EPA Finalizes Targeted Relief from HFC Technology Transitions Rule
Key Takeaways
What Happened? On May 26, 2026, the U.S. Environmental Protection Agency (EPA) published a final rule revising several requirements under the 2023 Hydrofluorocarbon (HFC) Technology Transitions Rule (TTR), which implements subsection (i) of the American Innovation and Manufacturing Act of 2020 (AIM Act), 42 U.S.C. § 7675(i). These revisions, announced as part of EPA Administrator Lee Zeldin’s broader deregulatory initiative, follow petitions for reconsideration and judicial challenges filed by several industry groups in response to the prior rule’s stringent requirements. EPA largely finalized the regulatory relief it proposed in October 2025, including extended compliance dates and relaxed interim global warming potential (GWP)1 limits for certain subsectors. However, EPA did not provide relief for all regulated industries. The final rule will become effective on July 27, 2026.
Who Is Affected? The final rule may affect manufacturers, importers, distributors, installers, owners, and users of refrigerated transport intermodal containers, semiconductor manufacturing equipment, retail food refrigeration systems, cold storage warehouses, refrigerated laboratory centrifuges and shakers, industrial process refrigeration (IPR), and residential and light commercial air conditioning and heat pump (AC/HP) systems.
What Should You Do? Affected stakeholders should review whether their activities are subject to revised compliance dates, interim GWP limits, or installation flexibility.
Key Elements of the Final Rule
EPA finalized many key elements of the proposed rule and added provisions based on comments received, including expanding cooling capacity in supermarket systems without triggering requirements to install new systems.
Chillers and Industrial Process Refrigeration Equipment Used in Semiconductor Manufacturing. EPA extended the 2023 TTR compliance deadlines for IPR chillers with charge sizes of 100 pounds or less used in semiconductor manufacturing. Specifically, EPA extended deadlines from January 1, 2026, and January 1, 2028, as applicable, to January 1, 2030. This extension resolves the legal challenge and the administrative petition for reconsideration brought by SEMI, the global trade association for the semiconductor supply chain, which challenged the 2023 TTR compliance deadlines for semiconductor manufacturing and related equipment and submitted a petition for reconsideration. (Beveridge & Diamond represented SEMI in challenging the rule and petitioning for administrative reconsideration.) EPA also clarified that the lowest temperature at which equipment is designed to operate determines whether it is subject to use restrictions.
Retail Food Refrigeration – Remote Condensing Unit Systems and Supermarket Systems. Based on concerns raised by food retailers about the availability of substitutes and unreasonable costs, EPA finalized a graduated schedule for GWP limits for both remote condensing units and supermarket systems, depending on the system’s charge size and type. These systems will now be subject to an interim GWP limit of 1,400 for remote condensing units, effective July 27, 2026, while the limit for supermarket systems takes effect on January 1, 2027. In both cases, the TTR’s original GWP limits of 150 or 300, depending on charge size and equipment configuration, will resume on January 1, 2032.
The proposed rule sought comment on whether expanding cooling capacity during a supermarket system remodel should be permitted without triggering new-system requirements under 40 C.F.R. § 84.54(e). EPA decided to allow an increase in cooling capacity (in BTU per hour) of up to 15 percent compared to the system’s original installed capacity. This will allow supermarket systems to conduct minor routine store refreshes, remodels, or layout changes that increase cooling capacity up to %without being considered the installation of a new system. The 15% limit applies throughout the life of the supermarket system. Systems may perform any number of routine remodels, so long as the aggregate changes remain within 15% of the cooling capacity provided at the time of installation. EPA also clarified that increasing refrigeration load (e.g., adding refrigeration cases where there is existing cooling capacity) does not necessarily expand cooling capacity (i.e., adding compressor power to the system/increase of BTU per hour).
Refrigerated Transport – Intermodal Containers. EPA finalized the proposal to raise the lower-bound temperature exclusion threshold for intermodal containers from -50 °C to
-35 °C and to measure that temperature inside the container, referred to as “box temperature.” EPA concluded that such relief is appropriate because no alternative currently available meets the 2023 TTR threshold at -50°C, and the box temperature is the more commonly used measurement in industry. EPA also clarified that the lowest temperature at which equipment is designed to operate determines whether it is subject to use restrictions. This means that if an intermodal container is designed to achieve a box temperature below -35 °C, it would not be subject to restrictions even if, at times, the container is operated at temperatures above -35 °C.
Residential and Light Commercial Air Conditioning and Heat Pump (AC/HP) Systems. EPA removed the deadline for installing residential and light commercial AC/HP systems, provided that all specified components of such systems were domestically manufactured or imported before January 1, 2025. EPA believes that removing this deadline will avoid the costs of stranded inventory in this subsector.
Other Elements of the Final Rule
Cold Storage Warehouses. In addition to the graduated schedule for GWP limits on remote condensing units and supermarket systems, EPA also finalized an interim 700 GWP limit for cold storage warehouses effective July 27, 2026, through January 1, 2032. Thereafter, GWP limits of 150 or 300 apply depending on charge size and equipment configuration. EPA’s decision relies on information regarding the availability of substitutes.
Industrial Process Refrigeration in Certain Laboratory Equipment. EPA extended the compliance date for refrigerated laboratory centrifuges and refrigerated laboratory shakers from January 1, 2026, to January 1, 2028. EPA also clarified that the lowest temperature at which equipment is designed to operate determines whether it is subject to use restrictions.
Next Steps
Affected stakeholders should reassess their compliance obligations under EPA’s final rule. This includes:
- Reviewing compliance deadline extensions for equipment and projects.
- Confirming compliance with refrigerant charge sizes, system configurations, box temperatures, manufacturing or import dates, or original installed cooling capacity, as applicable.
- Updating procurement, installation, warranty, service, and construction agreements to reflect revised GWP limits and deadlines.
- Preserving documentation showing when equipment or specified components were manufactured or imported.
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1 GWP is a measure of how much energy the emission of one ton of a gas will absorb over a given period of time (usually 100 years), relative to the emission of one ton of carbon dioxide (CO2). Appendix A to 40 C.F.R. Part 84 specifies the GWP values for regulated substances.
