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Environmental Law Monitor

Your Guide to Emerging Issues in Environmental Regulation and Litigation.

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• Emissions, Environmental Law Monitor, EPA

EPA Puts Freeze on Refrigerant Rules

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In May, the U.S. Environmental Protection Agency (EPA) announced a final rule to revise the 2023 Technology Transitions Rule (TTR) as well as a technical fix to the 2024 Emissions Reduction and Reclamation Rule (ER&R). By way of background, the TTR required many companies, including supermarkets, in-home AC systems, manufacturers of semiconductor chips, and transporters of medical supplies, to change to using specific refrigerants in order to reduce greenhouse gas emissions, while the ER&R established, among other provisions, leak repair requirements for appliances that contain at least 15 pounds of hydrofluorocarbon (HFCs) refrigerants used to transport perishable goods.

The final revisions to the TTR extend compliance deadlines for the use of HFCs, making a wider variety of refrigerants available to businesses while still meeting statutory requirements under the American Innovation and Manufacturing (AIM) Act. In particular, companies can now use HFCs that are up to 1,400 times as potent as carbon dioxide until 2032 instead of 2027, as mandated under the previous rule. The TTR also allows the inventory of residential and light commercial air conditioning and heat pump equipment manufactured in the United States or imported into the United States before January 1, 2025, to continue to be installed. Additionally, the EPA proposed to exempt all road refrigerant transport appliances from the HFC leak repair requirements that were established under the 2024 ER&R. Notably, the EPA also announced it will reconsider revisions of the remaining portions of the ER&R in the future.

Proponents of these changes believe they will reduce the price of transporting and storing refrigerated goods, ultimately lowering the price of food and other items Americans buy every day.  On the other hand, opponents of the revisions argue that by extending the compliance deadline, the EPA is maintaining and/or increasing demand in the market for existing refrigerants while supply continues to fall under the AIM Act, resulting in higher service costs and higher costs for consumers. However, it remains to be seen how these rule changes will ultimately affect market prices on various consumer goods.

The final TTR was published in the Federal Register on May 26, 2026. It will become effective on July 27, 2026.