EPA Issues FINAL Ruling on 2023 Technology Transition Rule
The U.S. Environmental Protection Agency (EPA) has issued a final ruling under the AIM Act (American Innovation and Manufacturing Act of 2020), updating timelines and requirements for transitioning away from high global warming potential (GWP) refrigerants. This final ruling will be effective starting July 27, 2026.
Zero Zone will continue to fully comply with all EPA regulations and support you through these changes.
What Is Changing?
Originally, the EPA established transition deadlines beginning in 2025–2027. The May 2026 update introduces revised extended timelines, shown below.
Retail Refrigeration (Supermarkets, C-Stores, Discount stores, etc.)
| Subsector | Products | Original Requirement (2023 Rule) | Updated Rule (May 2026) | What it means for you between now and new compliance date | ||
| GWP Limit | Compliance Date | GWP Limit | New Compliance Date | |||
| Self-Contained “stand-alone unit” | Retail food-refrigeration stand-alone units | 150 | 1/1/2025 | 150 | 1/1/2025 | |
| Remote Condensing Units
(Zero Zone Hybrid Display Cases) |
With 200 or more lbs refrigerant charge, excluding high temp side of cascade system | 150 | 1/1/2026 | 150 | 1/1/2032 | Customers need to use equipment with GWP<1400 until new compliance date |
| With less than 200 lb refrigerant charge | 300 | 1/1/2026 | 300 | 1/1/2032 | ||
| High temp side of cascade | 300 | 1/1/2026 | 300 | 1/1/2032 | ||
| All Retail Systems | With 200 or more lb refrigerant charge, excluding high temp side of cascade system | 150 | 1/1/2027 | 150 | 1/1/2032 | Starting 1/1/2027, customers need to use equipment with GWP <1400 until new compliance date |
*GWP limit refers to GWP100 limit i.e. calculated over 100 year horizon
*Individual State requirements may differ. Please check relevant state regulations as well
Industrial Refrigeration (Cold Storage, Process Cooling, Data Centers)
| Subsector | Products | Original Requirement (2023 Rule) | Updated Rule (May 2026) | What it means for you between now and new compliance date | ||
| GWP Limit | Compliance Date | GWP Limit | New Compliance Date | |||
| Ice Rinks | Ice Rinks | 700 | 1/1/2025 | 700 | 1/1/2025 | |
| Chillers | Industrial process refrigeration with exiting fluid equal to or above -22F | 700 | 1/1/2026 | 700 | 1/1/2026 | No change except for semiconductor wafer application |
| Industrial Process Refrigeration not using chillers | With 200 or more lb refrigerant charge excluding high temp side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -22F | 150 | 1/1/2026 | 150 | 1/1/2026 | No change except for semiconductor wafer, refrigerated laboratory shakers and refrigerated centrifuges application |
| With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator equal to or above -22F | 300 | 1/1/2026 | 300 | 1/1/2026 | ||
| High temp side of cascade system and temperature of the refrigerant entering the evaporator equal to or above -22F | 300 | 1/1/2026 | 300 | 1/1/2026 | ||
| With refrigerant entering the evaporator equal to or above -58F and less than -22F | 700 | 1/1/2028 | 700 | 1/1/2028 | ||
| Cold Storage Warehouses | With 200 or more lb refrigerant charge, excluding high temp side of cascade system | 150 | 1/1/2026 | 150 | 1/1/2032 | Customers need to use equipment with GWP <700 until new compliance date |
| With less than 200 lb refrigerant charge | 300 | 1/1/2026 | 300 | 1/1/2032 | ||
| High temp side of cascade | 300 | 1/1/2026 | 300 | 1/1/2032 | ||
| Data Centers | Data centers, computer room air conditioning, and information technology equipment cooling | 700 | 1/1/2027 | 700 | 1/1/2027 | |
*GWP limit refers to GWP100 limit i.e. calculated over 100 year horizon
*Individual State requirements may differ. Please check relevant state regulations as well
Service of Legacy Systems
This rule does not restrict customers from using their existing refrigeration systems. The EPA has allowed an existing system to continue its operation to the end of its useful life. The system may be serviced and repaired throughout its use, including replacing components.
The following actions are considered a new installation:
- Assembling a system for the first time from used or new components
- Increasing the compressor cooling capacity, in BTU per hour, of an existing system by 15% of capacity at initial installation (Changed from 0% to 15% in May 2026 ruling)
- Replacing 75 percent or more of evaporators (by number) and 100 percent of the compressor racks, condensers, and connected evaporator loads of an existing system.
Important: What Has NOT Changed
The AIM Act still requires a full transition to the production of low-GWP refrigerants (up to GWP 300)
Existing systems can:
- Continue operating
- Be serviced and repaired throughout their life
The AIM Act HFC phasedown schedule through 2036 remains unchanged – Under the EPA allowance allocation program, the 2029 stepdown reduces available production and consumption allowances to 30% of baseline levels, which is expected to further tighten bulk HFC supply and may increase price volatility for higher-GWP refrigerants. Costs may increase, making it beneficial to plan earlier for refrigerants that meet the 2032 requirements.
What Does This Mean for You?
In the Near Term:
You may continue to:
- Purchase and install certain HFC-based systems within updated limits
- Use existing equipment
You have more time to:
- Evaluate options
- Plan capital investments
- Establish refrigerant strategy that is best for you
- Individual State requirements may change. Please review relevant state regulations as well
Looking Ahead:
HFC supply will continue to decrease
- National phasedown is still in effect
- Availability and pricing will be impacted over time
Low-GWP solutions will still be required
- The final transition has not changed — only the timing
A phased approach is recommended
- Delaying too long may increase future costs and complexity
Various groups opposed the changes to the rule in their formal comments during the comment period. It is likely these groups will file legal challenges that could affect the requirements and implementation dates that are stated above. Zero Zone will continue to monitor these activities and provide updates as they become available.
Zero Zone Commitment
We will continue to follow all enacted regulations and compliance timelines
We provide solutions that support both:
- Near-term flexibility
- Long-term compliance
We offer a full range of refrigerant options, including:
- CO₂ (R-744)
- Propane (R-290)
- A2Ls and other low-GWP alternatives
How We Can Help
We are here to help you navigate these changes with confidence:
- Evaluate your current system strategy
- Plan a phased transition aligned with your business goals
- Identify cost-effective, compliant solutions for your applications
Register for a webinar on June 10 at 1pm (CST) with Bruce Hierlmeier, Zero Zone’s Director of Regulatory Compliance & Safety, where Bruce breaks down:
- What changed (and what didn’t)
- Updated compliance timelines
- What it means for your current and future projects
- How to plan your transition with confidence
Questions?
ADDITIONAL INFORMATION
Refrigerant Data
With the large selection of refrigerants, how do you know which one is the right one for your application? With over 60 years of experience, Zero Zone knows which one is right to solve your challenge. Below is a list of refrigerants Zero Zone uses and their common applications.
| REFRIGERANT | GWP | COMPOSITION | CLASS | TYPICAL USES |
| R-717 | 0 | Ammonia | B2 | Low and medium temperature refrigeration |
| R-744 | 1 | CO2 | A1 | Low and medium temperature refrigeration, transport refrigeration, compact systems, direct expansion systems, indirect expansion systems, cascade systems |
| R-290 | 3 | HC (Natural) | A3 | Self-contained display cases |
| R-455A | 145 | HFO | A2L | Low and medium temperature refrigeration |
| R-454C | 148 | HFO | A2l | Air conditioners, self-contained units, low and medium temperature refrigeration |
| R-515B | 293 | HFO | A1 | Chillers and heat pumps |
| R-513A | 573 | HFO | A1 | Low and medium temperature refrigeration |
| R-449A | 1,280 | HFO | A1 | Low and medium temperature refrigeration, centralized and distributed systems, condensing units, cold stores |
| R-448A | 1,360 | HFO | A1 | Low and medium temperature refrigeration |
| R-134A | 1,430 | HFC | A1 | Automotive air conditioners, medium temperature refrigeration |
| R-407A | 2,107 | HFC | A1 | Low and medium temperature refrigeration |
| R-404A | 3,920 | HFC | A1 | Low and medium temperature refrigeration |
| R-507 | 3,985 | HFC | A1 | Low and medium temperature refrigeration, flooded systems |