Title VI of the Clean Air Act and NRER Program

Title VI of the Clean Air Act represents the primary regulatory authority to control HFCs, which includes the commitments in the Montreal Protocol. Title VI requires EPA to develop programs that protect the stratospheric ozone layer. Section 608 at 42 USC §§ 7671 – 7671q. 42 USC §7671g establishes to NRER program, under which EPA has established several regulations related to HFCs. For example, EPA has published a final rule extending refrigerant management requirements to the various substitutes for ozone-depleting chemicals that industry has transitioned to, including HFCs (81 Fed. Reg. 82272).