EPA has proposed amendments to its Technology Transitions (TT) rule under the AIM Act, including extended compliance deadlines and higher global warming potential (GWP) thresholds for specific refrigeration applications. These revisions follow industry input collected through a public comment period and hearing in late 2025 and early 2026. Stakeholders from manufacturing, distribution, and contracting sectors contributed feedback in advance of a final rule anticipated later this year. The proposed changes seek to align compliance schedules with industry inventory and cost concerns, resulting in varied industry responses.
Background
The 2023 TT rule, established under the 2020 AIM Act, outlines HFC phasedown schedules and GWP limits across HVAC/R sectors. It imposes progressively stricter GWP thresholds, with bans on high-GWP refrigerants taking effect on January 1, 2025, for select sectors and on other subsectors through 2026-2028, depending on equipment classification. The rule also mandates labeling, recordkeeping, and reporting by 2025, with data submission required in 2026.[1]
Details
EPA's proposal issued September 30, 2025, recommends raising the GWP limit for cold storage warehouses and retail food refrigeration to 1,400 beginning January 1, 2026. Previous GWP limits (150 or 300) would resume on January 1, 2032.[2] The proposal also suggests removing the installation deadline for residential and light commercial air conditioning and heat pumps manufactured or imported before January 1, 2025, allowing indefinite installation of this equipment.[2]
Industry representatives expressed a range of views. The Air Conditioning Contractors of America (ACCA) advocated for eliminating installation deadlines to prevent stranding R-410A equipment. Copeland cautioned that delaying transitions could impact supply-demand equilibrium and hinder investment in lower-GWP technologies. Daikin supported indefinite installation rights for pre-2026 equipment and requested a temporary non-enforcement assurance during ongoing rulemaking. HARDI called for eliminating installation deadlines throughout HVAC/R sectors, citing financial risk for distributors.[3] Rheem stressed the importance of clear enforcement protocols before January 1, 2026, to prevent compliance uncertainty for pre-ordered equipment.[4] At the public hearing, HARDI's Alex Ayers reported 92% adoption of A2L refrigerants in air conditioning and heat pump sales as of September and highlighted potential stranded inventory losses exceeding USD 500 million.[4]
Stakeholders submitted nearly 2,300 comments ahead of the deadline. EPA continues its review, with a final rule expected in 2026.[3]
Outlook
EPA intends to finalize the rule in the second quarter of 2026, specifying enforcement measures and outlining any non-enforcement intervals. Manufacturers, contractors, and equipment distributors await clarity on installation criteria, refrigerant supply timelines, and reporting requirements as they adapt inventory management and compliance strategies.
