EPA Extends Comment Period for Tech Transition Rule Change

The Environmental Protection Agency (EPA) EPA has extended the comment period for the proposed rule titled “Reconsideration of Certain Technology Transitions Requirements Promulgated under the Technology Transitions Provisions of the AIM Act.”   The comment period will end on November 21, 2025.

A public comment session was convened on October 20, during which time leading HVACR organizations and manufacturers expressed their preference for keeping the original transition timeline in place, citing technology development and market issues.

"When regulatory changes are delayed or altered so close to implementation, particularly for applications like remote condensing units, it creates significant market confusion," said Jennifer Butsch, Director of Regulatory Affairs for Copeland. 

“Companies have made significant investments in good faith, aligning their resources and operations with the final rule EPA has already published; a delay at this point will create uncertainty and may discourage those who have taken early, proactive steps, while appearing to benefit those who have not yet acted. This could have unintended consequences for businesses planning and confidence in the regulatory process," Butsch said. 

Samantha Slater, Vice President of Government Affairs for the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), spoke in favor of retaining the original transition schedule established in 2023, that is based on "years of technical collaboration, product development and capital investment to strengthen U.S. competitiveness" and that gave manufacturers time to design, test and certify and scale new equipment.

"Changing the schedule not would disrupt planning and inject uncertainty across the market," Slater said.

Among those in favor of moving the timeline back was Stephanie Harris, Chief Regulatory Officer and General Counsel for Food Management Institute (FMI). 

“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,” Harris 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."

A copy of the pre-publication Federal Register Notice announcing this extension may be found here: https://www.epa.gov/system/files/documents/2025-10/technology-transitions-comment-period-extension-notice_signed_prepublication_0.pdf

Additional information in the proposed rulemaking may be found here: https://www.epa.gov/climate-hfcs-reduction/regulatory-actions-technology-transitions