EPA Proposes New Dates for Refrigerants: What HVACR Contractors Should Know

WASHINGTON — On Sept. 30, the U.S. Environmental Protection Agency (EPA) proposed a targeted reconsideration of the Technology Transitions Rule that could reshape refrigerant choices, compliance timing, and near-term project planning. 

The 2023 Technology Transitions Rule, finalized in October 2023, aimed to phasedown high global warming potential (GWP) hydrofluorocarbons (HFCs) and facilitate the transition to low-GWP alternatives. The rule established a phasedown schedule for HFC production and consumption, limiting it to 90% of historical baseline levels in 2023, with further reductions for subsequent years, 60% in 2024, and 30% by 2029.

Recent action from the Environmental Protection Agency proposes a narrower, sector-focused rollback of near-term Technology Transitions requirements while preserving the rule’s long-term goals. The pre-publication draft lays out interim GWP thresholds, adjusted compliance dates, and a new effective-date approach for relaxations versus more stringent provisions. Industry groups and trade outlets have already begun parsing the operational and supply implications.

According to AHRI’s Oct. 1 summary, the proposal would establish a common reversion to 150/300 GWP on Jan.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. That staged approach is designed to reduce immediate retrofit and procurement costs while keeping the long-term compliance objective in place. EPA’s own prepublication material echoes the staging rationale and frames the interim relief as a way to limit near-term stranded-asset risk. 

In retail food refrigeration, the interim 1,400 thresholds would permit continued use of some higher-GWP HFC blends — such as R-448A and R-449A — through 2031, giving owners and contractors additional time to plan equipment refreshes and workforce training. 

Cold storage warehouses would see a similar two-step approach: an interim GWP ceiling of 700 starting Jan. 1, 2026, then a return to the 150/300 structure in 2032. For industrial process refrigeration used in semiconductor manufacturing, the agency proposes a targeted exemption: equipment with charge sizes below 100 pounds would have an extended compliance date to Jan. 1, 2030. EPA and AHRI characterize these extensions as responses to unique design, timing, and supply constraints in those subsectors. 

The rule also proposes operational adjustments for refrigerated transport: raising the lower-bound exclusion threshold from −50° C to −35° C and changing the measurement point from refrigerant/fluid temperature to box temperature for intermodal containers. That measurement change matters for manufacturers and transport operators because it alters when the GWP restriction applies to containerized shipments. The proposal would make these relaxations effective 30 days after Federal Register publication (per EPA’s interpretation of AIM Act § 103(i)(6)), while reserving the statute’s one-year minimum for any new or more stringent obligations.

Residential and light-commercial installers get a meaningful near-term change: EPA would remove the Jan. 1, 2026 installation cutoff for systems assembled from specified components manufactured or imported before Jan. 1, 2025 — effectively allowing indefinite sell-through and installation of those pre-2025 component sets. EPA frames this as a relaxation that could take effect 30 days after publication, and it also asks stakeholders for input on supply issues tied to R-454B and other refrigerants. For field technicians and wholesalers, the immediate operational takeaway is that previously manufactured inventories may remain installable beyond the prior deadline — affecting job scheduling and parts planning. 

From an economic and environmental standpoint, EPA acknowledges the tradeoff: the interim thresholds would likely increase near-term HFC use compared with the original Technology Transition Rule timelines, yet the 2032 reversion preserves the long-run emissions endpoint. 

Why It Matters for HVACR Contractors

1. Planning and Inventory Impact:
   The proposed delays or rule adjustments could affect contractors’ equipment purchasing strategies and inventory management heading into 2026. Contractors may have more time to work through existing stock or secure compliant alternatives.

2. Training and Certification Needs:
   Even with possible extensions, the shift toward A2L mildly flammable refrigerants remains on track. Contractors must continue to train technicians, update safety procedures, and invest in recovery and leak-detection tools to remain compliant.

3. Pricing and Supply Chain Uncertainty:
   Market volatility around refrigerant pricing and availability may continue as manufacturers wait for final rule clarity. Contractors should communicate with suppliers early and lock in equipment orders where possible.

4. Customer Communication and Trust:
   Contractors play a critical role in educating building owners and homeowners about changing refrigerant options, system performance, and long-term serviceability. Clarity now can prevent confusion later when new refrigerant systems dominate the market.

5. Business Strategy and Compliance Readiness:
   The revised rule may offer short-term relief, but the long-term transition away from HFCs remains inevitable. Contractors who stay proactive — tracking EPA updates, aligning with AHRI and OEM guidance, and refreshing technician training — will be better positioned to stay compliant and competitive.

How Contractors Should Prepare Now

• Stay Informed: Monitor updates from the EPA, AHRI, and industry publications like Contracting Business for the final rule timeline and refrigerant listings.

• Evaluate Equipment Portfolios: Identify which systems in your pipeline may be affected by the proposed changes and work with distributors to manage transitions smoothly.

• Invest in A2L Readiness: Continue training teams on safe handling, installation, and servicing of A2L refrigerants — even if timelines shift.

• Communicate with Customers: Use this moment to explain the long-term direction of refrigerant policy, emphasizing system efficiency and sustainability.

• Plan for 2026 and Beyond: Build flexibility into your business model to adapt to future refrigerant rulemaking under the AIM Act.

While this proposal largely follows stakeholder petitions seeking delay or relief in specific refrigeration segments, others warn that delaying tighter limits could disadvantage early adopters of low-GWP technologies. Stakeholders who already invested in lower-GWP alternatives may view extended interim thresholds as a potential competitive imbalance — something contractors should weigh when advising customers on retrofit versus replace decisions. 

EPA will host a virtual public hearing using Microsoft Teams to provide an opportunity for the public to offer oral comments on the proposed rule and related support documents on Oct. 20. The virtual public hearing is scheduled to begin at 1 p.m. ET. 

Bottom line: contractors who act now will be best positioned for the transition ahead.