The U.S. refrigerant transition is moving slower than its original legislative schedule required. The Environmental Protection Agency has yet to finalize revisions to the 2023 Technology Transitions Rule (TTR) while costs climb and supply chains remain strained. The regulatory stall affects HVAC installers, building owners, and equipment manufacturers across multiple market segments, creating compliance uncertainty that industry associations say could persist through 2026 and beyond.
Background
The American Innovation and Manufacturing (AIM) Act, enacted on December 27, 2020, directed the EPA to address hydrofluorocarbons (HFCs) by phasing down production, minimizing releases, and facilitating the transition to next-generation technologies through sector-based restrictions. In October 2023, the Technology Transitions Rule placed restrictions on the use of high-GWP HFCs in aerosols, foams, refrigeration, air conditioning, and heat pump products, with prohibitions on manufacturing, distribution, sale, installation, import, and export effective January 1, 2025.
On March 12, 2025, EPA announced reconsideration of the Technology Transitions Rule as one of its 31 deregulation priorities and released its reconsideration proposal on October 3, 2025. The agency proposed extending compliance deadlines on HFC use in several subsectors, including residential air conditioning, retail food refrigeration, cold storage warehouses, and semiconductor manufacturing.
Details
The proposed rule has not yet been finalized. The EPA formally sent it to the Office of Management and Budget for interagency review on April 17. The agency's proposal acknowledged that the installation deadline should be removed, but until the rule is finalized, it technically stands. The OMB review process typically takes around 90 days, meaning the final rule could still be several months away.
In the interim, EPA has shifted its enforcement posture. While the agency intends to extend compliance dates through the rulemaking, current deadlines remain effective until modified. Enforcement of those deadlines is described as a low priority, with resources to be focused on compliance with the new deadlines once the rulemaking is finalized. The January 1, 2026, installation deadline nonetheless remains in effect in New York State, where state regulation Part 494 provides a backstop to changes in federal rules.
The proposed rule introduces significant sector-specific changes. Under the reconsideration proposal, EPA would adjust the GWP threshold for remote condensing units and supermarket systems from 150 or 300 to 1,400 starting January 1, 2026, with thresholds reverting to original limits on January 1, 2032. To address supply chain issues related to R-454B, the agency also proposes removing the installation deadline for residential and light commercial air conditioning and heat pump systems, provided that the specified components were manufactured or imported before January 1, 2025.
Supply chain disruptions have driven costs sharply higher throughout the transition period. According to industry data, R-454B cylinder prices rose from $345 in 2021 to over $2,000 in 2025. During peak cooling season, many contractors reported being unable to source R-454B at any price, leading to project delays and customer frustration. Spring and summer 2025 brought significant challenges to the residential market-shortages, price spikes, and stockpiling of R-454B-while most major equipment manufacturers had already transitioned to that refrigerant.
For building owners and facilities teams, retrofit and replacement costs present an immediate planning challenge. New EPA-compliant HVAC systems are reported to cost between 20% and 30% more than pre-transition R-410A equipment, according to multiple industry sources. Retrofitting existing systems to work with new refrigerants is widely described as costly and often impractical. Costs for legacy refrigerants such as R-410A and R-404A are expected to rise further as supplies dwindle.
Industry stakeholders have been vocal about the risks of extended delays. Extending compliance across key sectors to 2032 as proposed-with a 1,400 GWP threshold for food retail-would directly conflict with the global HFC phasedown established under the AIM Act. The next phasedown step comes in 2029, mandating a reduction of supplies to 30% of baseline levels, meaning competing policies could cause demand to outpace supply. According to HARDI, distributor members estimate potential losses exceeding $500 million if the December 31, 2025, installation deadline is not formally repealed.
Beginning January 1, 2026, EPA's HFC Leak Repair and Management Rule also took effect, placing mandatory leak detection and repair requirements on owners or operators of HFC-containing appliances with a refrigerant charge of 15 pounds or greater. Automatic leak detection systems must be installed on new refrigerant-containing appliances in the industrial process and commercial refrigeration subsectors with charges of 1,500 pounds or more by January 1, 2026, for new systems and by January 1, 2027, for existing systems.
Outlook
Release of the final reconsideration rule is expected later in 2026, after some January 1 deadlines established in the original rule have already passed. Finalization will likely take several additional months, and legal challenges could delay it further. For HVAC contractors, procurement managers, and facility operators, the intervening period requires maintaining parallel compliance strategies across legacy R-410A inventory, incoming A2L equipment, and new leak management obligations-with final regulatory certainty still months away.
