EPA's Zeldin Acts in Name of Easier Refrigerant Transition

On September 30, U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin issued a Notice of Proposed Rulemaking to reform the Biden-Harris 2023 Technology Transitions Rule, a new action the agency is taking to continue meeting its statutory obligations under the American Innovation and Manufacturing (AIM) Act without compromising economic growth or safety.

If finalized, the proposed rule will balance the AIM Act mandated phasedown of hydrofluorocarbons (HFCs) with ensuring American families have access to functioning air conditioning systems. In doing so, businesses will also be able to install the refrigeration systems that work best for them and companies can continue making semiconductor chips that power everyday life. Specifically, EPA is proposing to extend the compliance deadlines on the use of HFCs in a number of subsectors, including residential air conditioning, retail food refrigeration, cold storage warehouses, and semiconductor manufacturing.

Unfortunately, the pages of this calendar can only be turned back so far. Manufacturers have stopped making R-410 HVAC units as systems that can only use alternative refrigerants, especially A2L refrigerants R-454B and R-32 have assumed preference among many contractors in 2025. Some may have some R-410A units left to install, but they must do so by January 1, 2026.

“Hardworking Americans have made their voices and frustrations heard about the lack of availability of refrigerant alternatives during hot summer months and regulations that increase the cost of living for families. Today, the Trump EPA is heeding the call for change,” said EPA Administrator Zeldin. “With this proposal, EPA is working to make American refrigerants affordable, safe, and reliable again.”

The 2023 Technology Transitions Rule forced companies to switch to specific refrigerants like designer HFC blends for residential air conditioning, ammonia or carbon dioxide for supermarket and cold storage refrigeration equipment, contributing to an increase in consumer costs and shortages.

Zeldin was not fully forthcoming. While it's true that the newer refrigerants are more expensive along with everything else today, the shortage of A2L refrigerants in the first half of 2025 were caused by a shortage of A2L refrigerant cylinders, not the refrigerant. Refrigerants such as R-410 to service the larger number of those units was available in ample supply.

Shortages of these HFC blends meant families were left without air conditioning during hot weather. Not only has this left Americans unable to afford or access the necessary refrigerants to install critical equipment, but it has also put public safety and human health at risk as substances like ammonia are more toxic and flammable.

Zeldin's EPA believes the Biden Administration pushed the rule forward too quickly, giving major industry players just over one year to comply, which has posed safety risks for families and manufacturers at risk from failed systems. It believes the semiconductor industry is particularly problematic for the semiconductor industry that needs precise temperature control because as little as a 0.1°C change could be disastrous for production. Concerns were raised that suitable substitute refrigerants won’t be ready by the compliance deadline. Furthermore, the estimated development and implementation of fit-for-purpose alternatives could take up to five years. Today’s proposed rule works to remedy this oversight while advancing Pillar 4 of the Powering the Great American Comeback initiative—Make the United States the Artificial Intelligence Capital of the World.

Additionally, to ensure EPA is accomplishing its core mission of protecting human health and the environment, the proposed changes would remove restrictions on certain intermodal containers that carry cargo transported at very cold temperatures, which include blood plasma and pharmaceuticals. Removing the restrictions will increase the efficiency, reliability, and reach of the medical supply chain helping to deliver life-saving medical products across America.

To address a request from the cold storage industry, EPA is proposing to raise the global warming potential (GWP) threshold for cold storage warehouses from 150 or 300, as applicable, to 700 starting January 1, 2026. EPA is also proposing a later adjustment to the GWP thresholds starting January 1, 2032.

EPA’s proposal preserves current flexibilities for residential and light commercial air conditioning and heat pumps manufactured or imported before January 1, 2025, by allowing them to continue to be installed indefinitely, protecting and lowering costs for homeowners and small businesses.

The proposed rule will be open for a 45-day public comment period after publication in the Federal Register. EPA will also hold a virtual public hearing for the proposed action 15 days after publication in the Federal Register. Further details about the public hearing, including registration, will be available at EPA’s Regulatory Actions for Technology Transitions webpage.

EPA VERBATIM SUMMARY OF RECENT EVENTS

The AIM Act, enacted on December 27, 2020, directs EPA to address HFCs in three main ways: (1) phasing down HFC production and consumption through an allowance allocation program, (2) promulgating certain regulations for purposes of maximizing reclamation and minimizing releases of HFCs from equipment and ensuring the safety of technicians and consumers, and (3) facilitating the transition to next-generation technologies through sector-based restrictions.

In October 2023, the Technology Transitions Rule placed restrictions on the use of high GWP HFCs in aerosols, foams, and refrigeration, air conditioning, and heat pump products, with prohibitions on manufacturing, distribution, sale, installation, import, and export effective January 1, 2025. In response to concerns about inventory stranding, a December 2023 interim final rule (IFR) amended the compliance date, allowing installation of higher-GWP HFC equipment manufactured or imported before January 1, 2025, until January 1, 2026, and clarifies exclusions for residential ice makers. Additionally, a December 2024 final rule further extended installation deadlines for higher-GWP HFC variable refrigerant flow systems, permitting installations until January 1, 2027, and for certain construction projects with permits issued before October 5, 2023, until January 1, 2028. 

AHRI SUMMARY SUMMARY AND COMMENT

Air-Conditioning, Heating & Refrigeration Institute provided the following helpful summary of what the proposal would mean for the compliance calendar.

• Establish a common reversion to 150/300 GWP on January 1, 2032, with interim thresholds of 1,400 GWP for remote condensing units beginning in 2026, 1,400 GWP for supermarket systems beginning in 2027, and 700 GWP for cold storage warehouses beginning in 2026. 
• Raise the lower-bound exclusion from -50 °C to -35 °C, measure at box temperature, and apply the restriction only when a regulated substance (or blend) with GWP ≥ 700 is used in intermodal containers.
• Extend compliance dates to January 1, 2030, for IPR and Chillers for IPR used in semiconductor manufacturing with charge sizes less than 100 pounds.
• Extend the compliance date to January 1, 2028, for refrigerated centrifuges and laboratory shakers.
• Remove the installation deadline for residential and light commercial AC/HP systems built with components manufactured or imported before January 1, 2025.
• Adopt an effective-date interpretati
• Invite advance comment on R-454B availability and related supply measures that may involve other federal agencies.

Sector Summary

Refrigerated transport — intermodal containers

• Current: The TT Rule excludes equipment designed to operate at refrigerant/fluid temperatures below -50 °C; the measurement point is the refrigerant entering the evaporator (or fluid exiting a chiller). Restrictions apply at or above that temperature.
• Proposed change:

o Raise the lower-bound exclusion threshold from -50 °C to -35 °C.

o Change the temperature measurement location from refrigerant/fluid temperature to box temperature.

o Clarify that intermodal containers with a box temperature of -35 °C or higher are restricted only if a regulated substance with a GWP ≥ 700 is used.

• Effective date: 30 days after Federal Register publication (relaxation/removal). 

Industrial Process Refrigeration (IPR) and Chillers for IPR used in semiconductor manufacturing (SMRE) 

• Current: For IPR and Chillers for IPR, restrictions vary by charge size and design temperature; compliance dates are January 1, 2026, or January 1, 2028. There is no SMRE-specific later date for small charges. 
• Proposed change:
  o Extend the compliance date to January 1, 2030, for SMRE equipment with charge sizes of less than 100 pounds that is subject to the paragraphs listed above (both IPR and IPR Chillers).
• Effective date: 30 days after Federal Register publication (relaxation/removal).

Retail food refrigeration — remote condensing units and supermarket systems 

Current: For remote condensing units (RCUs) installed on/after January 1, 2026, and supermarket systems installed on/after January 1, 2027, GWP limits are 150 (≥ 200 lb charge, except the high-temperature side of cascade) or 300 ( < 200 lb charge, or the high-temperature side of cascade).