EPA Finalizes Changes to "Technology Transitions" Provisions of the AIM Act

The U.S. Environmental Protection Agency (EPA) on May 26, 2026, published a final rule¹ amending its regulations under the "Technology Transitions" provisions of the American Innovation and Manufacturing (AIM) Act of 2020 (the Reconsideration Rule). EPA projects that the finalized changes would save $976 million in engineering costs, mostly for the supermarket sector, as well provide additional nonmonetized benefits. EPA also published a proposed rule² to exempt Transportation Refrigeration Units (TRUs) from leak repair requirements that EPA projects would yield an additional $1.5 billion in cost savings if finalized.

The 2023 Technology Transitions Rule

Hydrofluorocarbons (HFCs) are widely used as refrigerants (e.g., air conditioning, industrial refrigeration), propellants (e.g., in medical inhalers or defense sprays), in semiconductor manufacturing and for other purposes. They were originally developed as replacements for ozone-depleting substances, which are primarily regulated under Title VI of the Clean Air Act. Although HFCs do not deplete the ozone layer, the AIM Act was enacted into law in December 2020 to address their global warming potential (GWP) as greenhouse gases by phasing down the quantity of HFCs that can be produced or imported in the U.S. The "Technology Transitions" provision in Subsection (i) authorizes EPA to restrict the use of HFCs in certain sectors and subsectors.

The 2023 Technology Transitions Rule (2023 Rule) established³ sector-specific GWP limits for the manufacture, import or sale of certain products that use HFCs or installation of certain systems that use HFCs. For supermarket refrigeration systems, for example, the 2023 Rule set maximum GWP limits of 150 or 300. The 2023 Rule established different compliance dates for specific sectors and subsectors as well, with the latest restrictions set to come into effect January 1, 2028.

Industry groups representing the transport refrigeration, semiconductor manufacturing, and commercial air conditioning and refrigeration sectors submitted petitions for reconsideration asking EPA, citing concerns with the 2023 Rule's GWP limits and compliance deadlines. EPA granted reconsideration of these administrative petitions in June 2024. In October 2025, the agency issued a Notice of Proposed Rulemaking to amend certain requirements of the 2023 Rule.

Technology Transitions Reconsideration Rule

EPA's recent action amends the 2023 Rule by extending the compliance deadlines for certain sectors when installing new systems to transition to lower-GWP alternatives. It also increases the maximum GWP limits that apply to those sectors in the interim.

• The deadlines for installation of supermarket refrigeration systems and remote condensing units to use refrigerants that achieve 150 or 300 GWP limits (depending on charge capacity) have been extended five years and six years, respectively, to January 1, 2032. Installation of these systems will be subject to an interim limit of 1,400 GWP until then.
• The deadline has been extended six years, from January 1, 2026, to January 1, 2032, for any installation of cold storage warehouse systems to use refrigerants that achieve 150 or 300 GWP limits (depending on charge capacity). Installation of these systems will be subject to an interim limit of 700 GWP until then.
• For semiconductor manufacturing, the deadline is now January 1, 2030, to manufacture, import or install certain industrial process refrigeration equipment, systems and chillers that use HFCs that achieve specified GWP limits.
• EPA removed the deadline for installing new residential or light commercial air-conditioning or heat pump systems that use refrigerants with a GWP of 700 or greater where the systems had been manufactured or imported before January 1, 2025. The previous installation deadline had been January 1, 2026, but under the amended rule, any remaining legacy systems can continue to be installed.
• The exclusion threshold for intermodal containers used in refrigerated transport is now a box temperature of minus 35 degrees Celsius (changed from a temperature of the refrigerant entering the evaporator or fluid exiting of minus 50 degrees Celsius).
• The ban on manufacturing or importing refrigerated laboratory centrifuges and shakers with higher GWP limits has been extended two years, from January 1, 2026, to January 1, 2028.

The rule also clarifies that increasing the cooling capacity of a supermarket system by 15 percent or less (in Btu/hour) is not the "installation" of a system for purposes of the applicable compliance deadlines.

EPA projects that this rule will result in more than $900 million in saved costs compared to the 2023 Rule. EPA notes that the AIM Act "is inherently inflationary because it phases down the production and consumption of HFCs, which increases the consumer prices of goods and services that rely on or use HFCs for refrigeration or other purposes" and suggests that the Reconsideration Rule is necessary to minimize these effects while still allowing EPA to meet its obligations under the AIM Act. EPA also emphasizes the benefits of providing more flexibility in the choice of refrigerants in the residential, commercial and industrial spaces. In light of the Trump Administration's deregulatory agenda and current concerns over cost of living, the Reconsideration Rule is focused relatively narrowly on consumer-facing sectors (retail food and residential/light-commercial air conditioning) and sectors of particular technological and national security interest (semiconductors). And, notably, the rule does not alter the ultimate GWP limits in the affected sectors but merely establishes longer timelines for compliance with several of those limits.

2024 Emissions Reduction and Reclamation (ER&R) Rule Changes

EPA also announced its intent to propose changes to a second Biden-era regulations implementing the AIM Act ER&R Rule, (also called the Leak Management Rule) focused on repairing leaks and retrofitting chronically leaking appliances. The 2024 Leak Management Rule implements Subsection (h) of the AIM Act and purported to exempt TRUs from its requirements, but the Rule's 15-pound applicability threshold for appliances ended up subjecting a large number of TRUs to leak repair requirements that were not meant to apply to them. EPA's proposed technical correction would expressly exempt "all road and intermodal container TRUs, regardless of their charge size" from the Leak Management Rule's leak repair requirements. EPA indicates that it will turn next to reconsidering other aspects of its HFC regulations, including leak management, in a further bid to cut costs in particularly sensitive sectors such as residential cooling and retail food.

Implications

EPA's reconsideration of technology transition compliance deadlines for installing new systems using HFC refrigerants represents a relaxation of the current requirements to allow several industries additional time to comply, but the extension and interim compliance do not affect the ultimate requirements after 2032. Also, EPA has made no changes to the HFC allocation rule that implements the AIM Act's phasedown of HFC imports and domestic production. (Indeed, EPA continues⁴ to actively enforce the phasedown as part of its enforcement priorities.) The changes to the ER&R that are anticipated, including the TRU exemption and beyond, will also be an important aspect of EPA's overall approach to AIM Act implementation. These changes may also implicate enforcement discretion on how EPA intends to prioritize enforcement going forward.

At this time, EPA has not indicated what broader changes it may seek related to the Leak Management Rule provisions under AIM Act Subsection (h). Any changes that EPA makes to the Leak Management Rule would likely target regulatory relaxation to assist with impacts to cost of living, which remains a top priority for the public.

Finally, a number of states, including California, New York and Washington, have adopted vigorous state-level regulations for HFCs in recent years. These and other states are expected to continue their state-level efforts to address these regulated substances. Companies operating in multiple states will need to carefully track the growing patchwork of state regulation and enforcement in this area.

Holland & Knight will continue to track changes to EPA's HFC regulations. Our Environmental Team can provide advice and counseling on how these changes may impact compliance considerations going forward.

Notes

¹ 91 Fed. Reg. 31284 (May 26, 2026).

² 91 Fed. Reg. 30532 (May 26, 2026).

³ 88 Fed. Reg. 73098 (Oct. 24, 2023).

⁴ Memo from Jeffrey Hall, Acting Assistant Administrator, EPA Office of Enforcement and Compliance Assurance, Implementing National Enforcement and Compliance Initiatives Consistently with Executive Orders and Agency Priorities at 3 (March 12, 2025).

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