The U.S. Environmental Protection Agency (EPA) has proposed extending the compliance deadline for low-global warming potential (GWP) refrigerants in transport refrigeration-specifically for intermodal containers operating below -35 °C-until 2028. This move, part of the broader Technology Transitions Rule reconsideration, would postpone enforcement and alter planning for retrofits, capital allocation, and supplier contracts.
Background
The 2023 Technology Transitions Rule, under the AIM Act, set phased reductions of high-GWP hydrofluorocarbons (HFCs) across multiple sectors, including transport refrigeration. The regulation imposed a 700 GWP limit, effective in certain subsectors from 2025. The EPA has issued no-action assurances to allow stakeholders to adjust[1].
Transport refrigeration-particularly intermodal containers requiring -50 °C to -35 °C-was initially subject to the 700 GWP cap starting January 17, 2025. The current EPA proposal revises this threshold and extends the compliance timeline to 2028[2].
Details
The proposal grants refrigerated intermodal containers operating at ultra-low temperatures continued flexibility in refrigerant selection and transition periods. The EPA recognizes that maintaining such low temperatures often necessitates refrigerants with low boiling points and high refrigeration capacity, which are still limited in the market[3].
Modeling indicates that the shift to lower-GWP alternatives such as R-450A or R-513A may proceed gradually. Portions of the market may continue utilizing R-452A or other high-GWP HFCs until commercially viable, lower-GWP options become available[4].
The broader proposal is consistent with the EPA's approach to mitigating immediate economic impacts while upholding environmental targets. It includes staggered GWP thresholds for additional sectors, such as retail refrigeration and cold storage, with strict limits deferred until 2032[5].
Outlook
If finalized, the rule will require fleets and equipment manufacturers to adjust retrofit schedules and update procurement plans for refrigerants and components. With rule finalization expected by mid-2026, industry participants should monitor regulatory developments and revise budgets, supplier agreements, safety training, and refrigerant sourcing to comply with the updated timeline.



