The U.S. Environmental Protection Agency (EPA) on December 22 released an enforcement statement in regard to the 2023 Technology Transitions Rule, noting that enforcement of current deadlines addressed by the proposed reconsideration of the rule is a “low priority” for the agency.
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.
But on October 1, 2025, the EPA, in line with Trump administration priorities, announced a proposed reconsideration 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.
Release of the final version of the reconsideration rule is expected later in 2026, after some of the January 1 deadlines established in the original rule. For example, the original rule set January 1, 2026, as the deadline for cold-storage warehouses to use refrigerants with a GWP limit of 150 or 300 (depending on charge size and equipment configuration); the proposed reconsideration rule changes this GWP limit to 700 and delays the starting date for the GWP limit of 150 or 300 to January 1, 2032.
The January 1, 2026, deadline also applied to 150/300 GWP limits for remote condensing units in retail food and the deadline for installations of residential and light-commercial air-conditioning and heat pump systems manufactured or imported before January 1, 2025. These are also changed by the reconsideration, with a 1,400 GWP limit for remote condensing units until 2032, when the 150/300 GWPs apply, and no restrictions on HVAC installations.
According to the EPA’s December 22 enforcement statement, the original deadlines remain effective until modified by the new rule. However, enforcement of these deadlines “is a low enforcement priority for the agency and EPA intends to focus its resources on compliance with the new compliance dates that will be established by this rulemaking.” The change in enforcement only applies to deadlines addressed by the proposed reconsideration.
“We heard from our members the need for certainty, and HARDI submitted an official request to the Agency earlier this month to provide relief to distributors and contractors before the final rule is released.”
Talbot Gee, CEO of HARDI
The action to deprioritize enforcement of 2026 deadlines in the Technology Transitions Rule “is welcome news for distributors and contractors going into the new year,” Talbot Gee, CEO of the Heating, Air-Conditioning & Refrigeration Distributors International (HARDI), said in December. “We heard from our members the need for certainty, and HARDI submitted an official request to the Agency earlier this month to provide relief to distributors and contractors before the final rule is released.” HARDI was particularly opposed to the January 1, 2026, deadline for installation of HVAC systems.
The proposed Technology Transitions Rule, published in the Federal Register on October 3, does not apply to the other two parts of the AIM Act, one covering the phasedown of HFC production, the other emissions reduction and reclamation. HFC production and import is reduced by the 40% compared to baseline through 2028, followed by cuts of 70% (2029 to 2033), 80% (2034 to 2035) and 85%.
No action assurance in two areas
The EPA’s Office of Enforcement and Compliance Assurance (OECA) also announced on December 22 that it is extending the EPA’s January 17, 2025, No Action Assurance (NAA) for restrictions on the manufacture, import and installations of new refrigerated transport-intermodal containers. This means the EPA will continue to not enforce the prohibition on the manufacture, import and installation of refrigerated transport-intermodal containers using HFCs with a GWP above 700 in certain situations.
Extending the NAA for these containers “is necessary to assure the continued safe transport of dangerous goods, and will have minimal negative environmental impact,” the EPA’s Office of Air and Radiation (OAR) told the OECA on December 15.
The OECA is also providing an NAA for the manufacture, import and installation of stand-along chillers for industrial process refrigeration with refrigerant charges of 100lbs or less used in the manufacture of semiconductors. This avoids prohibitions that were scheduled to take place on January 1, 2026 under the Technology Transitions Rule. The OAR also expects this NAA to have minimal environmental impact while being needed to support the chip processing industry.
Differing views on reconsideration
In an online hearing hosted by the EPA last October, manufacturers, trade groups and NGOs expressed their opposition to some of the provisions in the proposed reconsideration rule, particularly the five- and six-year delays in the launch of new GWP limits for refrigerants used in supermarket and cold-storage refrigeration.
For example, Hillphoenix, the leading manufacturer of transcritical CO2 (R744) refrigeration systems to supermarkets in the U.S., is opposed to postponing the current transition dates for supermarket equipment to 2032, said Scott Martin, its Senior Director Industry Relations and Compliance at the EPA hearing.
The current dates “align with our product development cycles and are driving decisions in our industry to invest and build in the United States,” said Martin, who added that Hillphoenix “has massively expanded our CO2 and hydrocarbon portfolios with investments in testing and production capabilities.”
Some states, notably California, New York and Washington, have already enacted their own HFC regulations, which are in some cases more aggressive than the federal HFC requirements. Weakening the federal regulations will lead other states that are part of the U.S. Climate Alliance “to regulate our industry, creating a patchwork of extreme requirements that will increase compliance costs for manufacturers, contractors, wholesalers and retailers,” Martin said.
On the other hand, Stephanie Harris, Chief Regulatory Officer and General Counsel for FMI, which largely represents supermarkets, reiterated the organization’s support for the delays in the proposed Technology Transitions Rule. “The proposed reconsideration is a critical step forward by providing the additional time necessary for the grocery industry to transition its cooling systems to new technologies,” she said, adding that the current deadlines “would result in exorbitant compliance costs as a result of the current barriers for HFC alternative refrigerants and very few HFC alternative technologies.”
