EPA Hears Industry Feedback on Proposed Refrigerant Rule Revisions

While EPA described these adjustments as a pragmatic response to real-world disruptions, manufacturers and trade groups remain divided — some welcome the added flexibility, while others warn that delays could create confusion, undercut investments, and prolong the use of higher-GWP refrigerants.

All in Favor

At the hearing, contractors, industry associations, and manufacturers alike made their voices heard. Those supporting some of the proposed revisions to the TT rule included Heating, Air-conditioning & Refrigeration Distributors International (HARDI), the trade association representing HVACR wholesalers and distributors. HARDI’s director of government affairs, Alex Ayers, noted that the refrigerant transition is going well, with A2L units making up 92% of all a/c and heat pump sales as of September.

“While A2L adoption has been successful, we’re starting to see a slowing growth of that A2L market,” he said. “This is largely driven by the remaining R-410A equipment inventory in our distributors’ warehouses. That remaining R-410A equipment is a major issue for distributors across the country who are facing that January 1, 2026, installation date deadline. While the legal liability largely falls on contractors, the economic liability falls on both of them. When we look at the total reported inventory, we’re currently exceeding over $500,000,000 in potential losses if nothing is done to repeal the installation date.”

Ayers added that HARDI members also have concerns about some of the proposed changes in the refrigeration sectors, due to their current inventories of lower-GWP refrigeration equipment.

Daikin U.S. Corp. also supports extending the installation compliance date for residential and light commercial air conditioning and heat pump systems as proposed, said its director of government affairs, Charlie McCrudden.

“Daikin has consistently advocated for regulations based on the manufacturing date rather than the installation date,” he said. “Restrictions based on installation date are difficult to plan for in a construction-dependent business. Installation bans strand inventories of goods, forcing manufacturers to take extra and costly retrofit measures for compliance, or lead to the wasteful scrapping of that inventory.”

McCrudden added that Daikin believes the proposed extension of the installation compliance date for residential and light commercial equipment should also apply to VRV/VRF systems, in order to prevent costly or impossible redesigns of existing projects.

FMI – The Food Industry Association, which sued the EPA over what it called overly burdensome compliance deadlines for small grocers transitioning to new refrigerants, strongly supports the agency’s reconsideration of the TT rule, said Stephanie Harris, the group’s chief regulatory officer and general counsel.

“FMI supports the goals of the AIM Act to phase down the production and consumption of listed HFCs and facilitate the transition to next-generation technologies,” she said. “However, the 2023 TT rule went too far too fast in setting deadlines that were unworkable for our industry. The proposed reconsideration is a critical step forward by providing the additional time necessary for the grocery industry to transition its cooling systems to new technologies. EPA should finalize the rule as proposed to reduce the regulatory burden on grocery retailers and supermarkets.”

Harris added that these burdens include higher capital costs, maintenance shortages, building code compliance issues, increased costs for consumers, rural and small business impacts, and water and energy impacts.

“By extending the compliance deadline and adjusting the applicable GWP thresholds for cooling equipment for our industry, EPA can achieve environmental goals at a reasonable cost,” she said.

Bosch Home Comfort also supports an indefinite sell-through period for residential and light commercial systems, said Chris Forth, vice president of regulatory codes and environmental affairs.

“Bosch agrees with EPA that this is necessary to prevent the stranding of remaining 410A inventory and allow contractors greater installation flexibility, which will further stabilize the market,” he said. “We also support the stipulation that the indefinite sell-through period apply to products manufactured or imported prior to January 1, 2025, which will inhibit new foreign entities from flooding the market that could perpetuate further market disruption.”

Although not specifically mentioned in the proposed rule, Bosch asked the EPA to clarify in the final rule that the indefinite sell-through period should also apply to VRF systems. This, said Forth, would help prevent the same stranded inventory issues faced by residential and light commercial products and ensure a consistent, clear sell-through policy for contractors.

All Opposed

Not everyone agreed that more time is the answer. Several companies and associations warned that extending the deadlines could create new challenges across the supply chain. The Air-Conditioning, Heating, and Refrigeration Institute (AHRI), for example, urged the EPA to maintain the transition schedule that was finalized in 2023.

“That schedule … rests on years of technical collaboration, product development, and capital investment to strengthen U.S. competitiveness,” said Samantha Slater, vice president of government affairs at AHRI. “Changing the schedule now would disrupt planning and inject uncertainty across the market. Manufacturers have already retooled lines and certified models based on the current timeline … and building codes in all 50 states currently allow use of A2L refrigerants and other substitutes via successful updates by legislation, regulation, or other means.”

She added that delaying the deadlines for certain refrigeration sectors would also force manufacturers to maintain duplicate inventories, support dual product lines, and undergo additional recertification — costs that would fall most heavily on U.S. companies that had planned around the certainty provided by the AIM Act.

“Delays also have spillover effects,” said Slater. “The AIM Act’s phasedown reduces HFC supply to 30% of baseline in 2029. With finite and diminishing supply of these old classes of refrigerants, delaying one sector’s date reduces the supply for other sectors, increasing the risk of higher refrigerant prices for all new and existing equipment. In short, delaying the schedule would upend investment and planning timelines, advantage foreign-based competitors that did not invest, and risk higher costs for U.S. consumers.”

Hillphoenix, a commercial and industrial refrigeration manufacturer, also opposes the proposed revisions, said Scott Martin, the company’s senior director of industry relations and compliance.

“Delaying the transition dates would undermine years of investment, create uncertainty, impose redundant costs, and prolong the demand for high-GWP refrigerants, just as the AIM Act phasedown steps reduce supply, thus raising prices for retailers, manufacturers, and consumers,” he said. “Further weakening federal HFC requirements will result in states that are part of the U.S. Climate Alliance to continue to regulate our industry, creating a patchwork of divergent and extreme requirements that will increase compliance costs for manufacturers, contractors, wholesalers, and retailers.”

Martin added that delays would also advantage foreign manufacturers, particularly in China, which could enable outdated equipment to enter the U.S. market, undercutting American factories and workers.

“We recognize there may be discrete challenges facing niche and specialty applications, but EPA can address these in the rulemaking through targeted relief, tailored to specific circumstances, rather than overly broad extensions,” he said.

Copeland also does not support the extended deadlines proposed by the EPA, said senior director of regulatory affairs, Jennifer Butsch.

“Effective rulemaking must carefully weigh the impacts across all stakeholders, manufacturers, contractors, distributors, and end users,” she said. “When regulatory changes are delayed or altered so close to implementation, particularly for applications like remote condensing units, it creates significant market confusion.”

Butsch added that companies have already made significant investments in good faith, aligning resources and operations with the final rule the EPA previously issued. In addition, she noted that cost-effective, commercially viable pathways are readily available for transitioning new equipment to lower-GWP alternatives.

“A delay at this point will create uncertainty and may discourage those who have taken early, proactive steps, while appearing to benefit those who have not yet acted,” she said.

With some compliance deadlines taking effect on January 1, 2026, several companies urged the EPA to swiftly issue guidance for the remainder of the rulemaking process.

“EPA needs to urgently provide no-action assurance or other enforcement guidance to cover the period of time between January 1, 2026, and the effective date of the amended final rule,” said Allison Skidd, director of global regulatory affairs at Rheem Manufacturing Co. “Given that it’s unlikely that a final rule would clear necessary review and publish prior to the end of the year, the January 1st installation deadline for both air conditioning and refrigeration systems in certain subsectors presents compliance ambiguity.”

She cited large remote condensing units and cold storage projects as examples, noting that equipment for these jobs must be ordered months before installation. Because installation timelines can shift, contractors are uncertain which equipment will still be allowed after January 1, 2026, risking stranded inventory if projects are delayed.

“If you remember one thing from my remarks, it would be that Rheem requests EPA to provide written enforcement guidance prior to January 1, so that affected manufacturers and installers and end users can have compliance certainty during the remainder of the rulemaking period,” said Skidd.

EPA is accepting comments on the Technology Transitions rule until Friday, Nov. 21.