IIAR Government Affairs
By Lowell Randel, IIAR Government Affairs Director
EPA Proposes Reconsideration of Technology Transitions Rule
On September 30th, The Environmental Protection Agency (EPA) announced a proposed rule to reconsider policies contained in the Technology Transitions Rule under the American Innovation and Manufacturing (AIM) Act. The AIM Act, passed in 2020, directs EPA to address hydrofluorocarbons (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.
IIAR was one of the first organizations to submit a petition under the AIM Act suggesting GWP limits for multiple uses of HFCs related to refrigeration. IIAR’s petition was granted and helped form the basis of the agency’s October 2023 rule – Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under Subsection (i) of the American Innovation and Manufacturing Act of 2020, otherwise known as the Technology Transitions Rule.
The new rule being proposed by EPA is part of a broader effort to consider deregulatory actions that was announced on March 12, 2025. The proposal also responds to a petition submitted in March 2025 by the Coalition for the Use of Safe and Efficient Refrigerants, Inc. (CUSER), which focuses on requesting EPA to raise the GWP limit for cold storage warehouses from 150 GWP to 700 GWP. Other policies addressed in the proposed rule relate to intermodal refrigerated transport, industrial process refrigeration and chillers used in semiconductor manufacturing, certain types of refrigerated laboratory equipment, retail food refrigeration systems for supermarkets and remote condensing units, and residential and light commercial air conditioning and heat pump systems.
EPA has stated that the proposed rule is intended to increase flexibility and relax certain restrictions on the use of HFC refrigerants previously established under the Technology Transitions section of the AIM Act by changing compliance dates and/or global warming potential thresholds for various applications. EPA is also proposing to remove the installation compliance date for residential and light commercial air conditioning and heat pump (AC/HP) systems, using components manufactured or imported prior to January 1, 2025. Below are specific changes proposed for cold storage warehouses and retail food (supermarkets):
Cold Storage Warehouses:
Current Policy –
Starting January 1, 2026: 150 or 300 threshold (depending on charge size and equipment configuration)
Proposed Change –
Starting January 1, 2026: 700 threshold
Starting January 1, 2032: 150 or 300 threshold (depending on charge size and equipment configuration)
Retail Food (Supermarkets)
Current Policy –
Starting January 1, 2027: 150 or 300 threshold (depending on charge size and equipment configuration)
Proposed Change –
Starting January 1, 2027: 1,400 threshold
Starting January 1, 2032: 150 or 300 threshold (depending on charge size and equipment configuration)
Retail Food (Remote Condensing Units) –
Current Policy –
Starting January 1, 2026: 150 or 300 threshold (depending on charge size and equipment configuration)
Proposed Change –
Starting January 1, 2026: 1,400 threshold
Starting January 1, 2032: 150 or 300 threshold (depending on charge size and equipment configuration)
IIAR has been actively engaged with EPA throughout the rulemaking process. IIAR President Gary Schrift met with EPA and Office of Management and Budget (OMB) representatives to share concerns about potential policy changes ahead of the EPA’s release of the proposed rule. Schrift and IIAR Vice President Eric Smith also provided oral comments at an EPA hosted public meeting on October 20th, after the proposal had been published. Schrift and Smith asserted that extending the compliance deadline could cause further market disruption as well as increase the potential exposure to PFAS chemicals. Both of these are unnecessary risks given the already wide adoption of safe, efficient and readily available natural refrigeration technologies.
Schrift also took the opportunity to highlight that over 90 percent of cold storages currently use natural refrigerants and that reducing the burdens of ammonia regulations would have a much larger impact on businesses across the food supply chain. For example, IIAR is requesting EPA to reconsider current Risk Management Program (RMP) regulations as a part of the agency’s deregulatory activities. RMP is one of the over 30 regulations identified by EPA for potential reforms and IIAR supports the agency’s efforts to modernize the RMP regulation.
With the January 1, 2026 compliance date for several of the Technology Transition Rule provisions rapidly approaching, it is expected that EPA will work to finalize any rule changes prior to that date. However, the extended government shutdown has forced a pause in many EPA activities and could delay final rulemaking action. IIAR will continue to actively engage with EPA throughout the rulemaking process.
