Arguments to delay based on transient market disruptions are misguided, economically harmful, and strategically shortsighted. U.S. HVACR and water heating manufacturers strongly oppose any rollback. Implementation of the AIM Act is essential to sustaining American industrial competitiveness, ensuring long-term affordability, and delivering tangible environmental and public health benefits.

The refrigerant transition under the AIM Act was adopted with bipartisan support and implemented through a phased, sector-specific framework developed in close collaboration with U.S. industry. The Technology Transitions Rule applies only to newly manufactured equipment. It does not mandate retrofits, restrict servicing, or impose requirements on existing systems. These provisions protect continuity in the installed base while guiding the shift toward next-generation refrigerant technologies.

The present challenge is not a refrigerant supply shortfall — it is a short-term distribution bottleneck driven by A2L cylinder packaging and certification. Multiple U.S. producers are already scaling up compliant packaging solutions. Most critically, R-454B and other transition refrigerants are broadly available. Repealing the rule would do nothing to resolve logistics; it would instead dismantle years of U.S. investment, confuse the market, and reward noncompliance.

American manufacturers have already committed billions of dollars in workforce training, product redesign, plant retooling, and channel coordination to align with this rule. A reversal now would inject major inefficiencies, delay production cycles, and force duplicative revalidation of legacy platforms. It would also open the door to noncompliant foreign imports — undercutting domestic innovation and employment.

Contrary to recent claims, the rule strengthens protections for vulnerable households by preserving full access to service refrigerants and enabling the use of more energy-efficient systems. Over time, these systems will deliver lower utility bills and reduced maintenance costs. As shown in previous transitions — this is the third major shift in refrigerants — costs stabilize with scale, and consumers benefit from improved performance.

Manufacturers, distributors, and contractors need policy stability — not reversals triggered by temporary logistical issues. The AIM Act and its implementing rules offer exactly that: a predictable policy framework that supports productive investment, technology modernization, and supply chain resilience. Repealing these rules would not relieve temporary supply pressures, but it would fracture the market and destabilize American manufacturing.

We urge the Trump Administration and the U.S. Congress to reject any legislative effort to suspend or repeal the Technology Transitions Rule. The American HVACR industry is fully prepared to meet this transition — on schedule, with improved technology, and without compromising economic competitiveness or public safety. Our government should stand with American manufacturers and reject efforts that put short-term convenience ahead of long-term strength.