Hudson Technologies, Inc. (Board decision, March 10, 2026)

Read the official release (epa.gov)

Plain-English summary

Hudson Technologies, Inc. operates a refrigerant services company in Woodcliff Lake, New Jersey. EPA alleged that Hudson failed to timely submit advance notification reports for 75 HFC import entries between May 18, 2022, and January 30, 2024. The alleged violations concerned the reporting deadlines in 40 C.F.R. § 84.31(c)(7), including the prior 2022 rule. Hudson neither admitted nor denied the alleged violations, agreed to a $215,000 civil penalty, and waived its rights to contest the allegations and appeal. The EAB ratified the Consent Agreement and ordered compliance.

Decision snapshot

• Cited authorities: American Innovation and Manufacturing Act, 42 U.S.C. §§ 7413 and 7675, and 40 C.F.R. parts 13, 19, 22, and 84
• Outcome: The Consent Agreement was ratified, Hudson was ordered to comply with its terms, and a $215,000 civil penalty was approved.
• Key point: HFC importers must timely submit the advance notification reports required by the applicable EPA regulations.

Full text (EPA EAB public release)

F I L E D
Mar 10, 2026
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ______
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.

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In re Hudson Technologies, Inc. Docket No. CAA-2025-8719
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                                   FINAL ORDER


                                Decided March 10, 2026



   Before Environmental Appeals Judges Aaron P. Avila and Ammie Roseman-Orr.

   Order of the Board by Judge Roseman-Orr:

   Pursuant to 40 C.F.R. § 22.18(b)-(c) of EPA’s Consolidated Rules of Practice, the

attached Consent 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 Consent Agreement,

effective immediately.

   So ordered.

ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.

In re:

Hudson Technologies, Inc.

Docket No. CAA-2025-8719

[illegible]

CONSENT AGREEMENT

A. PRELIMINARY STATEMENT
This is an 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 bulk hydrofluorocarbons (HFCs), under Section 113(d) of the Clean Air Act (“CAA”), 42 U.S.C. § 7413(d); and Sections 22.13 and 22.18 of the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and Revocation/Termination or Suspension of Permits (“Consolidated Rules”), codified at 40 C.F.R. Part 22. HFCs are potent greenhouse gases that impact our environment. The United States has committed, as a signatory of the Kigali Amendment to the Montreal Protocol, to reduce its production and consumption of HFCs by 85% in a stepwise manner by the year 2036. Complainant is the United States Environmental Protection Agency (“EPA”). On the EPA’s behalf, Sparsh Khandeshi, Acting Director, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the CAA. Respondent is Hudson Technologies, Inc. (“Hudson Technologies”), a corporation headquartered in Woodcliff Lake, New Jersey. Respondent is a “person” as defined in Section

302(e) of the CAA, 42 U.S.C. § 7602(e).

Consent Agreement and Final Order — Docket No. CAA-2025-8719

10.

[illegible]

Complainant and Respondent (together, the “Parties”), having agreed that settlement of this action is in their mutual interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this Consent Agreement (“Consent Agreement” or “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. Furthermore, Complainant has determined, and Respondent does not dispute, that settlement of this action is in the public interest. B. JURISDICTION

This Consent Agreement is entered into under Section 113(d) of the CAA, as amended, 42 U.S.C. § 7413(d), and the Consolidated Rules, 40 C.F.R. Part 22. The EPA and the United States Department of Justice jointly determined that this matter, although it involves alleged violations that occurred more than one year before the initiation of this proceeding, is appropriate for an administrative penalty assessment. 42 U.S.C.
§ 7413(d).
The Environmental Appeals Board is authorized to ratify this Consent Agreement, which memorializes a settlement between Complainant and Respondent. 40 C.F.R. §§ 22.4(a) and 22.18(b). The issuance of this Consent Agreement and attached Final Order simultaneously commences and concludes this proceeding. 40 C.F.R. § 22.13(b).

C. GOVERNING LAW
This proceeding arises under the AIM Act, 42 U.S.C. § 7675, and CAA Section 113, 42 U.S.C.
§ 7413, and the regulations promulgated thereunder.
The EPA is authorized to enforce the AIM Act and any regulation promulgated thereunder

pursuant to the federal enforcement authorities established by Section 113 of the CAA, 42 U.S.C.

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

12.

13.

14.

§ 7413, as though the AIM Act was expressly included in Title VI of the CAA. 42 U.S.C.

§ 7675(k)(1)(C).

The 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).

The regulations at 40 C.F.R. Part 84, Subpart A, contain the following definitions:

(a)

(b)

(c)

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. “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. “Consumption allowances” are defined as “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.

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

(d) “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.

(e) “Exchange value equivalent” (“EVe’’) 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.

(f) “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.

(g) “Importer” is defined as: “[A]ny 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.

(h) “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.

' The exchange values are the same as the 100-year Global Warming Potentials (“GWPs”) listed in the 2007 Intergovernmental Panel on Climate Change (“IPCC”) Fourth Assessment Report. 4

Consent Agreement and Final Order — Docket No. CAA-2025-8719

15.

16.

17.

18.

19.

(i) “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. The regulations at 40 C.F.R. § 84.5(b)(1)(i) provide that “[n]o person may import bulk regulated substances” except by expending, at the time of the import, consumption or application-specific allowances in a quantity equal to the exchange-value weighted equivalent of the regulated substances imported. Pursuant to 40 C.F.R. § 84.31(a), “[a]ny person who produces, imports, exports, transforms, uses as a process agent, destroys, reclaims, or repackages regulated substances” must meet specified recordkeeping and reporting requirements. From January 1, 2022 to September 18, 2023, the regulations at 40 C.F.R. § 84.31(c)(7) (2022) provided that the importer of record must submit an advance notification report for each shipment of regulated substances imported “no later than 14 days before importation.” 40 C.F.R.
§ 84.31(c)(7) (2022).
Starting September 18, 2023, the regulations at 40 C.F.R. § 84.31(c)(7) provide that the importer of record must submit an advance notification report for each shipment of regulated substances “no later than 10 days if arriving by marine vessel or 5 days for non-marine vessel prior to the date of importation.” 40 C.F.R. § 84.31(c)(7). 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.

• The language in 40 C.F.R. § 84.5(b)(1)(i) (2023) was modified slightly from the previous language in
  40 C.F.R. § 84.5(b)(1)(i) (2022), but the requirement that every importer must expend consumption or application-specific allowances equal to the exchange-value weighted equivalent of the regulated substances imported remained unchanged.

3 As previously discussed in footnote 2, 40 C.F.R. § 84.31(c)(7) has since been modified, effective September 18, 2023 (see 88 Fed. Reg. 46,836, 46,897 (July 20, 2023)).

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

20.

21.

22

23.

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 HFCs at issue in this matter are assigned the following exchange values:

HFC Chemical Formula Exchange Value

HFC-32 CH2F2 675.0

HFC-125 C2HF5 3,500.0

HFC-134a CH2FCF3 1,430.0

HFC-227ea CF3CHFCF3 3,220.0

R-410A 50% HFC-125, 50%

HFC-32 2,087.5

R-422B 55% HFC-125, 42% 2208.5
HFC-134A, 3% 600a ;

40 C.F.R. Part 84, Appendix A.
The CAA authorizes the Administrator of the EPA to assess a civil administrative penalty of not more than $25,000 per day of violation of Title VI of the CAA, or regulations promulgated thereunder. CAA § 113(a)(3)(A), (d)(1), 42 U.S.C. § 7413(a)(3)(A), (d)(1). Pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, Pub. L. 101-410, as amended, and its implementing regulation, the Civil Monetary Penalty Inflation Adjustment Rule, codified at 40 C.F.R. Part 19, the statutory maximum civil administrative penalty has subsequently been raised to $59,114 per day of violation. 40 C.F.R. § 19.4, Table 1.

D. STIPULATED FACTS

Hudson Technologies owns and operates a refrigerant services company located at 300 Tice Boulevard, Suite 290, Woodcliff Lake, New Jersey 07677, and Hudson Technologies is

incorporated under the laws of the State of New York.

• The EPA notes that 600A, or isobutane, is not a regulated substance under the AIM Act or its
  implementing regulations at 40 C.F.R. Part 84. See 40 C.F.R. Part 84, Appendix A.

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

24.

25.

26.

27.

28.

29.

30.

31.

Respondent is a “person,” as that term is defined in 40 C.F.R. § 84.3.

Respondent is an “importer,” as that term is defined in 40 C.F.R. § 84.3.

From 2022 to 2024, the EPA has issued Hudson Technologies consumption allowances for the importation of HFCs and HFC blends. See Phasedown of Hydrofluorocarbons: Notice of 2022

Allowance Allocations for Production and Consumption of Regulated Substances Under the

American Innovation and Manufacturing Act of 2020, 86 Fed. Reg. 55,841 (Oct. 7, 2021); Notice of 2023 Allowance Allocations for Production and Consumption of Regulated Substances Under the American Innovation and Manufacturing Act of 2020, 87 Fed. Reg. 61,314 (Oct. 11, 2022); and Notice of 2024 Allowance Allocations for Production and Consumption of Regulated Substances Under the American Innovation and Manufacturing Act of 2020, and Notice of Final Administrative Consequences, 88 Fed. Reg. 72,060 (Oct. 19, 2023).

From May 18, 2022 through January 30, 2024, Hudson Technologies imported at least 75 separate shipments of HFCs and HFC blends (“Subject HFCs”), including shipments containing HFC-125, HFC-134a, HFC-227ea, R-410A, and R-422B. The shipments of Subject HFCs and the entry dates of each shipment are identified in the table of Exhibit A of this CAFO.

The Subject HFCs identified in Exhibit A of this CAFO are each a “regulated substance,” as that term is defined in 40 C.F.R. § 84.3.

Respondent is the importer of record of the Subject HFCs.

Respondent submitted an advance notification report for each shipment of Subject HFCs on the date identified in the column titled “Entry Filing Date” in the table of Exhibit A of this CAFO.

E. ALLEGED VIOLATIONS OF LAW

From May 18, 2022 through January 30, 2024, Respondent failed to timely submit an advance

notification report by the day specified by 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7) 7

Consent Agreement and Final Order — Docket No. CAA-2025-8719

32;

33;

34.

(2022) for 75 separate import entries of Subject HFCs. The number of days late of each advance notification report is identified in the column titled “Days Advance Notification Reports Late” in the table of Exhibit A of this CAFO. Respondent violated 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7) (2022) by failing to timely submit an advance notification report for the 75 import entries of Subject HFCs by the day specified by 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7) (2022). F. TERMS OF CONSENT 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

Consent Agreement;

(b) admits the facts stipulated in Section D of this Consent Agreement;

(c) neither admits nor denies the alleged violations of law stated in Section E of this Consent

Agreement;

(d) consents to the assessment of a civil penalty as stated below;

(e) waives any right to contest the alleged violations of law; and

(f) waives its rights to appeal the Order accompanying this Consent Agreement.

For the purpose of this proceeding, Respondent:

(a) agrees that this Consent Agreement states a claim upon which relief may be granted against Respondent;

(b) acknowledges that this Consent Agreement constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent

enforcement actions related to the Respondent;

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

(c) waives any and all remedies, claims for relief and otherwise available rights to judicial or administrative review that Respondent may have with respect to any issue of fact or law set forth in this Consent Agreement, including any right of judicial review under Section 307(b)(1) of the Clean Air Act, 42 U.S.C. § 7607(b)(1);

(d) 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 Consent Agreement;

(e) consents to personal jurisdiction in any action to enforce this Agreement or Final Order, or both, in the United States District Court for the District of Columbia;

(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 a United States District Court to compel compliance with this Consent Agreement or Final Order, or both, and to seek an additional penalty for noncompliance with this Consent Agreement or Final Order, and agrees that federal law shall govern in any such civil action;

(g) acknowledges that this Consent Agreement and attached Final Order will be available to the public and agrees that it does not contain any confidential business information or personally identifiable information;

(h) acknowledges that its tax identification number may be used for collecting or reporting any delinquent monetary obligation arising from this Consent Agreement (see 31 U.S.C. § 7701);

(i) certifies that the information it has supplied concerning this matter was at the time of

submission true, accurate, and complete; and

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

35.

36.

af.

(j) acknowledges that there are significant penalties for knowingly submitting false, fictitious, or fraudulent information, including the possibility of fines and imprisonment (see 18 U.S.C. § 1001).

Civil Penalty. The civil penalty agreed upon by the Parties for settlement purposes is $215,000

(the “Assessed Penalty”).

Penalty Payment. Respondent agrees to pay the Assessed Penalty to the United States in the

manner specified below:

(a) pay the Assessed Penalty within 30 calendar days of the Effective Date of this Agreement.

(b) pay the Assessed Penalty using any method, provided on the following website

https://www.epa.gov/financial/additional-instructions-making-payments-epa#Pay.gov.

(c) identify each and every payment with Docket No. [CAA-2025-8719]; and

(d) within 24 hours of payment of the EPA Penalty, email proof of payment to Hallie Lipsey at Lipsey. [email protected]. “Proof of payment” means, as applicable, a copy of the check, confirmation of credit card or debit card payment, confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to the EPA requirements, in the amount due, and identified with Docket No. [CAA-2025-8719].

Failure to pay the full amount of the penalty assessed under this Consent Agreement may subject

Respondent to a civil action to collect any unpaid portion of the proposed civil penalty and

interest. In order to avoid the assessment of interest, administrative costs, and late payment

penalty in connection with such civil penalty, as described in the following four paragraphs of

this Consent Agreement, Respondent must timely pay the penalty.

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

38. Interest, Charges, and Penalties on Late Payments. Pursuant to 42 U.S.C. § 7524(c)(6), 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 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 30 days, interest accrued is waived. If the Assessed Penalty is not paid in full within 30 days, interest will continue to accrue until any unpaid portion of the Assessed Penalty as well as any accrued 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 collection proceedings.

(c) Late Payment Penalty. A 10% quarterly non-payment penalty.

39. 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, interest, or other charges and penalties per this Consent Agreement and attached Final Order, 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, per 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

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Consent Agreement and Final Order — Docket No. CAA-2025-8719

40.

41.

42.

43.

not limited to, referral to the Internal Revenue Service for offset against income tax refunds, per 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, per 40 C.F.R. § 13.17.

(d) Request that the Attorney General bring a civil action in the appropriate district court to recover the full remaining balance of the Assessed Penalty, in addition to interest and the amounts described above, per 42 U.S.C. § 7524(c)(6). In any such action, the validity, amount, and appropriateness of the Assessed Penalty 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.

Tax Treatment of Penalties. Penalties, interest, and other charges paid pursuant to this Consent

Agreement and attached Final Order shall not be deductible for purposes of federal taxes.

By signing this Agreement, the undersigned representative of Complainant and the undersigned representative of Respondent each certify that he or she is fully authorized to execute and enter into the terms and conditions of this Agreement and has the legal capacity to

bind the party he or she represents 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. Complainant agrees to

acceptance of the Respondent’s digital or an original signature on this Agreement.

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44.

45.

46.

47.

Except as qualified by Paragraph 38(b), each party shall bear its own attorney’s fees, costs,

and disbursements incurred in this proceeding.

G. EFFECT OF CONSENT AGREEMENT AND ATTACHED FINAL ORDER

In accordance with 40 C.F.R. § 22.18(c), Respondent’s full compliance with this Consent Agreement shall only resolve Respondent’s liability for federal civil penalties for the violations alleged in Section E of this Consent Agreement.

This Consent Agreement and attached Final Order apply to and are binding upon the Complainant and the Respondent. Successors and assigns of Respondent are also bound if they are owned, in whole or in part, directly or indirectly, or otherwise controlled by Respondent. Nothing in the previous sentence adversely affects any right of the EPA under applicable law to assert successor or assignee liability against Respondent’s successor or assignee.

Pursuant to 26 U.S.C. § 6050X and 26 C.F.R. § 1.6050X-1, EPA is required to annually send to the Internal Revenue Service (“IRS”) a completed IRS Form 1098-F (“Fines, Penalties, and Other Amounts”) with respect to any court order or settlement agreement (including administrative settlements) that require a payor to pay an aggregate amount that EPA reasonably believes will be equal to, or in excess of, $50,000 for the payor’s violation of any law or the investigation or inquiry into the payor’s potential violation of any law, including amounts paid for “restitution or remediation of property” or to come “into compliance with a law.” EPA is further required to furnish a written statement, which provides the same information provided to the IRS, to each payor (i.e., a copy of IRS Form 1098-F). Respondent’s failure to comply with providing IRS Form W-9 or Tax Identification Number (“TIN”), as described below, may subject Respondent to a penalty,

per 26 U.S.C. § 6723, 26 U.S.C. § 6724(d)(3), and 26 C.F.R. § 301.6723-1. To provide

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48.

49.

EPA with sufficient information to enable it to fulfill these obligations, Respondent shall

complete the following actions as applicable.

a.

Respondent shall complete an IRS Form W-9 (“Request for Taxpayer Identification Number and Certification”), which is available at

https://www.irs.gov/pub/irspdf/fw9.pdf.

Respondent shall therein certify that its completed IRS Form W-9 includes Respondent’s correct TIN or that Respondent has applied and is waiting for issuance

ofa TIN.

Respondent shall email its completed Form W-9 to EPA’s Cincinnati Finance

Division at [email protected], on or before the date that Respondent’s penalty

payment is due, pursuant to Paragraph 49 of this Agreement, or within 7 days should the order become effective between December 15 and December 31 of the calendar year. EPA recommends encrypting IRS Form W-9 email correspondence. In the event that Respondent has certified in its completed IRS Form W-9 that it does not yet have a TIN but has applied for a TIN, Respondent shall provide EPA’s Cincinnati Finance Division with Respondent’s TIN, via email, within five (5) days

of Respondent’s receipt of a TIN issued by the IRS.

This Consent 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.

This Consent Agreement may be signed in any number of counterparts, each of which will be

deemed an original and, when taken together, constitute one agreement; the counterparts are

binding on each of the Parties individually as fully and completely as if the Parties had signed

one single instrument, so that the rights and liabilities of the Parties will be unaffected by the

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50.

51.

52.

53.

failure of any of the undersigned to execute any or all of the counterparts; any signature page and any copy of a signed signature page may be detached from any counterpart and attached to any other counterpart of this Consent Agreement. Nothing in this Agreement shall relieve Respondent of the duty to comply with all applicable provisions of the CAA 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 Consent Agreement and settlement penalty if and to the extent that the EPA finds, after signing this Consent 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 in writing.

H. EFFECTIVE DATE
Respondent and Complainant agree to the Environmental Appeals Board’s issuance of the attached Final Order. The EPA will transmit a copy of the Final Order and ratified Consent Agreement to the Respondent. The date upon which the Final Order is issued is the “Effective

Date.”

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Exhibit A

vi Days Advance
Entry Date _ Eling Entry Number HFC/HFC Blend | Notification ate Reports Late 30-Jan-24 23-Jan-24 07102564106 HFC-125 3 3-Feb-24 30-Jan-24 07102562290 HFC-125 6 21-Jan-24 18-Jan-24 07102558579 HFC-125 7 30-Sep-23 25-Sep-23 07102540254 HFC-227ea 5 Change in Reporting Requirements. See 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7) (2022).5 21-Jun-23 16-Jun-23 07102520777 HFC-125 9 7-Jun-23 5-Jun-23 07102519514 HFC-227ea 12 7-Jun-23 5-Jun-23 07102517179 HFC-125 12 28-May-23 26-May-23 07102512634 HFC-125 12 20-May-23 17-May-23 07102510661 HFC-125 11 20-May-23 17-May-23 07102510638 HFC-125 11 20-May-23 17-May-23 07102510612 HFC-125 11 18-May-23 16-May-23 07102517591 HFC-227ea 12 9-May-23 17-May-23 07102513152 HFC-125 22 9-May-23 17-May-23 07102512261 HFC-125 22 30-Apr-23 27-Apr-23 07102506339 HFC-125 11 28-Apr-23 27-Apr-23 07102509028 HFC-125 13 17-Apr-23 14-Apr-23 07102507576 HFC-125 11 14-Apr-23 14-Apr-23 07102507584 HFC-125 14 11-Apr-23 7-Apr-23 07102506909 HFC-125 10 10-Apr-23 7-Apr-23 07102506883 HFC-125 11 29-Mar-23 27-Mar-23 07102504466 HFC-125 12 7-Mar-23 6-Mar-23 07102501322 HFC-125 13 7-Mar-23 6-Mar-23 07102501314 HFC-125 13 7-Mar-23 6-Mar-23 07102501306 HFC-125 13 7-Mar-23 6-Mar-23 07102501298 HFC-125 13 12-Dec-22 9-Dec-22 07102484099 | HFC-125/R-422B 11 12-Dec-22 9-Dec-22 07102484081 | HFC-125/R-422B 11

From January 1, 2022 to September 17, 2023, 40 C.F.R. § 84.31(c)(7) (2022) provided that the
importer of record was required to submit an advance notification report for each shipment of regulated substances imported no later than 14 days before importation. Beginning September 18, 2023, 40 C.F.R.
§ 84.31(c)(7) provides that the importer of record is required to submit an advance notification report for each shipment of regulated substances imported no later than 10 days if arriving by marine vessel or 5

days for non-marine vessel prior to the date of importation. 16

Consent Agreement and Final Order — Docket No. CAA-2025-8719

5-Dec-22 2-Dec-22 07102486060 | HFC-125/R-422B 11
28-Nov-22 25-Nov-22 07102484438 | HFC-125/R-422B 11
22-Nov-22 22-Nov-22 07102482226 | HFC-125/R-422B 14
22-Nov-22 22-Nov-22 07102482218 | HFC-125/R-422B 14
22-Nov-22 22-Nov-22 07102482200 | HFC-125/R-422B 14
14-Nov-22 8-Nov-22 07102488025 HFC-125 8
10-Nov-22 7-Nov-22 07102487985 HFC-125 11

8-Nov-22 3-Nov-22 07102487621 HFC-125 9

7-Nov-22 7-Nov-22 07102488017 HFC-125 14

7-Nov-22 8-Nov-22 07102485815 | HFC-125/R-422B 15

1-Nov-22 31-Oct-22 07102487001 HFC-125 13

30-Oct-22 28-Oct-22 07102485054 HFC-227ea 12
20-Oct-22 18-Oct-22 07102484214 HFC-227ea 12
16-Oct-22 19-Oct-22 07102475048 | HFC-125/R-422B 17

7-Oct-22 6-Oct-22 07102483356 HFC-125 13

4-Oct-22 3-Oct-22 07102482788 HFC-125 13

3-Oct-22 17-Oct-22 07102477721 | HFC-125/R-422B 28

3-Oct-22 17-Oct-22 07102477713 | HFC-125/R-422B 28

1-Oct-22 30-Sep-22 07102469223 HFC-125 13
1-Oct-22 30-Sep-22 07102469207 HFC-125 13
29-Sep-22 29-Sep-22 07102482432 HFC-125 14
28-Sep-22 28-Sep-22 07102479016 HFC-227ea 14
27-Sep-22 20-Oct-22 07102476582 HFC-125 37
26-Sep-22 29-Sep-22 07102476012 | HFC-125/R-422B 17
26-Sep-22 29-Sep-22 07102475998 | HFC-125/R-422B 17
21-Sep-22 23-Sep-22 07102473399 | HFC-125/R-422B 16
21-Sep-22 23-Sep-22 07102473373 | HFC-125/R-422B 16
15-Sep-22 13-Sep-22 07102464851 HFC-125 12
14-Sep-22 13-Sep-22 07102464844 HFC-125 13
14-Sep-22 13-Sep-22 07102464836 HFC-125 13
11-Sep-22 26-Sep-22 07102475378 | HFC-125/R-422B 29
28-Aug-22 25-Aug-22 07102471971 HFC-125 11
28-Aug-22 25-Aug-22 07102471682 HFC-125 11
13-Aug-22 15-Aug-22 07102469439 HFC-125 16
13-Aug-22 15-Aug-22 07102469421 HFC-125 16
13-Aug-22 15-Aug-22 07102469413 HFC-125 16
13-Aug-22 15-Aug-22 07102469397 HFC-125 16
13-Aug-22 15-Aug-22 07102469389 HFC-125 16
13-Aug-22 15-Aug-22 07102469371 HFC-125 16

17

Consent Agreement and Final Order — Docket No. CAA-2025-8719

3-Aug-22 5-Aug-22 07102474082 HFC-227ea 16
13-Jul-22 2-Aug-22 07102466013 R-410A 34
24-Jun-22 1-Jul-22 07102462459 HFC-134a 21
24-Jun-22 29-Jun-22 07102462129 HFC-134a 19
15-Jun-22 15-Jun-22 07102461063 HFC-134a 14
5-Jun-22 8-Jun-22 07102456626 HFC-134a 17
31-May-22 3-Jun-22 07102460271 HFC-134a 17
31-May-22 3-Jun-22 07102457087 HFC-134a 17
20-May-22 18-May-22 07102456287 HFC-134a 12
18

Consent Agreement and Final Order — Docket No. CAA-2025-8719

The foregoing Consent Agreement In the Matter of Hudson Technologies, Inc., Docket No. CAA- 2025-8719, is Hereby Stipulated, Agreed, and Approved for Entry.

FOR RESPONDENT:

[signature]

9/4/2025
Signature Date
Printed Name: Brian Coleman
Title: President & Chief Executive Officer
Address: 300 Tice Blvd Suite 290 Woodcliff Lake, NJ 07677

Federal Tax Identification Number: 13-3641539

19

Consent Agreement and Final Order — Docket No. CAA-2025-8719

The foregoing Consent Agreement In the Matter of Hudson Technologies, Inc., Docket No. CAA- 2025-8719, is Hereby Stipulated, Agreed, and Approved for Entry.

COMPLAINANT:

[digital signature]

Sparsh Khandeshi

Sparsh Khandeshi, Acting Director
Air Enforcement Division

20

Consent Agreement and Final Order — Docket No. CAA-2025-8719

CERTIFICATE OF SERVICE

   I certify that copies of the foregoing “Consent Agreement” and “Final Order” in the

matter of Hudson Technologies, Inc., Docket No. CAA-2025-8719, were sent to the following persons on March 10, 2026, in the manner indicated:

By E-mail:

Hallie Lipsey, Attorney Advisor
United States Environmental Protection Agency
Air Enforcement Division
[email protected]

Michael Grundei, Counsel for Respondent
David Speranzini, Counsel for Respondent
Zachary Lee, Counsel for Respondent
Wiggin and Dana LLP
[email protected]
[email protected]
[email protected]

                                                                   Digitally signed by
                                                                   TOMMIE MADISON
                                                                   Date: 2026.03.10
                                                                   11:07:47 -04'00'
                                                         Tommie Madison
                                                         Clerk of the Board