EPA Reconsiders HFC Limits Under AIM Act, Raising Uncertainty in Refrigeration Sector

The U.S. Environmental Protection Agency (EPA) has initiated a review of the Technology Transition rule under the American Innovation and Manufacturing (AIM) Act. This rule, finalized in October 2023 and revised in December 2023, mandates a phased reduction in the use of hydrofluorocarbons (HFCs) with high global warming potential (GWP) in new refrigeration, air conditioning, and heat pump equipment.

The reassessment comes as part of a broader deregulatory agenda announced by EPA Administrator Lee Zeldin, aligning with directives from the Trump administration to lower regulatory burdens. While the review does not signal a return to high-GWP refrigerants like R-410A—which manufacturers have already begun replacing with low-GWP A2L alternatives such as R-32 and R-454B—it could affect compliance timelines for the HVACR industry.

Under the current rule, most new comfort cooling systems must meet a 700 GWP limit starting January 1, 2025. Commercial refrigeration systems are subject to stricter GWP limits of 150 or 300, with deadlines ranging from 2026 to 2028. These thresholds have prompted legal challenges from trade associations, including the Food Industry Association (FMI), which argues the EPA did not adequately consider the rule’s impact on supermarket equipment and implementation feasibility.

The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) confirmed that the reconsideration responds to pending legal petitions and does not currently alter the industry’s expectations. AHRI also emphasized that any modifications must undergo a full rulemaking process, and under the AIM Act, changes cannot take effect until at least one year after publication of a new final rule.

The review has raised concerns among environmental organizations that delaying implementation could slow national efforts to reduce emissions from HFCs. In contrast, the EPA views the reassessment as a measure to reduce costs for businesses and consumers.

Importantly, the AIM Act does not override state-level regulations. States like California, Washington, and New York have enacted stricter rules on HFCs, which will remain in force regardless of federal action. This may result in a fragmented regulatory environment, increasing complexity for manufacturers and operators working across state lines.

As the EPA moves forward with its review, stakeholders in the refrigeration and air conditioning sectors are advised to continue preparing for upcoming compliance dates while monitoring developments in the federal rulemaking process.