HARDI Turns HVACR Distributor Data Into Regulatory Advocacy

A distributor’s perspective carries value because of where the company sits in the supply chain. Distributors see which products contractors purchase, how demand changes across markets, and how equipment transitions unfold. When members share their knowledge through consistent reporting, HARDI can develop a much clearer understanding of the market, which pays dividends for your business and helps stop bad policy before it gets implemented. 

HARDI’s Trends Report provides context through measures that include distributor sales and inventory growth. Our Unitary Market Intelligence Program adds detail about equipment sales by product type, efficiency level, and geography. These tools give participating distributors a broader view of the conditions surrounding their own performance. Their perspective becomes especially valuable when policymakers ask questions about where the industry is headed. We recently had an opportunity to put it to work. 

In August, HARDI submitted comments to the U.S. Environmental Protection Agency (EPA) on the data the agency is using to evaluate which companies receive allocations for HFC production and import. This analysis required technical, number-heavy market information that, as an association, we needed to explain our concerns and voice our recommendations effectively. 

HARDI came prepared with our own all-sector HFC demand model built from available shipment data and assumptions about equipment stock, refrigerant charges, service needs, and the transition to newer refrigerants. The information members share through our programs helped ground that analysis in the market. We then compared our projections with EPA’s. 

The result was substantive. We told EPA that its aggregate demand projections broadly match our independent analysis. Identifying where our analyses agree helps establish common ground and gives us credibility when we get more specific. 

And we did get specific. At the individual refrigerant level, we pointed out where EPA’s estimates ran higher than ours for R-410A, R-454B, and R-32, and we offered possible explanations for the differences. These included how we treat equipment manufactured in one year but installed in the next, along with differing assumptions about market growth, charge size, and service demand. We also identified where our modeling ran higher than EPA’s and we were candid about where our leak-rate assumptions diverge from the agency’s published figures. The value of the historical market perspective becomes even clearer when looking at refrigerant reclamation. 

Another example of how HARDI used market data to inform its comments to EPA involves refrigerant reclamation. EPA data show rising R-410A reclamation volumes, and it’s easy to read that as proof that recovery practices are improving. But our unitary data show that the transition from R-22 to R-410A took place over several years and was largely complete by 2016. Assuming an average equipment life of around 15 years, much of the R-410A now entering the reclamation stream likely comes from systems installed around 2010, when R-410A was rapidly gaining market share, not from a sudden change in contractor behavior around recovery. 

In other words, rising reclamation volumes may reflect the amount of R-410A equipment reaching retirement age, even without an improvement in recovery rates. The decline in R-22 reclamation is consistent with the same shift in retired equipment. None of this analysis could be possible without the participation of members in HARDI’s benchmarking programs. 

Other EPA regulations and analyses assume significant growth in recovered and reclaimed refrigerant. If policymakers misread the trend, they risk building future rules on expectations the market cannot meet. Our market data gave us a basis to raise that concern and recommend that EPA compare reclamation growth with the refrigerant mix in systems being retired. 

For distributors, the practical stakes couldn’t be clearer. The market must supply refrigerants for new equipment while continuing to meet the service needs of systems already installed. Understanding how equipment sales, system retirements, and reclamation interact helps us explain those overlapping needs and ask more precise questions about future refrigerant supply. 

Our members’ participation helped us assess EPA’s projections, explain market trends, and identify questions deserving further research. It gives our advocacy team evidence to return to as the agency develops its next allocation rule, supporting our goal of creating a meaningful return on investment for the time our members spend reporting. 

The value of participation therefore continues well beyond the next benchmarking report. Every time a member submits data to a HARDI program, they contribute to a body of market intelligence built from distributors’ collective experience across products, regions, and years. 

To the members already participating, thank you. You provide the industry with much-needed market understanding while giving yourself a leg up in evaluating your business’s performance. 

If your company isn’t yet participating, consider what you are missing. Participants see how they stack up against the market and gain insights to run their businesses better. They also contribute data that helps Washington understand our industry and informs decisions that can affect your inventory, margins, and customers. 

Talk with HARDI’s Market Intelligence team about the benchmarking programs that fit your business and what participation requires. Information already moving through your company can help you understand your market more clearly and help HARDI ensure policymakers understand it, too.