Portions of the American Innovation and Manufacturing (AIM) Act are under scrutiny as part of a broader deregulatory agenda, casting uncertainty over the future of U.S. climate policy for refrigerants. The Environmental Protection Agency (EPA) has announced it will reconsider the Technology Transitions Rule, while Congress is reviewing the Refrigerant Management Rule—two key components of the AIM Act framework.
“There’s a lot at stake for a number of folks, including the OEMs. Some of the delays and rollbacks really serve to actually hurt the U.S. manufacturers because they’re already prepared for this transition,” said Tristam Coffin, co-founder and president, sustainability, policy, and technical services, êffecterra. “Delaying it any further actually opens the door for manufacturers outside of the U.S. to come in and potentially undercut what they’ve already tooled up.”
Avipsa Mahapatra, climate campaign director for the Environmental Investigation Agency, said ultra-low GWP refrigerants, which include ammonia and CO₂, are already providing cooling in a wide range of applications.
“This is established technology being used globally. Asking for more time is, to me, not a need, but an excuse, and rolling back rules that were already vetted and long in consideration with multiple stakeholders does not create certainty,” Mahapatra said. “Rolling back any regulations creates a regulatory vacuum that freezes investment and lets our global competitors spread ahead.”

Technology Transitions Rule Under Pressure

The Technology Transitions Rule targets the phase-down of high global warming potential (GWP) hydrofluorocarbons (HFCs) used in refrigeration and HVAC systems. Under current provisions, refrigerants with a GWP above 150 are banned in many refrigeration applications, while air conditioning and heat pump systems face a 700-GWP threshold. Compliance deadlines range from 2025 to 2028.
However, many R-513A users and suppliers are pushing back. The Coalition for the Use of Safe and Efficient Refrigerants (CUSER), representing users and suppliers of R-513A, has formally petitioned the EPA to revise the rule. CUSER seeks to raise the GWP limit for cold storage systems from 150 to 700, citing high costs, limited alternatives, and safety-related building code challenges.
The petition, filed under subsection (i) of the AIM Act and 40 C.F.R. § 84.62, argues that the EPA underestimated the practical difficulties in transitioning the cold storage sector. It specifically challenges 40 C.F.R. § 84.54(c)(9), which bans refrigerants with a GWP over 150 in new cold storage refrigeration systems beginning January 1, 2026. CUSER is also requesting exemptions for specific refrigerants, such as R-513A, to prevent disruptions in the cold storage supply chain.

According to CUSER, the cold storage sector is facing significant barriers in complying with the 150 GWP limit. These include the continued unavailability of viable low-GWP alternatives, high conversion costs, and complicated compliance with building codes when using flammable or high-pressure refrigerants. The Coalition argues that these challenges are more severe than the EPA anticipated when it issued the Technology Transition Rule in October 2023.
CUSER has also requested that the EPA allow the continued use of specific refrigerants with GWP values up to 700, such as R-513A, in lieu of a general increase to the limit. The group urges the EPA to expedite consideration of its petition to avoid major disruptions to the cold storage supply chain.
Coffin said he doesn’t see the need for any changes, given that safer, lower-GWP options, including, namely, carbon dioxide systems, are commercially available and technically viable. “I could see the reasoning if the industry were widely adopting a moderate GWP refrigerant like R-513A, but the majority of commercial and industry refrigeration applications are adopting CO2 as the go-forward solution of choice,” he said. “There’s really no basis in reality here.”
While working for Whole Foods, Coffin worked on one of the first transcritical CO₂ stores stateside in 2013. “It’s 2025 and the industry is largely moving in that direction,” he explained.
IIAR is currently drafting its own letter to the EPA opposing the CUSER petition.

Congressional Scrutiny of the Refrigerant Management Rule

Alongside the Technology Transitions Rule, Congress has initiated a Congressional Review Act process to examine the AIM Act’s Subsection (h), known as the Refrigerant Management Rule or Emissions Reduction and Reclamation Rule. While no legislative action has yet occurred, the review may prompt further EPA evaluation.
“The Technology Transition Rule sets policies for different uses of HFCs and associated global warming potential limitations. The Refrigerant Management Rule is more around what you need to do related to leak detection and monitoring,” said Lowell Randell, director of government relations for IIAR. “There hasn’t been any movement on that Congressional Review Act, but that may lead EPA to take a closer look at that piece of the AIM Act as well.”
Coffin said subsections (h) and (i) are meant to help balance the demand of refrigerants and regardless of the regulatory requirements are generally smart business practices. “The rules in themselves are meant to ensure that there isn’t a pinch on the supply of the refrigerants and to also address the potential for price volatility of the refrigerants. So, to remove those is almost like cutting off your nose to spite your face,” he said.

Staying the Course

While the reviews could bring potential changes, the AIM Act will remain in place. “The main goal of the AIM Act is to phase down the production and consumption of HFCs in the United
States,” said Danielle Wright, executive director of the North American Sustainable Refrigeration Council (NASRC). “The primary mechanism to accomplish this is a gradual reduction in the manufacture and use of HFCs, aiming for an 85% reduction from the baseline by 2036. This has not fundamentally changed.”
Coffin is urging end users to stay the course and not form their plans based on temporary political shifts. “Don’t allow the noise to disrupt where you’re headed. Make sure you’re doing the proper due diligence and working with the proper experts to point you in the right direction,” he said. “If people are going to change their strategy based on the political environment every two to four years, it’s a failed approach because the pendulum is likely to continue to swing.”
Before purchasing equipment, Mahapatra recommends that end users think long-term. “Ask: Will this still be legal and affordable five years from now? What about 10 years from now? This equipment usually has a life of at least 15 to 25 years. You do not want to invest in stranded technology, and betting on yesterday’s refrigerant is a gamble.”
Mahapatra added that the trend is clear. “Globally, companies should see the writing on the wall that HFCs are not refrigerants that are going to continue in the future,” she said. “We might have a little bit of delay—plus two years here or plus three years there—but at the end of the day, this is a dead-end technology.”
Smart companies globally are looking for the best technology that is the lowest GWP that is safe and that can be adopted in the market today. “American companies can either set the pace or spend the next decade catching up,” Mahapatra said. “We need this framework of rules that were already established to keep the momentum and to give innovators clear runway, and rollbacks are only sending mixed signals and creating more uncertainty.”