The U.S. Environmental Protection Agency finalized sweeping revisions to its 2023 Technology Transitions Rule on May 21, 2025, rolling back or extending compliance deadlines for high-GWP HFC refrigerants across multiple HVAC and refrigeration subsectors. The action, announced alongside a proposed technical correction to the 2024 Emissions Reduction and Reclamation (ER&R) Rule, is reshaping procurement strategies, refrigerant inventory positions, and compliance timelines for contractors, distributors, and facility operators industry-wide.
Background
The AIM Act of 2020 directed EPA to phase down HFC production and consumption to 15 percent of historic baseline levels by 2036, restrict HFC usage across industry sectors, and establish requirements for the management, service, repair, disposal, and installation of HFC-utilizing equipment. To implement these mandates, EPA established three regulatory programs: the Allowance Allocation and Trading Program, the Technology Transitions Program, and the Emissions Reduction and Reclamation (ER&R) Program, which targets servicing, repair, disposal, and installation of HFC-containing equipment.
EPA released the final Technology Transitions Rule in October 2023 to accelerate the shift to more efficient, climate-safe technologies in new refrigeration, heating, and cooling systems by restricting HFC use where alternatives were already available. On October 1, 2025, EPA announced a proposed reconsideration aligned with Trump administration priorities, including delays to new GWP limits for supermarket and cold-storage refrigeration.
Key Rule Changes and Supply Chain Consequences
The May 21 final rule revises the 2023 Technology Transitions Rule, extending compliance deadlines by several years for refrigerants with a GWP below 150 or 300 in supermarket systems, remote condensing units, and cold storage warehouses.
Among the most significant changes for residential and commercial HVAC contractors: the rule formally lifts the January 1, 2026 prohibition on installing residential and light commercial R-410A air conditioning and heat pump equipment manufactured or imported before January 1, 2025. EPA explicitly acknowledged that the original deadline created a stranded inventory problem, that A2L transition supply chain conditions worsened the issue beyond 2023 projections, and that the rapid market shift toward compliant A2L equipment produced larger-than-expected inventories of legacy R-410A systems.
For commercial refrigeration, manufacturers of grocery store and retail refrigeration systems can now offer units using refrigerants with GWP limits up to 1,400 - rather than 150 or 300 - until 2032. Cold storage warehouses, originally required to use refrigerants with a GWP limit of 150 or 300 by January 1, 2026, now face a GWP limit of 700 starting that date, with the stricter 150/300 threshold pushed to January 1, 2032.
On refrigerant pricing, the trade-offs are sharply contested. Stephen Yurek, president and CEO of the Air-Conditioning, Heating, and Refrigeration Institute, argued that extending the compliance deadline maintains and even increases demand for existing refrigerants while supply continues to fall, warning that "refrigerant prices are likely to rise, resulting in higher service costs." These pressures are already evident in the field: R-454B cylinder prices rose from approximately $345 in 2021 to over $2,000 in 2025, according to industry data, with contractors during peak cooling season reporting an inability to source R-454B at any price, leading to project delays.
HARDI warned that "the impacts will not be limited to supermarkets or cold storage facilities, but will affect the broader HVACR market, including contractors, distributors, building owners, manufacturers, and consumers." Alex Ayers, vice president of government affairs at HARDI, cautioned that the HFC phasedown relies on a careful balance between reducing demand through the Technology Transitions Rule and decreasing supply under the AIM Act's allowance program, and that the rule change "upsets that balance, likely causing shortages."
Industry groups also warned that these changes risk supply chain disruptions and price increases "at a moment when America's contractors and their customers can least afford them," while manufacturers that redesigned products, retooled factories, and trained workers under the 2023 rule face compounding uncertainty.
On the ER&R side, EPA proposed an exemption for road and intermodal container transport refrigeration units from leak repair requirements established under the 2024 ER&R rule. The ER&R program as originally finalized includes requirements for repairing leaking equipment, automatic leak detection on large refrigeration systems, mandatory use of reclaimed HFCs to service certain existing equipment, and removal of HFCs from disposable cylinders before discard. Delays or exemptions to reclamation-linked provisions leave open questions about reclaimed refrigerant supply volumes and service pricing for existing systems.
| Sector | Original Deadline / GWP Limit | Revised Deadline / GWP Limit |
|---|---|---|
| Residential & Light Commercial AC (pre-2025 inventory) | Install by Jan. 1, 2026 | No installation deadline |
| Supermarket Refrigeration | GWP ≤ 150/300 by Jan. 1, 2027 | GWP ≤ 1,400 until Jan. 1, 2032 |
| Remote Condensing Units | GWP ≤ 150/300 by Jan. 1, 2027 | GWP ≤ 1,400 until Jan. 1, 2032 |
| Cold Storage Warehouses | GWP ≤ 150/300 by Jan. 1, 2026 | GWP ≤ 700 from 2026; ≤ 150/300 from 2032 |
| Semiconductor Industrial Chillers | Comply Jan. 1, 2026/2028 | Extended to Jan. 1, 2030 |
| Transport Refrigeration Units (ER&R leak repair) | Subject to 10% leak-rate threshold | Proposed exemption (pending final rule) |
Outlook
The residential HVAC industry has largely adjusted to new refrigerants, with A2L equipment comprising more than 90 percent of distributors' equipment sales in late 2024, according to HARDI data - suggesting the installation deadline rollback arrives after significant market transition has already occurred. Other industry groups have raised concerns that prolonged use of higher-GWP refrigerants could consume available HFC allowances and force a more rapid future transition to highly flammable A3 refrigerants. The AIM Act's HFC phasedown schedule requires a 40% reduction through 2028, followed by cuts of 70% by 2029 and 85% by 2036, all of which remain unchanged by the latest rule revisions. Contractor refrigerant planning now demands 6- to 12-month forecasting horizons rather than traditional just-in-time ordering - a shift that procurement managers, service firms, and facility operators should factor into maintenance contract pricing and capital project budgets for the remainder of the decade.
