Mexico has formalized its next phase of refrigerant phaseout regulations, intensifying pressure on manufacturers, distributors, and service contractors across a deeply integrated North American market already adjusting to parallel U.S. mandates.
Published on January 23, 2026, in Mexico's Official Gazette of the Federation, new measures issued by the Ministry of Environment and Natural Resources (SEMARNAT) establish maximum allowable consumption levels for hydrochlorofluorocarbons (HCFCs) for 2026-2030. The rules cover the final stage of Mexico's national HCFC phaseout under the Montreal Protocol, with particular focus on the service sector, where legacy refrigerant use persists. The final stage includes training programs, equipment donations, and official certification requirements for refrigeration and air-conditioning technicians, as well as customs training to prevent illicit HCFC trade.
Background
Mexico has actively participated in international refrigerant governance for over a decade. Mexico co-authored the North American proposal - alongside the United States and Canada - that resulted in the 2016 Kigali Amendment to the Montreal Protocol, which mandates a phasedown of hydrofluorocarbons (HFCs) by more than 80% over 30 years. Mexico ratified the Kigali Amendment on September 25, 2018, with its promulgation decree published in the Official Gazette of the Federation on November 30, 2018.
Mexico's Kigali Roadmap, published by SEMARNAT, establishes a four-pillar framework covering regulation - including import and export licensing systems - strategic planning, implementation, and reporting and verification. As a developing-country (Article 5) party, Mexico was required to freeze HFC consumption by 2024, based on 2020-2022 baseline levels. Progress on the preceding HCFC phaseout has been substantial: by 2024, Mexico achieved an 84.2% reduction in HCFC consumption compared with the 2013 baseline, having already phased out HCFCs in commercial and domestic refrigeration, aerosols, foams, and solvents.
On the U.S. side, the American Innovation and Manufacturing (AIM) Act of 2020 requires an 85% reduction in domestic HFC production and consumption by 2036, benchmarked against 2011-2013 levels. Beginning January 1, 2025, the U.S. EPA's Technology Transitions Program prohibits the manufacture, import, and installation of new HVAC and refrigeration equipment using HFCs with a GWP above 700, effectively ending the use of R-410A - which carries a GWP of 2,088 - in new systems. A significant additional reduction step - cutting HFC allowances to 70% below baseline - is scheduled for 2029.
Details
The convergence of Mexican and U.S. regulatory timelines is compounding compliance demands for cross-border supply chains. The North America refrigerants market is projected to grow from USD 1.75 billion in 2025 to USD 2.41 billion by 2030, at a compound annual growth rate of 6.36%, driven by the federal AIM Act phasedown schedule, state-level restrictions, and rising demand for low-GWP alternatives. Market analysis indicates the region is shifting away from high-GWP HFCs - including R-404A, R-410A, and R-134a - toward HFOs, HFO blends, CO₂ (R-744), and propane (R-290).
The primary low-GWP candidates gaining traction in North American commercial and residential applications are R-32 - with a GWP of approximately 675 - and R-454B, which carries a GWP of 466, representing a 75% reduction compared to R-410A. Both are classified as A2L refrigerants, meaning they are mildly flammable and require updated installation standards, gas detection, and technician training. Contractors holding a U.S. EPA Section 608 certification do not require an additional exam to work with A2L refrigerants.
Cross-border supply chain dynamics add further complexity. USMCA integration remains the dominant framework for North American goods trade. In 2024, total bilateral trade between Mexico and the United States reached approximately USD 873 billion, with Mexico holding its position as the top U.S. trading partner. In 2025, the share of Mexican exports utilizing USMCA preferential treatment rose from 44.8% to 88.7%, as companies restructured supply chains to meet rules-of-origin requirements and avoid U.S. tariff exposure. For HVAC and refrigeration equipment manufacturers operating across Mexico, the United States, and Canada, these shifts directly affect component sourcing, product certification, and refrigerant procurement.
The Kigali Amendment sets a 2033 deadline after which parties must ban HFC trade with any country that has not ratified the agreement, creating an additional market-access incentive for regulatory alignment across North America. As of December 2025, 172 countries are parties to the Kigali Amendment.
A key challenge for mid-market operators in both countries is transition cost. According to U.S. Department of Energy estimates, retrofitting facilities to accommodate natural refrigerants can increase costs by 20-40%. Many legacy units cannot be easily retrofitted and require complete system overhauls, creating financial barriers that slow replacement cycles - particularly for small and mid-sized businesses.
Outlook
Mexico's publication of HCFC limits through 2030 and its ongoing HFC freeze commitment under the Kigali Amendment provide greater regulatory certainty for equipment manufacturers planning product lines and distributors structuring inventory. However, the U.S. EPA released a proposed rule in October 2025 that would extend or remove compliance deadlines for several sectors - including residential air conditioning, retail food refrigeration, and cold-storage warehouses - introducing uncertainty around the pace of the U.S. phasedown. Industry stakeholders on both sides of the border will monitor whether that rule is finalized and how its outcome affects technology investment decisions and the availability of compliant low-GWP equipment in shared North American supply chains.
