ZPMC North America Inc. (Board decision, November 17, 2025)
In re ZPMC North America Inc. (EAB CAA Appeal No. 25-12C): HFC import settlement approved
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Plain-English summary
ZPMC North America Inc. imported 202 kilograms of HFC-227ea, a regulated hydrofluorocarbon, through the Port of Newark in July 2025. EPA alleged that ZPMC imported the bulk substance without expending the required allowances and failed to submit an advance notification report. ZPMC agreed to the settlement, waived its right to contest the allegations and appeal the Final Order, and certified corrective action involving export of the HFCs. The EAB ratified the agreement and ordered ZPMC to pay an $8,048 civil penalty.
Decision snapshot
- Cited authorities: AIM Act; Clean Air Act § 113; 40 C.F.R. parts 13, 22, and 84; 42 U.S.C. §§ 7413 and 7675
- Outcome: The Expedited Settlement Agreement was ratified, and ZPMC was ordered to pay an $8,048 civil penalty and comply with the agreement.
- Key point: Importers of bulk regulated substances must satisfy the allowance and advance-reporting requirements that apply to the shipment.
Full text (EPA EAB public release)
F I L E D
Nov 17, 2025
Clerk, Environmental Appeals Board
INITIALS ______
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
)
In re ZPMC North America Inc. ) Docket No. CAA-2026-8722
)
)
)
)
FINAL ORDER
Decided November 17, 2025
Before Environmental Appeals Judges Aaron P. Avila and Ammie Roseman-Orr
Order of the Board by Judge Avila:
Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice Governing
the Administrative Assessment of Penalties and the Revocation/Termination or Suspension of Permits, the attached Expedited Settlement Agreement resolving this matter is incorporated by reference into this Final Order and is hereby ratified.
The Respondent is ORDERED to comply with all terms of the Expedited Settlement
Agreement, effective immediately.
So ordered.
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ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C
)
In re: ) Docket No. CAA 2026-8722
)
ZPMC North America Inc. )
)
)
)
EXPEDITED SETTLEMENT AGREEMENT
A. JURISDICTION
-
This is an expedited administrative penalty assessment proceeding brought for alleged
violations of the American Innovation and Manufacturing Act of 2020 (“AIM Act”), 42 U.S.C. § 7675, which governs the import of hydrofluorocarbons (“HFCs”). This proceeding is brought under Section 113(d) of the Clean Air Act (“CAA”), 42 U.S.C. § 7413(d), which authorizes the United States Environmental Protection Agency (“EPA”) to bring administrative civil enforcement actions. -
This expedited settlement agreement (“Agreement”) is entered into under Section 113(d) of
the CAA, as amended, 42 U.S.C. § 7413(d), and the Consolidated Rules of Practice Governing the Administrative Assessment of Penalties and the Revocation/Termination or Suspension of Permits, 40 C.F.R. Part 22. -
Complainant is the United States Environmental Protection Agency. On the EPA’s behalf,
Acting Director, Sparsh S. Khandeshi, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the CAA. -
Respondent is ZPMC North America Inc. (“ZPMC”) and is a “person” as defined below and
identified further in Table 1 of the Expedited Settlement Agreement (“ESA”) Attachment 1. -
Complainant and Respondent (together, the “Parties”), having agreed that settlement of this
action is in the public interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this expedited settlement agreement before taking testimony and without adjudication of any issues of law or fact herein, and Respondent agrees to comply with the terms of this Agreement and Final Order. -
The Environmental Appeals Board is authorized to ratify this Agreement, which
memorializes a settlement between Complainant and Respondent. 40 C.F.R. §§ 22.4(b) and 22.18(b).
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-
The ratification of the Final Order, incorporating this Agreement, simultaneously commences
and concludes this proceeding. 40 C.F.R. § 22.13(b).B. GOVERNING LAW -
This proceeding arises under the AIM Act, 42 U.S.C. § 7675, and Section 113 of the CAA,
42 U.S.C. § 7413, and the regulations promulgated thereunder, which impose limits on HFC production and consumption. -
The EPA is authorized to enforce the AIM Act and any regulation promulgated thereunder
pursuant to the federal enforcement authorities established by Section 113(a) of the CAA, 42 U.S.C. § 7675(k)(1)(C). -
The EPA regulations at 40 C.F.R. Part 84, Subpart A, implement the AIM Act requirement to
phase down HFC production and consumption. -
The regulations at 40 C.F.R. Part 84, Subpart A, apply to any person who imports a regulated
substance. 40 C.F.R. § 84.1(b). -
40 C.F.R. § 84.5(b)(1) states that “[n]o person may import bulk regulated substances, either
as a single component or a multicomponent substance, except . . . [i]f the importer of record
possesses at the time they are required to submit reports to EPA pursuant to § 84.31(c)(7),
and expends at the time of ship berthing for vessel arrivals, border crossing for land arrivals
such as trucks, rails, and autos, and first point of terminus in U.S. jurisdiction for arrivals via
air, consumption or application-specific allowances in a quantity equal to the exchange-value
weighted equivalent of the regulated substances imported, whether present as a single
component or a multicomponent blend.” -
The regulations at 40 C.F.R. § 84.5(b)(7) state that “every kilogram of bulk regulated
substances imported … constitutes a separate violation of this subpart.” -
Pursuant to 40 C.F.R. § 84.31(a), “any person who … imports, … regulated substances” must
comply with specified reporting requirements. -
The regulations at 40 C.F.R. § 84.31(c)(7) provide that the importer of record of imported
regulated substances must submit an advance notification report for each shipment of
regulated substances imported no later than 10 days prior to the date of importation if
arriving by marine vessel and no later than 5 days if arriving by non-marine vessel.
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- The definitions, listed at 40 C.F.R. Part 84, Subpart A, include:
a) An “allowance” is defined as a “limited authorization for the production or consumption
of a regulated substance established under subsection (e) of Section 103 in Division S,
Innovation for the Environment, of the Consolidated Appropriations Act, 2021 (Pub. L.
116-260) (the AIM Act). An allowance allocated under subsection (e) of Section 103 in
Division S of the AIM Act does not constitute a property right.” 40 C.F.R. § 84.3.
b) An “application-specific allowance” is defined as “a limited authorization granted in
accordance with subsection (e)(4)(B)(iv) of the AIM Act for the production or import of a
regulated substance for use in the specifically identified applications that are listed in that
subsection and in accordance with the restrictions contained at § 84.5(c).” 40 C.F.R.
§ 84.3.
c) “Bulk” is defined as “a regulated substance of any amount that is in a container for the
transportation or storage of that substance such as cylinders, drums, ISO tanks, and small
cans. A regulated substance that must first be transferred from a container to another
container, vessel, or piece of equipment in order to realize its intended use is a bulk
substance. A regulated substance contained in a manufactured product such as an
appliance, an aerosol can, or a foam is not a bulk substance.” 40 C.F.R. § 84.3.
d) “Consumption allowances” are “a limited authorization to produce and import regulated
substances; however, consumption allowances may be used to produce regulated
substances only in conjunction with production allowances.” 40 C.F.R. § 84.3.
e) “Exchange value” is defined as the “value assigned to a regulated substance in
accordance with AIM Act subsections (c) and (e), as applicable, and as provided in
Appendix A to 40 C.F.R. Part 84.” 40 C.F.R. § 84.3.
f) “Exchange value equivalent” is defined as “the exchange value-weighted amount of a
regulated substance obtained by multiplying the mass of a regulated substance by the
exchange value of that substance.” 40 C.F.R. § 84.3.
g) “Import” is defined as “to land on, bring into, or introduce into, or attempt to land on,
bring into, or introduce into, any place subject to the jurisdiction of the United States,
regardless of whether that landing, bringing, or introduction constitutes an importation
within the meaning of the customs laws of the United States. Offloading used regulated
substances recovered from equipment aboard a marine vessel, aircraft, or other aerospace
vehicle during servicing is not considered an import.” 40 C.F.R. § 84.3.
h) “Importer” is defined as “any person who imports a regulated substance into the United
States. ‘Importer’ includes the person primarily liable for the payment of any duties on
the merchandise or an authorized agent acting on his or her behalf. The term also
includes: (1) [t]he consignee; (2) [t]he importer of record; (3) [t]he actual owner; or (4)
[t]he transferee, if the right to draw merchandise in a bonded warehouse has been
transferred.” 40 C.F.R. § 84.3.
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i) “Person” is defined as “any individual or legal entity, including an individual,
corporation, partnership, association; state, municipality, political subdivision of a state,
Indian tribe; any agency, department, or instrumentality of the United States; and any
officer, agent, or employee thereof.” 40 C.F.R. § 84.3.
j) “Regulated substance” is defined as “a hydrofluorocarbon listed in the table contained in
subsection (c)(1) of the AIM Act and a substance included as a regulated substance by
the Administrator under the authority granted in subsection (c)(3).” 40 C.F.R. § 84.3.
-
A current list of regulated substances, their chemical formulas, and their exchange values can
be found in Appendix A to 40 C.F.R. Part 84. See 40 C.F.R. § 84.3. -
Pursuant to 40 C.F.R. § 84.5(b)(3), “[e]ach person meeting the definition of importer for a
particular regulated substance import transaction is jointly and severally liable for a violation
of paragraph (b)(1) of this section, unless they can demonstrate that the importer of record
possessed and expended allowances in accordance with the requirement outlined in
paragraph (b)(1)(i) or (v) of this section or another party who meets the definition of an
importer met one of the exceptions set forth in paragraphs (b)(1)(ii) through (iv) of this
section.” -
The exchange value of a blend is calculated by summing the exchange value of each
constituent of the blend multiplied by the nominal mass fraction of the constituent within that
blend. 40 C.F.R. § 84.64. -
The HFC at issue in this matter is assigned the following exchange value:
HFC Chemical Formula or Blends Exchange Value
HFC-227ea CF3CHFCF3 3,220.0 40 C.F.R. Part 84, Appendix A.C. ALLEGED VIOLATIONS OF LAW -
The EPA alleges that, on or about, July 5, 2025, Respondent violated the prohibition on
importing bulk regulated substances into the United States without expending allowances as
required by 40 C.F.R. § 84.5(b) for the 202 kg of HFC-227ea (“Subject HFCs”) identified in
Table 1 of ESA Attachment 1. -
The EPA alleges Respondent, the importer of record, violated 40 C.F.R. § 84.31(c)(7) by
failing to submit an advance notification report for the Subject HFCs no later than 10 days
prior to importation.
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D. TERMS OF AGREEMENT
-
For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2), Respondent:
a. admits that the EPA has jurisdiction over the subject matter alleged in this
Agreement;
b. admits the facts stipulated in Table 1 of ESA Attachment 1;
c. consents to the assessment of a civil penalty as stated in Table 3 of ESA
Attachment 1 and below;
d. waives any right to contest the alleged violation(s) of law set forth in Section C of
this Agreement; and
e. waives its right to appeal the Final Order accompanying this Agreement. -
By signing this Agreement, Respondent waives any rights or defenses that Respondent has or
may have for this matter to be resolved in federal court, including but not limited to any right
to a jury trial, and waives any right to challenge the lawfulness of the Final Order
accompanying the Expedited Settlement Agreement. -
For the purpose of this proceeding, Respondent:
a. agrees that this Agreement states a claim upon which relief may be granted
against Respondent;
b. acknowledges that this Agreement constitutes an enforcement action for purposes
of considering Respondent’s compliance history in any subsequent enforcement
actions related to the Respondent;
c. certifies that it completed the corrective action as set forth in Table 4 of ESA
Attachment 1;
d. waives its right to request a hearing, any right to contest the allegations in this
Expedited Settlement Agreement and Final Order and its right to appeal this
Expedited Settlement Agreement and Final Order;
e. consents to personal jurisdiction in any action to enforce this Agreement or Final
Order, or both, in an appropriate United States District Court; and
f. waives any rights it may possess at law or in equity to challenge the authority of
the EPA to bring a civil action in an appropriate United States District Court to
compel compliance with the Agreement or Final Order, or both, and to seek an
additional penalty for noncompliance with the Agreement or Final Order and
agrees that federal law shall govern in any such civil action.E. TERMS OF PAYMENT -
Respondent agrees to pay a civil penalty in the amount of $8,048 (“Assessed Penalty”),
which is stated in Table 3 of ESA Attachment 1, within thirty (30) calendar days after the
date the Final Order ratifying this Agreement is filed with the Clerk of the Environmental
Appeals Board (“Filing Date”). Respondent shall pay the Assessed Penalty and any interest,
fees, and other charges due using any method, or combination of appropriate methods, as
provided on the EPA website: https://www.epa.gov/financial/makepayment. However, for
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any payments made after September 30, 2025, and in accordance with the March 25, 2025 Executive Order on Modernizing Payments To and From America’s Bank Account, Respondent shall pay using one of the electronic payment methods listed on EPA’s How to Make a Payment website and will not pay with a paper check. For additional instructions see: https://www.epa.gov/financial/additional-instructions-making-payments-epa.
-
When making a payment, Respondent shall:
a. Identify every payment with Respondent’s name and the docket number of this Agreement, CAA-2026-8722, b. Concurrently with any payment or within 24 hours of any payment, Respondent shall serve proof of such payment (confirmation of electronic payment) to the following persons: Clerk of the Board, Clerk of the Environmental Appeals Board U.S. Environmental Protection Agency, Headquarters 1200 Pennsylvania Avenue, NW Mail Code: 1103M Washington, DC 20460-0001 [email protected] Hallie Lipsey, Attorney-Adviser U.S. Environmental Protection Agency, Headquarters 2.2226 J, William Jefferson Clinton Building South 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Mail Code: 2242A [email protected] and U.S. Environmental Protection Agency Cincinnati Finance Center Via electronic mail to: [email protected] “Proof of payment” means, as applicable confirmation of credit card or debit card payment, or confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to EPA requirements, in the amount due, and identified with the appropriate docket number and Respondent’s name. -
Interest, Charges, and Penalties on Late Payments. Pursuant to 42 U.S.C. § 7413(d)(5), 31
U.S.C. § 3717, 31 C.F.R. § 901.9, and 40 C.F.R. § 13.11, if Respondent fails to timely pay
any portion of the Assessed Penalty per this Agreement, the entire unpaid balance of the
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Assessed Penalty and all accrued interest shall become immediately due and owing, and the EPA is authorized to recover the following amounts.
a. Interest. Interest begins to accrue from the Filing Date. If the Assessed Penalty is
paid in full within thirty (30) days, interest accrued is waived. If the Assessed
Penalty is not paid in full within thirty (30) days, interest will continue to accrue
until any unpaid portion of the Assessed Penalty as well as any interest, penalties,
and other charges are paid in full. Per 42 U.S.C. § 7524(c)(6), interest will be
assessed pursuant to 26 U.S.C. § 6621(a)(2), that is the IRS standard
underpayment rate, equal to the Federal short-term rate plus 3 percentage points.
b. Handling Charges. The United States’ enforcement expenses including, but not
limited to, attorneys’ fees and costs of handling collection.
c. Late Payment Penalty. A ten percent (10%) quarterly non-payment penalty.
-
Late Penalty Actions. In addition to the amounts described in the prior Paragraph, if
Respondent fails to timely pay any portion of the Assessed Penalty per this Agreement, the
EPA may take additional actions. Such actions the EPA may take include, but are not limited
to, the following.a. Refer the debt to a credit reporting agency or a collection agency, pursuant to 40 C.F.R. §§ 13.13 and 13.14. b. Collect the debt by administrative offset (i.e., the withholding of money payable by the United States government to, or held by the United States government for, a person to satisfy the debt the person owes the United States government), which includes, but is not limited to, referral to the Internal Revenue Service for offset against income tax refunds, pursuant to 40 C.F.R. Part 13, Subparts C and H. c. Suspend or revoke Respondent’s licenses or other privileges, or suspend or disqualify Respondent from doing business with the EPA or engaging in programs the EPA sponsors or funds, pursuant to 40 C.F.R. § 13.17. d. Request that the Attorney General bring a civil action in the appropriate district court to enforce the Final Order and recover the full remaining balance of the Assessed Penalty, in addition to interest and the amounts described above, pursuant to 42 U.S.C. § 7413(d)(5). In any such action, the validity, amount, and appropriateness of the Assessed Penalty and Final Order shall not be subject to review. -
Allocation of Payments. Pursuant to 31 C.F.R. § 901.9(f) and 40 C.F.R. § 13.11(d), a partial
payment of debt will be applied first to outstanding handling charges, second to late penalty
charges, third to accrued interest, and last to the principal that is the outstanding Assessed
Penalty amount.
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-
Tax Treatment of Penalties. Pursuant to 26 U.S.C. § 162(f), penalties, interest, and other
charges paid pursuant to this Agreement shall not be deductible for purposes of federal taxes. -
By signing this Agreement, Respondent certifies that the information it has supplied
concerning this matter was at the time of submission true, accurate, and complete for each
such submission, response, and statement. Respondent acknowledges that there are
significant penalties for submitting false or misleading information, including the possibility
of fines and imprisonment for knowing submission of such information, under 18 U.S.C.
§ 1001. -
By signing this Agreement, Respondent acknowledges that this Agreement and Order,
including identifying information such as name, federal tax ID number, mailing and e-mail
address, will be available to the public when the Agreement and Certificate of Service are
filed and uploaded to a searchable database and agrees that this Agreement does not contain
any confidential business information or other personally identifiable information. -
By signing this Agreement, the undersigned representative of Complainant and the
undersigned representative of Respondent each certify that they are fully authorized to
execute and enter into the terms and conditions of this Agreement and has the legal capacity
to bind the party they represent to this Agreement. -
By signing this Agreement, Respondent agrees to acceptance of the Complainant’s: (a)
digital or an original signature on this Agreement; and (b) service of the fully executed
Agreement on the Respondent by mail or electronically by e-mail. Respondent understands
that the mailing or e-mail address may be made public when the Agreement and Certificate
of Service are filed and uploaded to a searchable database. Complainant agrees to acceptance
of the Respondent’s digital or an original signature on this Agreement. -
Each party shall bear its own attorney’s fees, costs, and disbursements incurred in this
proceeding.F. EFFECT OF AGREEMENT AND ATTACHED FINAL ORDER -
In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this Agreement and
Final Order resolves only Respondent's liability for federal civil penalties for the violation(s)
identified in Section C of this Agreement. -
This Agreement constitutes the entire agreement and understanding of the Parties and
supersedes any prior agreements or understandings among the Parties with respect to the
subject matter hereof. -
The terms, conditions, and compliance requirements of this Agreement may not be modified
or amended after it is ratified except upon the written agreement of both parties, and approval
of the Environmental Appeals Board. -
Any violation of this Agreement or Order may result in a civil judicial action for an
injunction, or civil penalties of up to $124,426 per day per violation (with each kilogram a
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separate violation), or both, as provided in Section 113(b)(2) of the Act, 42 U.S.C.
§ 7413(b)(2), as well as criminal sanctions as provided in Section 113(c) of the Act, 42 U.S.C.
§ 7413(c). The EPA may use any information submitted under this Agreement in an
administrative, civil judicial, or criminal action.
-
Nothing in this Agreement shall relieve Respondent of the duty to comply with all applicable
provisions of the Act and other federal, state, or local laws or statutes, nor shall it restrict the
EPA’s authority to seek compliance with any applicable laws or regulations, nor shall it be
construed to be a ruling on, or determination of, any issue related to any federal, state, or
local permit. -
Nothing herein shall be construed to limit the power of the EPA to undertake any action
against Respondent or any person in response to conditions that may present an imminent
and substantial endangerment to the public health, welfare, or the environment. -
The EPA reserves the right to revoke this Agreement and settlement penalty if and to the
extent that the EPA finds, after signing this Agreement, that any information provided by
Respondent was materially false or inaccurate at the time such information was provided to
the EPA, and the EPA reserves the right to assess and collect any and all civil penalties for
any violation described herein. The EPA shall give Respondent notice of its intent to revoke,
which shall not be effective until received by Respondent. -
Respondent and Complainant agree to the Environmental Appeals Board’s issuance of the
attached Final Order ratifying the Agreement.
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The foregoing Agreement In the Matter of ZPMC North America Inc., Docket No. CAA-2026- 8722 is Hereby Stipulated, Agreed, and Approved.
COMPLAINANT:
Digitally signed by
SPARSH SPARSH KHANDESHI
KHANDESHI Date: 2025.10.28
18:08:59 -04'00'
Signature
Sparsh S. Khandeshi, Acting Director
Air Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
10
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The foregoing Agreement In the Matter of ZPMC North America, Inc. Docket No. CAA-2026- 8722, is Hereby Stipulated, Agreed, and Approved.
FOR RESPONDENT:
_____ ______ Signature Date
Printed Name: [illegible] ______
Title: [illegible] ________
Address: [illegible] ___________
Federal Tax Identification Number: [illegible] ____
11
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EXPEDITED SETTLEMENT AGREEMENT ATTACHMENT 1
AMERICAN INNOVATION AND MANUFACTURING ACT
OFFSITE COMPLIANCE MONITORING ACTIVITY OR INSPECTION FACTS, ALLEGED VIOLATIONS, PENALTY, AND CORRECTIVE ACTION FORM
Table 1 – Offsite Compliance Monitoring Activity or Inspection Stipulated Facts Inspection Date: July 28, 2025 Docket Number: CAA-2026-8722 Inspection Location: Port of Entry: Newark, NJ H&M International Transport Shipment ID: 26099584230 700 Belleville Turnpike, Kearny, NJ 07032 Entry Number: 9HX-57807866 Person/Importer Name (“Respondent”): Inspector Name: Jessica Cordasco ZPMC International Inc. Email Address: [email protected] Importer Number: 47-106815800 Respondent Address: Date of Detention or Hold: 2805 McGraw Ave., Irvine, CA 92614 July 28, 2025 Value of Goods: $20,160 Arrival Date: July 5, 2025 Subject Regulated Product(s) and Mass (in MTEVe: 3,220 kg): (“Subject HFCs”) HFC-227ea, 202kg
Did the importer have and expend Container and Quantity: allowances equal to the imported HFCs? Two cylinders containing 101kg each as listed No on import documents Did the importer receive any non-objection notices from the EPA? No
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Table 2 – Description of Alleged Violation(s)
The EPA alleges that:
1) Based on the facts in Table 1, the Subject HFCs are bulk regulated substances that
were imported without the importer expending consumption or application specific
allowances in a quantity equal to the exchange-value weighted equivalent of the
regulated substances imported, in violation of the HFC Allocation regulations at 40
C.F.R. § 84.5(b).
2) ZPMC, as importer of record, failed to submit an advance notification report for the
Subject HFCs no later than 10 days prior to importation, in violation of 40 C.F.R.
§ 84.31(c)(7), for the entry listed in Table 1.
Table 3 – Civil Penalty
Complainant and Respondent agree upon the following civil penalty for settlement purposes: $8,048 where:
HFC Allocation Regulation Calculation: $6,048
Monetary Value of Goods * Percentage Multiplier = Penalty
$20,160 * 30% = $6,048
Reporting Violations Calculation:
Number of Violations * Violation Type Penalty Amount = Penalty 1 * $2,000 (failure to provide HFC advance reporting): $2,000
Violation Type Total
Penalty
Amount
Late advance reporting (40 C.F.R. § 84.31(c)(7)) $1,000 Failure to provide any advance reporting (40 C.F.R. § 84.31(c)(7)) $2,000 Late quarterly reports (40 C.F.R. § 84.31(c)(1)) $2,500 Incomplete or inaccurate quarterly reporting (40 C.F.R. § 84.31(c)(1)) $3,000 Failure to submit quarterly reports (40 C.F.R. § 84.31(c)(1)) $3,500 Late annual reports (40 C.F.R. § 84.33(a); 40 C.F.R. § 84.60(a)) $10,000 Incomplete or inaccurate annual reporting (40 C.F.R. § 84.33(a); 40 $10,000 C.F.R. § 84.60(a)) Failure to submit annual reports (40 C.F.R. § 84.33(a); 40 C.F.R. $15,000
§ 84.60(a))
Failure to maintain records (40 C.F.R. § 98.3(g)) $5,000 Late annual GHG reports (40 C.F.R. § 98.3(b)) $10,000 Incomplete or inaccurate annual GHG reporting (40 C.F.R. § 98.3(b); $10,000 40 C.F.R. § 98.3(h)) Failure to submit annual GHG reports (40 C.F.R. § 98.3(b)) $15,000
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HFC EV1 Percentage HFC EV
Multiplier HFC-152 53
< 1,300 20% HFC-41 92
≥ 1,300 ≤ 5,000 30% HFC-152a 124
> 5,000 ≤ 10,000 40% HFC-143 353
>10,000 ≤ 15,000 50% HFC-32 675
HFC-245ca 693
Percentage HFC-365mfc 794
TT Product GWP2 Multiplier HFC-245fa 1,030
< 1,300 20% HFC-134 1,100
≥ 1,300 ≤ 5,000 30% HFC-236cb 1,340
> 5,000 ≤ 10,000 40% HFC-236ea 1,370
>10,000 ≤ 15,000 50% HFC-134a 1,430
HFC-43-10mee 1,640
ODS Percentage HFC-227ea 3,220
Multiplier HFC-125 3,500
Any ODS listed as a 40% HFC-143a 4,470
class I or class II HFC-236fa 9,810
controlled substance in HFC-23 14,800
40 C.F.R. Part 82,
whether on its own or
in a blend
1 EVs are found in Appendix A of 40 C.F.R. Part 84.
2 Id.
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Table 4 – Corrective Action
Respondent certifies that it:
✓ has exported the Subject HFCs to The Viking Corporation (Far East) PTE LTD,
69 TUAS VIEW SQUARE WESTLINK TECHPARK, SINGAPORE 637621, a country other
than Canada or Mexico, and has paid [illegible] to perform the action to export the
Subject HFCs.
✓ will submit to the EPA at [illegible], within thirty (30) days of the Filing Date of the ESA
a record documenting such payment for export of the Subject HFCs.
Respondent must check the boxes, fill in all relevant blanks, and return any enclosures, as applicable, and this Attachment with the signed Agreement.
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CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Expedited Settlement Agreement” and “Final
Order” in the matter of ZPMC North America Inc., Docket No. CAA-2026-8722, were sent to the following persons on November 17, 2025 in the manner indicated:
By E-mail:
Hallie Lipsey, Attorney-Adviser Tony Zhang, President Air Enforcement Division ZPMC North America Inc. William Jefferson Clinton Building South 2805 McGraw Ave. 2.2226 J Irvine, CA 92614 1200 Pennsylvania Avenue, N.W. [email protected] Washington, DC 20460 [email protected]
Digitally signed by
TOMMIE MADISON
Date: 2025.11.17
10:37:39 -05'00'
Tommie Madison
Clerk of the Board
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