The U.S. Environmental Protection Agency's proposed reconsideration of the Technology Transitions Rule is prompting cold-chain operators, transport refrigeration fleets, and equipment suppliers across North America to revise investment timelines and procurement strategies. Published in the Federal Register on October 3, 2025, the proposed rule extends compliance deadlines and raises interim global warming potential (GWP) thresholds for refrigerants used in cold storage, retail food refrigeration, and refrigerated transport, creating a multi-year window of regulatory uncertainty that directly affects equipment replacement cycles and refrigerant sourcing.

Background

The Technology Transitions Rule is one of three pillars of the American Innovation and Manufacturing (AIM) Act, enacted in 2020 with bipartisan and industry support. The EPA released the final version in October 2023 to accelerate the shift to climate-safe technologies in new refrigeration, heating, and cooling systems by restricting HFCs where alternatives exist.

On October 1, 2025, the EPA, aligned with Trump administration priorities, announced a proposed reconsideration that would introduce several changes, including delayed start dates for new GWP limits on refrigerants used in supermarket and cold-storage refrigeration. The comment period closed on November 21, 2025, drawing more than 2,300 submissions from industry stakeholders, according to ACHR News.

For transport refrigeration specifically, the EPA extended its No Action Assurance for restrictions on refrigerated transport-intermodal containers, meaning the agency will continue not enforcing the prohibition on HFCs with a GWP above 700 in certain situations. The EPA stated that extending the assurance "is necessary to assure the continued safe transport of dangerous goods."

Details

The original rule set January 1, 2026, as the deadline for cold-storage warehouses to use refrigerants with a GWP limit of 150 or 300; the proposed reconsideration raises this threshold to 700 and delays the stricter limits to January 1, 2032. For retail food refrigeration, the proposal raises the interim GWP threshold for remote condensing units and supermarket systems to 1,400, permitting continued use of HFC blends such as R-448A and R-449A through 2032.

On December 22, the EPA released an enforcement statement noting that enforcing current deadlines addressed by the proposed reconsideration is a "low priority." Industry sources expect the agency to finalize the reconsideration rule by late Q2 or early Q3 of 2026.

The proposed delays have drawn criticism from manufacturers already invested in low-GWP equipment. Hillphoenix, the leading U.S. manufacturer of transcritical CO₂ refrigeration systems for supermarkets, opposed postponing current transition dates to 2032 at an EPA hearing in October 2025. Copeland raised concerns that extending compliance across key sectors to 2032 with a 1,400 GWP threshold for food retail would directly conflict with the global HFC phasedown schedule established under the AIM Act.

Supply-side pressure remains unchanged regardless of the regulatory delay. Under the AIM Act's statutory phasedown schedule, HFC production and import allowances drop to 30% of baseline levels in 2029 and to 15% by 2036. Servicing and repair of refrigerant-containing appliances in the supermarket systems, refrigerated transport, and automatic commercial ice maker subsectors must use reclaimed HFCs after January 1, 2029.

Outlook

Systems still running high-GWP HFCs face rising input costs with every service cycle, tightening compliance requirements, and a forced transition regardless of how the EPA adjusts its schedule. Fleet operators and cold-chain facility managers confront a planning paradox: the regulatory timeline has loosened, but the underlying supply contraction under the AIM Act has not. Equipment purchasers weighing capital expenditures through 2028 must now account for both interim regulatory flexibility and the 2029 supply cliff when allocating budgets for new systems, retrofits, and technician training on low-GWP refrigerant handling.