Kyle Klahre, Project Engineer

The question of whether refrigerant regulations will be rolled back is on the minds of many end-users. On March 12, 2025, the U.S. Environmental Protection Agency (EPA) announced its plan to reconsider the Technology Transitions rule. This reconsideration is one of 31 actions the EPA intends to undertake, all of which are aimed at reversing previously enacted environmental regulations. The announcement stated that they would reevaluate the rule “that forces companies to use certain technologies, which increase costs for food at grocery stores and in semiconductor manufacturing.”

This Technology Transitions Rule was one of the three main pillars of the American Innovation and Manufacturing (AIM) Act. The AIM Act established a schedule to phase down hydrofluorocarbon (HFC) refrigerants in the U.S. market, aligning with the Kigali Amendment to the Montreal Protocol. At the time of this writing, the remaining phase-down dates are January 1, 2029, 2034 and 2036, with 70%, 80% and 85% decreases in HFC refrigerant production and consumption in the U.S. market, based on a baseline from 2011 to 2013. Although the AIM Act was bipartisan, it is important to note that the Act did not explicitly outline the specifics of how these percentages would be achieved. The “how” was given to the EPA. The AIM Act empowered the EPA to mandate supply restrictions, establish sector-based global warming potential (GWP) limits, and create and enforce standards for servicing and repairing existing systems to accomplish the phase-down schedule. The sector-based GWP limits were established under this Technology Transitions Rule. In October 2023, the EPA released the final version of the Technology Transitions Rule with compliance dates ranging from 2025 to 2028.

Retailers nationwide are already feeling the impact of these regulations in the Technology Transitions Rule, with self-contained refrigerated fixtures and HVAC units transitioning to lower GWP solutions as of January 1, 2025 and many new remote condensing units already being purchased to utilize a lower GWP refrigerant since current regulation is in line for those starting January 1, 2026. In the end-user community, many may welcome a potential delay, as it would provide breathing room for new technologies to be vetted for performance while allowing local jurisdictions to adopt the latest codes. However, under subsection (i) of the AIM Act, a revised Technology Transitions Rule could not take effect until one year after a new final rule is published. Therefore, even if the EPA initiates changes to the Technology Transitions Rule or other regulations, those changes would likely take time to implement and reach end-users. Additionally, given the bipartisan nature of the AIM Act and the sustainability goals set by many larger retailers, any changes to refrigerant regulations are likely to result in temporary delays rather than a complete halt in the industry’s move towards lower GWP refrigerants.

The EPA’s reconsideration of the Technology Transitions Rule is likely to create additional uncertainty for many end-users. While some may welcome the potential delay as an opportunity to vet new technologies more thoroughly and adapt to local codes, the overall industry trend toward lower GWP refrigerants is unlikely to be halted. The bipartisan support for the AIM Act and the sustainability commitments of major retailers suggest that any regulatory changes will be temporary. Retailers are wisely remaining proactive, continuing with their established plans to meet regulatory demands and avoid unnecessary vulnerabilities. Staying informed about federal and state regulations, as well as technological advancements to ensure future compliance, will be crucial for navigating this evolving landscape.

To read more about what the future may look like, please visit: Grocer’s Guide to Refrigeration Regulations