlled substances
• Purchases ODS for specified industrial use
• Manufactures equipment using controlled substances
• Uses controlled substances in foam or solvent applications
• Undertakes reclamation or destruction
• Handles ODS under an exemption
• Imports pre-charged equipment
• Operates in a sector specifically covered by the Rules

An ordinary factory operating old air-conditioning equipment may have different obligations from an importer, refrigerant seller or equipment manufacturer.

Check the current requirement based on the actual substance, quantity and activity undertaken.

Common Misunderstandings in Indian Plants

“We do not manufacture refrigerants, so the Rules do not concern us.”

Not always.

The plant may still purchase, store, use or operate equipment containing controlled substances.

Even where formal registration does not apply, refrigerant management is still important.

“Every R-22 machine became illegal from 1 January 2025.”

No.

The restriction concerns the use of HCFCs in manufacturing new equipment.

Existing equipment is not automatically prohibited by that specific restriction.

“We can run the old chiller until 2040 without concern.”

This is also incorrect.

The official schedule reaches 100% reduction in 2030, followed by only a limited servicing tail.

Availability, servicing capability and cost may become more uncertain.

“HFC refrigerants are completely environmentally safe.”

HFCs generally do not damage the ozone layer.

However, several HFCs have high global-warming potential.

“The HVAC contractor handles everything.”

The contractor performs the technical service.

The plant should still know:

• Which refrigerant is used
• How much was recovered
• How much was added
• Where leakage occurred
• What repair was completed

“Refrigerant top-up is normal maintenance.”

Repeated top-ups normally indicate refrigerant loss.

The reason should be identified and recorded.

“Any low-GWP refrigerant can replace R-22.”

Not without a technical assessment.

Pressure, flammability, toxicity, oil, seals, compressor compatibility and system controls may be different.

Practical ODS Checklist for Indian Plants

Check whether your plant can answer these questions:

• Do we know every refrigerant used at the site?
• Do we know which equipment contains HCFCs?
• Do we know the rated refrigerant charge of major equipment?
• Are refrigerant additions recorded equipment-wise?
• Is every repeated top-up linked to a leak investigation?
• Does the contractor use recovery equipment where applicable?
• Is recovered refrigerant properly accounted for?
• Are refrigerant cylinders controlled through stores?
• Have old fire-suppression systems been checked for halons?
• Do project specifications prevent the purchase of obsolete technology?
• Are new systems checked for ozone impact and climate impact?
• Do we have a replacement plan for ageing HCFC equipment?
• Are EHS, maintenance, projects, stores and procurement using the same information?

If several answers are unclear, the plant may not yet have a refrigerant failure.

But it does have an information gap.

That is the right place to start.

Frequently Asked Questions

What are the Ozone-Depleting Substances Rules, 2000?

These are Indian environmental rules that control the production, import, export, sale, purchase, consumption and specified uses of substances that damage the ozone layer.

Is R-22 an ozone-depleting substance?

Yes.

R-22, also called HCFC-22, is an ozone-depleting substance covered under India’s HCFC phase-out framework.

Is it illegal to operate an R-22 chiller after 1 January 2025?

The restriction from 1 January 2025 concerns manufacturing new equipment using HCFCs.

It does not automatically prohibit every R-22 chiller installed earlier.

However, leakage, service records and replacement planning should be properly managed.

Can a plant still purchase R-22 for servicing?

Servicing of existing equipment forms part of the controlled HCFC phase-out system.

Availability is affected by production, import, consumption and quota controls.

Plants should purchase refrigerant through proper channels and keep clear purchase and usage records.

Does the 2040 date mean HCFCs will remain freely available?

No.

India’s schedule reaches 100% reduction in 2030.

Only a limited servicing tail is provided during 2030–2040.

It should not be understood as unrestricted supply.

Are HFCs ozone-depleting substances?

HFCs generally do not damage the ozone layer.

However, many have high global-warming potential and are covered under the Kigali Amendment phase-down.

Should every HCFC chiller be replaced immediately?

Not necessarily.

Replacement should be prioritised based on:

• Equipment age
• Leakage history
• Energy consumption
• Reliability
• Refrigerant availability
• Process importance
• Safety
• Replacement cost

Can an existing chiller be retrofitted?

It may be possible.

However, the alternative refrigerant must be checked for compressor compatibility, oil, seals, pressure, cooling capacity, controls and safety.

What should EHS ask the HVAC contractor?

Ask for:

• Refrigerant identification
• Quantity recovered
• Quantity charged
• Leak location
• Repairs completed
• Recovery method
• Pressure-test details
• Destination of recovered refrigerant
• Updated service record

Does every factory need registration under the ODS Rules?

Not necessarily.

Registration and reporting depend on the substance, activity, quantity and regulatory category.

A producer, importer, seller or specified industrial user may have different obligations from an ordinary equipment operator.

The Practical Lesson

Do not panic only because an old R-22 machine is still operating.

First identify the refrigerant.

Then check leakage, service records, equipment condition and remaining useful life.

The real issue is not always the old machine.

The bigger issue is operating it without knowing:

• What refrigerant is inside
• How much is being lost
• Why repeated top-ups are happening
• What the contractor is doing
• When the equipment will be replaced

Good ODS compliance starts with a clear equipment register and consistent maintenance records.

It does not need panic.

It needs visibility, proper servicing and planned replacement.

Regulatory note: This article reflects the Ozone-Depleting Substances (Regulation and Control) Rules, 2000 and the amendment framework listed by the Government of India’s Ozone Cell, including the 2014 and 2019 Amendment Rules, as reviewed in July 2026. Plant-specific requirements should be checked based on the latest Rules, schedules, licences, quota orders, government directions and the actual activity carried out by the facility.

Links:

• Ministry of Environment, Forest and Climate Change
  Ozone-Depleting Substances Rules, 2000
  ODS Amendment Rules, 2014
  Relevant 2019 amendment notification
  Montreal Protocol or UNEP Ozone Secretariat
  India HCFC Phase-out Management Plan documents