The HVACR industry has been waiting for clarity on the TT Rule since last year, when the EPA announced plans to reconsider portions of the regulation governing the use of higher-GWP HFC refrigerants in new refrigeration, air conditioning, and heat pump equipment. 

Rule Changes 

Under the final rule issued today, the EPA is removing the January 1, 2026, installation deadline for residential and light commercial air conditioning and heat pump systems using refrigerants with a GWP above 700, as long as the equipment was manufactured or imported before January 1, 2025. This means contractors and distributors can continue installing existing pre-2025 inventory until supplies are depleted, rather than being forced to stop installations at the start of 2026. 

For supermarkets and other retail food refrigeration systems, the EPA is temporarily raising the allowable refrigerant GWP limit from 150 or 300 to 1,400 GWP, beginning January 1, 2027, through January 1, 2032. After that date, the lower GWP limits of 150 or 300, depending on the system’s size and configuration, will take effect again. The rule also gives supermarkets more flexibility to expand existing refrigeration systems, allowing cooling capacity increases of up to 15% without the project being classified as a completely new system installation. 

Remote condensing units used in retail food applications will receive similar relief, with the allowable refrigerant limit temporarily increasing to 1,400 GWP, beginning 60 days after publication in the Federal Register through January 1, 2032. After that date, new refrigeration systems must use refrigerants of 150 or 300 GWP, depending on the equipment charge size. 

For cold storage warehouses, the EPA is temporarily increasing the allowable refrigerant limit to 700 GWP starting 60 days after publication in the Federal Register through January 1, 2032. After that period, the rule will revert to the lower 150 or 300 GWP limits, depending on the system’s size and configuration. 

Industry Feedback

Several industry groups do not support the changes to the final rule. In a press release, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and the Alliance for Responsible Atmospheric Policy (Alliance) argued that delaying the refrigerant transition deadlines for supermarket refrigeration equipment could increase the risk of higher prices by increasing the demand for existing refrigerants while reducing their supply. This would impact refrigerant costs for supermarkets, commercial buildings, and residential dwellings.  

“This rule works against basic supply and demand,” said Stephen Yurek, president and CEO of AHRI. “By extending the compliance deadline, the EPA is maintaining and even increasing demand in the market for existing refrigerants while supply continues to fall under the AIM Act. So, instead of falling, refrigerant prices are likely to rise, resulting in higher service costs, and higher costs for consumers.” 

HARDI also criticized the commercial refrigeration revisions, agreeing that the changes could increase refrigerant demand at a time when HFC supply is already declining under the AIM Act phasedown. According to HARDI estimates, the increased demand could add nearly $8 billion in refrigerant costs alone, with broader economic impacts potentially reaching $13 billion across the HVACR industry.

HARDI added that the EPA’s decision is particularly concerning because many food retailers have already started transitioning to lower-GWP refrigeration systems, making efforts to delay the transition increasingly out of step with the direction many businesses have already chosen. “This outcome is deeply disappointing, and it did not have to go this way,” said Talbot Gee, CEO of HARDI. 

The groups also emphasized that the requirements applied only to newly manufactured equipment, not existing systems already in operation.  

“This was never a rule forcing stores to replace existing equipment,” said Yurek. “It was a rule for new equipment. The EPA has no analysis showing that delaying these dates will lower costs for consumers.” 

AHRI and the Alliance also reject claims that the market is not ready for the transition, noting that next-generation refrigerants are widely available and approved for use today. They state that over 90% of new residential and light commercial equipment already uses next-generation refrigerants. The groups added that the final rule also harms U.S. manufacturers who invested to meet the existing dates. 

“American manufacturers did what Congress and the first Trump Administration asked them to do,” said John Hurst, executive director of the Alliance. “They invested in new equipment, new refrigerants, new production lines, and American workers. The Administration has now changed course in a way that weakens those investments.” 

The final rule will take effect 60 days after publication in the Federal Register (Docket ID No. EPA-HQ-OAR-2026-2905).