Summary
- EPA’s May rule lets supermarkets and remote condensing systems use refrigerants up to 1,400 GWP until 2032. EPA estimates the change will save about $976 million from 2026 through 2050, with most of the benefit going to supermarkets.
- Self-contained foodservice equipment received no extension. New stand-alone refrigeration units and smaller ice machines are already under lower-GWP limits, and new beverage and food dispensers face restrictions beginning January 1, 2027.
- No rule requires operators to replace equipment that still works. The main challenge is keeping older units running: HFC production and import allowances drop from 60% to 30% of the baseline in 2029, and HFC ice machines must use reclaimed refrigerant for service starting that year.
- EPA acknowledges that its relief could raise HFC prices for other users. Operators have roughly two years to prepare before the 2029 phasedown step and reclaimed-refrigerant requirement take effect.
EPA’s May rule easing refrigerant requirements includes a warning few operators are likely to see. The agency said the relief could increase demand for HFC refrigerants, which “may result in tighter supply and higher HFC prices for downstream consumers, including users of HFCs in subsectors outside the scope of this final rule.”¹
Put simply, the rule helped supermarkets but could raise costs for everyone else, including many restaurants, coffee shops, and convenience stores. Their kitchen and beverage equipment remains on the original schedule, while the refrigerant needed to service older units may become more expensive.
Who Got Relief
The 2020 AIM Act gives EPA three responsibilities: cap HFC production and imports, manage HFC use and reuse, and set deadlines for new equipment to switch to lower-GWP refrigerants.¹ A 2023 rule set those deadlines for more than 40 equipment types. In March 2025, EPA said it would revisit parts of the rule, saying it forced “companies to use particular technologies for refrigerant systems that raise the cost of food at the grocery store.”⁸
The final rule took effect July 27. It gives new supermarket systems and remote condensing units an interim GWP limit of 1,400 until January 1, 2032, when the original stricter limits apply. Cold storage warehouses received an interim limit of 700.¹ That means familiar HFC blends such as R-448A and R-449A can remain available for new installations for several more years.¹
EPA estimates the change will save $976 million from 2026 through 2050, or about $56 million a year.¹ Holland & Knight notes that most savings go to supermarkets,² which accounted for 24% of HFC demand in refrigeration and air conditioning in 2025.¹ Some convenience stores, bakeries, and butcher shops that use remote condensing units for walk-ins and display cases also benefit.¹
Your Kitchen Stayed on the Original Schedule
Self-contained equipment—the reach-ins, merchandisers, ice machines, and dispensers common in restaurants and cafes—was not included in the rollback. Since January 1, 2025, new stand-alone refrigeration units have had to use refrigerants with a GWP of 150 or less. Smaller ice machines, up to 1,000 pounds per day for batch machines and 1,200 for continuous models, followed on January 1, 2026.³
The next deadline is January 1, 2027. New dispensing equipment that holds 500 grams of refrigerant or less must use refrigerants with a GWP of 150 or below. Larger dispensers, larger self-contained ice machines, and remote ice machines will no longer be allowed to use certain HFCs, including R-404A and R-134a. Ice cream makers follow in 2028.³
Much of the market has already shifted: Jennifer Butsch, Copeland’s director of regulatory affairs, wrote last year that 4.6 million self-contained propane cabinets are installed across North America.⁴
Your Current Equipment Can Keep Running
The 2027 deadlines apply to new equipment made or imported after that date, and older-design units may still be sold for three more years.³ You are not required to replace a working machine. Repair parts for existing systems are not restricted,³ and EPA says legacy equipment can be repaired throughout its useful life.¹
The leak repair rule that took effect in January is also unlikely to affect most kitchen equipment. It applies to units containing 15 pounds or more of HFC refrigerant.⁵ By comparison, EPA’s threshold for dispensers is 500 grams, just over one pound. Larger walk-in systems may exceed 15 pounds, and EPA has said it plans to revisit the leak rule, though it has not yet provided details.²
More Demand, Same Shrinking Supply
Here is the catch: EPA extended the time supermarkets can buy HFC-based systems, but it did not change the separate cap on HFC production and imports, and it continues to enforce that cap.² Supply remains at 60 percent of the 2011–2013 baseline through 2028, then falls to 30 percent from 2029 through 2033.⁶ The Department of Energy expected producers to cut high-GWP, low-volume blends first.⁶
During the comment period, Copeland’s Butsch warned that prolonging HFC use as the 2029 reduction nears could push demand beyond supply and raise the cost of servicing existing systems.⁴ Copeland makes lower-GWP equipment, so it has a stake in that position. EPA reached a similar conclusion in its own rule.¹
A foodservice-specific change also arrives in 2029. Beginning January 1, commercial ice machines that use HFCs must be serviced only with reclaimed refrigerant.⁷ An R-404A ice machine that needs a recharge in 2029 will depend on reclaimed supply in the same year new production is cut in half.
California, New York, and Washington have separate HFC rules, and Holland & Knight expects those states to continue enforcing them.²
Using the Next Two Years
Check your machines. Each unit’s nameplate lists its refrigerant. A simple list showing which machines use R-404A or R-134a, their age, and how often they have needed a recharge will show where your 2029 exposure is greatest. Check ice machines first because they face both the supply cut and the reclaimed-refrigerant rule.
That list changes the repair-or-replace calculation. A ten-year-old R-404A ice machine with a slow leak looks different in 2028 than it did in 2024. Purchase timing matters too. After January 1, 2027, new dispensers and larger ice machines will be built for lower-GWP refrigerants, while older-design inventory can still be sold for three more years.³ Many new units use flammable refrigerants such as propane, and food retailers told EPA they are concerned about building codes and a shortage of trained technicians.¹ Before buying, ask whether your service provider is trained and equipped for the new machine’s refrigerant.
The May rollback gave supermarkets six more years. For restaurants, cafes, and convenience stores, the timeline stayed the same, and the most important equipment decisions will come between now and 2029.
Sources
- U.S. Environmental Protection Agency, “Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020,” Federal Register, May 26, 2026. https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under; U.S. Environmental Protection Agency, “Analysis of Economic and Environmental Impacts,” EPA Document No. 430R26001, May 2026. https://www.epa.gov/system/files/documents/2026-05/economic-and-environmental-impacts-memo.pdf
- Matthew Z. Leopold and Aaron Aber, “EPA Finalizes Changes to ‘Technology Transitions’ Provisions of the AIM Act,” Holland & Knight, May 26, 2026. https://www.hklaw.com/en/insights/publications/2026/05/epa-finalizes-changes-to-technology-transitions-provisions
- U.S. Environmental Protection Agency, “Technology Transitions HFC Restrictions by Sector,” updated August 28, 2026. https://www.epa.gov/hfcs/technology-transitions-hfc-restrictions-sector
- Jennifer Butsch (Copeland), “Progress Postponed: Understanding EPA’s Proposed Changes to Refrigerant Rule,” ACHR News, November 5, 2025. https://www.achrnews.com/articles/165454-progress-postponed-understanding-epas-proposed-changes-to-refrigerant-rule
- U.S. Environmental Protection Agency, “Reporting Resources for the Emissions Reduction & Reclamation Rule,” updated April 6, 2026. https://www.epa.gov/hfcs/reporting-resources-emissions-reduction-reclamation-rule
- U.S. Department of Energy, “OE-3: 2021-06, HFC Phasedown,” November 2021. https://www.energy.gov/sites/default/files/2021-12/OE_3_2021_06_HFC_Phasedown_508.pdf
- 40 CFR § 84.112, “Reclamation,” via eCFR. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.112
- U.S. Environmental Protection Agency, “Trump EPA Takes Action to Lower Costs for American Families at the Grocery Store by Reconsidering Burdensome Technology Transition Rule,” March 12, 2025. https://www.epa.gov/newsreleases/trump-epa-takes-action-lower-costs-american-families-grocery-store-reconsidering