The U.S. Environmental Protection Agency (EPA) yesterday announced a proposed rule that would make a number of changes in the Technology Transitions rule, including delays in the start days of new GWP limits for refrigerants used in supermarket and cold-storage refrigeration.
The Technology Transitions rule is one of three pillars of the American Innovation and Manufacturing (AIM) Act, enacted in 2020 at the end of the first Trump administration with bipartisan and industry support. The EPA released the final version of the Technology Transitions rule in October 2023 to accelerate the ongoing transition to more efficient and climate-safe technologies in new refrigeration, heating and cooling systems and other products by restricting the use of HFCs where alternatives are already available. The proposed rule does not apply to the other parts of the AIM Act, which cover the phasedown of HFC production and maintenance requirements.
“There was broad industry support for the original timeline because smart companies are already invested in better technology and prefer market certainty over a harder and costlier transition later,” said Avipsa Mahapatra, Climate Campaign Director, Environmental Investigation Agency US
However, on March 12 the EPA announced that it would pursue “reconsideration” of the Technology Transitions rule as part of 31 actions aimed at rolling back previously enacted environmental regulations.
The original rule bans HFCs in certain new equipment and sets a limit on the GWP of the HFCs that can be used in each subsector, with compliance dates ranging from 2025 to 2028. It sets GWP limits of 150 for many refrigeration uses and 700 for air-conditioning and heat pumps.
The new proposed rule would do the following:
- Retail food: On January 1, 2027, change the GWP limit of 150 or 300 (depending on charge size and equipment configuration) to 1,400. Change the starting date for GWP limits of 150 or 300 from January 1, 2027, to January 1, 2032. Same applies to remote condensing units except the original date was January 1, 2026, not 2027.
- Cold-storage warehouses: On January 1, 2026, change the GWP limit of 150 or 300 (depending on charge size and equipment configuration) to 700. Change the starting date for GWP limits of 150 or 300 from January 1, 2026, to January 1, 2032.
- Residential and light-commercial air-conditioning and heat pump systems: For equipment manufactured or imported before January 1, 2025, change the deadline for installations from January 1, 2026, to no deadline at all.
The proposal also stipulates changes for refrigerated transport – intermodal containers, industrial process refrigeration and chillers used for semiconductor manufacturing, and industrial refrigeration for centrifuges and laboratory shakers.
A preliminary version of the proposed rule is available here. Fifteen days after the final version is published in the Federal Register, the EPA will hold a virtual hearing on the rule. Further details on the hearing will be available here. The EPA will accept comments on the proposal for 45 days after it is published in the Federal Register. Comments, identified by Docket ID No. EPA-HQ-OAR-2025-0005, may be submitted here.
Industry response
The original Technology Transition timeline supported the transition to natural refrigerant-based systems, especially in supermarkets and cold-storage facilities, where they are widely adopted in Europe and increasingly in the U.S. Industry NGOs noted that delaying this transition would not do U.S. end users any favors.
“The proposed rule is not setting up the refrigeration industry for long-term success,” said Danielle Wright, Executive Director for the North American Sustainable Refrigeration Council, a nonprofit that promotes the use of natural refrigerants in commercial applications. “It ignores the reality that most refrigerants greater than 150 GWP will be phased out well before 2032, resulting in stranded assets and unnecessary costs to businesses.”
“Extending deadlines will not help American industry,” added EIA’s Mahapatra. “Instead it sends the wrong signal to end users, suggesting there’s room to delay when in fact it raises costs as regulated refrigerants become scarcer and systems more expensive to maintain over time.”
Moreover, said Mahapatra, “during a global phasedown, every extra year of unnecessary HFC use also risks fueling illegal trade and locks in additional climate damage, at a moment when every fraction of a degree matters.”
Industry trade groups differed in their response to the proposed rule. FMI President and Chief Executive Officer Leslie Sarasin applauded the EPA for “reconsidering certain aspects of the Technology Transitions Rule in a way that achieves the intended environmental benefits without placing unnecessary and costly burdens on the food industry. The previous rule imposed significant and unrealistic compliance timelines, and we are pleased to see those are being reconsidered.”
On the other hand, industry trade group AHRI defended the original Technology Transitions rule with a list of its positions:
- Delaying the Technology Transitions rule transition dates “would disrupt multi-year planning and investment by U.S. manufacturers. Companies have already retooled production, certified new equipment, and built supply chains around the current schedule.”
- “Maintaining the current dates avoids duplicative costs, dual inventories, and confusion in the marketplace. Delays would force manufacturers and distributors to manage redundant product lines and training programs.”
- “A delay would re-open the U.S. market to outdated, high-GWP equipment, giving foreign manufacturers a competitive advantage. This would penalize American firms that acted in good faith to comply with the AIM Act.”
- “Certainty under the AIM Act supports stable refrigerant supply, protects domestic jobs, and prevents fragmented state rules. Reopening the rule would invite a patchwork of requirements across jurisdictions.”
- “Over time, delays would increase costs for manufacturers, distributors, contractors, and end users. Staying on schedule lowers costs, supports investment recovery, and ensures affordable, energy-efficient equipment for consumers.”
“It’s important to remember,” the AHRI added, “that the existing Technology Transitions rule applies only to newly manufactured equipment. Existing systems can operate through their full useful life, and components will remain available to ensure that servicing is not disrupted.”
IIAR tries to retain 150 GWP
In June the International Institute of All-Natural Refrigeration (IIAR) submitted a letter to the EPA asking that the agency retain the GWP limit of 150 for refrigerants in new cold-storage applications established by the Technology Transitions rule and noting that the availability of natural refrigerant systems make that GWP limit a reasonable restriction for end users.
The letter, addressed to EPA Administrator Lee Zeldin and signed by IIAR President Gary Schrift, was sent in response to a March petition to Zeldin filed by the Coalition for the Use of Safe and Efficient Refrigerants (CUSER). The petition asked the EPA to raise the 100-year GWP limit for refrigerants in new cold-storage applications from 150 to 700 to allow the use of R513A. R513A, a blend of HFO-1234yf (56%) and HFC-134a (44%), has a 100-year GWP of 673 and a 20-year GWP of 1,823, per IPCC AR6 (2021).
The CUSER petition was signed by Eric Brown, Chairman of CUSER and President of Georgia-based Alta Refrigeration, which markets R513A-based refrigeration systems. It was co-signed by 23 other manufacturing and contracting companies.
In August, Zeldin joined U.S. Vice President J.D. Vance in a tour of Altra Refrigeration where Zeldin signaled the EPA’s intention to meet CUSER’s request to raise the charge limit for cold storage to 700 GWP, at least until 2032.
The rollback of federal environmental regulations of refrigerants has prompted some states, notably California, New York and Washington, to enact regulations that are at least as aggressive.
Last November, following the re-election of President Donald Trump, the U.S. Climate Alliance, a bipartisan coalition of 24 state governors, recommitted itself to protecting the environment in the face of potential regulatory rollbacks by the EPA. “The U.S. Climate Alliance and its governors filled the void of leadership during President-elect Trump’s first term and Americans can be assured we’re prepared to fill it again,” said New York Governor Kathy Hochul, Co-Chair of the Alliance, in a statement. “Together, we’ll tap every ounce of our experience and authority to protect America’s progress and press forward.”
New York has perhaps the most pro-active HFC regulation, using a 20-year GWP rather than the usual 100-year GWP employed by the EPA and other states.
“Maintaining the current dates avoids duplicative costs, dual inventories, and confusion in the marketplace.”
AHRI
