EPA’s amended rule extends compliance deadlines for certain commercial refrigeration applications at the same time as the American Innovation and Manufacturing (AIM) Act continues to reduce the supply of hydrofluorocarbon (HFC) refrigerants. According to the groups, the result is increased demand for refrigerants whose production and consumption are already being phased down. They argue that the rule effectively increases demand for legacy refrigerants while the AIM Act continues reducing available supply, creating market pressures that could affect contractors, distributors, and end users.

“For the EPA to completely abandon the timelines for transitioning to next-generation products proposed by industry in 2021 misses the mark,” said Talbot Gee, CEO of HARDI. “The final reconsideration rule’s treatment of commercial refrigeration is legally flawed, economically reckless, and directly at odds with the AIM Act. The EPA ignored industry data and over a decade of industry work to prepare for this transition, in violation of the AIM Act’s requirements.”

The Main Argument

The organizations argue that extending the commercial refrigeration deadlines will increase demand for refrigerants at a time when supply is shrinking under the AIM Act’s phasedown schedule.

PHCC CEO Cindy Sheridan said the decision could create additional challenges for contractors already helping customers navigate refrigerant transitions.

“PHCC members are working hands-on and helping customers navigate refrigerant changes every day,” Sheridan said. “Allowing legacy refrigerants to be used longer in new commercial refrigeration systems creates confusion for the contractors who install and service this equipment and hurts consumers.”

Sheridan cited EPA’s own analysis projecting refrigerant prices could rise 12% to 24% by 2029 as HFC supplies continue to decline under the AIM Act phasedown.

“That means inflation between 4% and 8% per year over the next three years, and likely to continue for years beyond that as supplies drop in 2029, 2034, and 2036,” said Alex Ayers, vice president of government affairs for HARDI. “That sustained level of inflation will make installation decisions today have a major, long-term impact on maintenance costs for commercial refrigeration systems.”

The petitioners also argue that extending compliance deadlines for supermarket, retail food, and cold-storage refrigeration applications could divert limited refrigerant supplies away from other sectors, including residential air conditioning and heat pumps.

“While ACCA appreciates EPA eliminating the install deadline for R-410A split-system equipment, the rule’s delayed refrigeration transition will significantly increase the demand for the limited supply of HFC refrigerants and will drive up costs for contractors and their customers,” said Martin Hoover, interim president and CEO of ACCA.

“This change will also increase pressure for a rushed transition to highly flammable A3 refrigerants and encourage a patchwork of state regulations,” Hoover said.

Sean Robertson, vice president of government relations for ACCA, said the delayed commercial refrigeration transition could accelerate state-level regulatory action. 

“For example, New York State sought to ban some virgin refrigerants immediately, pending legal action, and prohibitions on A2L equipment take effect in 2027 for heat pump water heaters, 2030 for chillers and VRF, and 2034 for most residential and light commercial systems,” Robertson said.

Where the Rule Draws Industry Support and Opposition

Despite the challenge, the organizations expressed support for EPA’s decision to eliminate installation restrictions on existing R-410A residential and light commercial split-system air conditioners and heat pumps. That change is scheduled to take effect July 20.

The groups said that provision helps prevent stranded inventory and reduces disruption for distributors, contractors, builders, and consumers.

Robertson said ACCA expects the elimination of the installation deadline for residential and light commercial R-410A split systems to move forward regardless of the legal challenge.

Still, the associations dispute EPA’s rationale for revisiting portions of the original Technology Transitions Rule, arguing that commercial refrigeration requirements had not yet taken effect when the agency proposed the reconsideration. 

EPA’s original rule applied only to newly manufactured equipment and did not require grocery stores, cold-storage operators, or other businesses to replace existing systems. Existing equipment could continue to operate and be serviced. The groups further argue that EPA’s reconsideration rests on the mistaken assumption that the original rule had already increased grocery prices, even though the commercial refrigeration provisions had not yet gone into effect when the agency proposed the revisions.

What Contractors Should Know — and Do — Now

As contractors plan inventory, train technicians, and communicate refrigerant-transition issues to customers amid ongoing regulatory uncertainty, Robertson said preparation is critical.

“An increasingly constrained refrigerant supply means that prices will rise even if we succeed in rolling back these changes,” he said.

“That makes it more important than ever for contractors to ensure their teams are trained and equipped to properly recover refrigerant. Recovered refrigerant will become an increasingly valuable company asset and we must all do our part to ensure adequate supply and avoid a forced A3 transition.”

Robertson also urged contractors to educate customers about repair-versus-replacement decisions as refrigerant supplies tighten.

“Contractors should educate customers to let them know that this is not the time to simply top-off a leaky system,” he said. “Refrigerant and equipment prices will inevitably rise, and a range of financing options should help contractors deliver real solutions for their customers.”

Ayers also emphasized education, saying two aspects of the regulations have created “huge amounts” of misinformation. 

“It’s very important to educate customers on what the rules really say. First off, no one is required to replace a system early under the [the rule]; its primary method of compliance is changing what new systems are manufactured and installed as natural replacements and new construction occurs,” Ayers said. “Secondly, equipment leak rates are more important than ever; not only has the EPA expanded what equipment is subject to leak repair requirements under the Emissions Reduction and Reclamation Rule, but high leak rates hurt the supply of refrigerants, which can lead to even larger shortages if we allow systems to leak unabated.”

Robertson said the legal focus is on slowing future refrigerant price increases — but contractors should prepare for tighter supply conditions regardless of the outcome.

“Today’s challenge is focused on slowing the longer-term increase in refrigerant prices,” he said. “If the revised refrigeration deadlines remain in place, prices will rise even faster than they have been … contractors should ensure their teams are trained and equipped to properly recover refrigerant in what is sure to be an increasingly competitive refrigerant market.”

For commercial refrigeration customers, long-term maintenance costs are becoming increasingly important because refrigeration equipment often remains in service for 15 to 30 years, Ayers said. 

“What may seem like a more economical installation cost today could lead to much higher maintenance costs over the next few decades as high-GWP refrigerant prices rise.”

The legal challenge marks the latest chapter in the HVACR industry’s refrigerant transition, with contractors now facing a combination of regulatory uncertainty, tightening refrigerant supplies, and rising customer concerns about future equipment and service costs.