Kyle Klahre
Director of Refrigeration

Earlier this year, the U.S. Environmental Protection Agency (EPA) announced plans to revisit the Technology Transitions rule, one of the three core pillars of the American Innovation and Manufacturing (AIM) Act. On September 30, 2025, the agency took its first meaningful step toward providing clarity for retailers navigating the refrigerant transition.

Read the article here.

The newly proposed framework directly addresses industry concerns by offering an alternative to the original rule, which many end-users found challenging due to its timeline for reducing the global warming potential of refrigerants in newly deployed systems.

Under the revised proposal, remote condensing units and supermarket systems would follow a phased compliance path: an interim GWP cap of 1,400 beginning January 1, 2026, for remote condensing units and January 1, 2027, for supermarket systems, followed by a final limit of 150 or 300 (depending on charge size and equipment configuration) by January 1, 2032. This timeline is designed to give retailers more flexibility to adopt lower-GWP refrigerants without compromising safety or operational readiness. One of the most debated aspects of the original rule was whether store remodels would trigger full compliance based on increased cooling capacity.

The EPA is now proposing a percentage-based threshold, with 25% being offered as an example. However, they’re actively seeking feedback on how this impacts supermarkets and what the appropriate limit should be for systems undergoing periodic updates. Under this proposal, remodels that increase cooling capacity by less than the threshold would not be considered new installations. This may be seen as a significant win for retailers concerned that even modest upgrades could lead to premature system replacements due to compliance issues.

The agency also has clarified that retrofits – changing refrigerants and modifying system components to ensure compatibility with the new refrigerant – are exempt from the rule, allowing for transitional strategies that lower GWP without requiring complete system overhauls. As a result, the definition of a “new system” subject to compliance would be more precisely outlined. Systems undergoing retrofits or remodels would remain outside the scope of the rule’s requirements, as long as any increase in cooling capacity stays below the specified percentage threshold.

As we noted in our earlier blog (Possible Rollback of Refrigerant Regulations?), many within the industry have been advocating for altered timelines and more precise definitions. The EPA’s reconsideration proposal looks to reflect that feedback and offer a more balanced path forward. But this isn’t a signal to slow down—it’s a moment to prepare. With bipartisan support behind the AIM Act and major retailers continuing to advance towards their sustainability commitments, the proposed framework—if adopted—is unlikely to derail the broader momentum toward lower-GWP solutions.

Retailers should also keep in mind that state-level regulations may evolve more rapidly than federal timelines, underscoring the importance of proactive planning and system design. Retailers should continue to evaluate all future low-GWP refrigerant options and design systems that can accommodate future regulatory requirements.

While reconsideration may offer much-needed clarity and flexibility for some, it’s important to remember that this is still a proposal—not final law. The EPA has opened it for public comment, and changes may follow before anything is officially adopted. That said, if the 2032 deadline remains part of the proposed framework, the direction of travel is clear. Retailers who start planning now by evaluating refrigerant options, preparing for technician training, and aligning with evolving codes will be best positioned to transition smoothly and avoid costly disruptions.

If you’re looking to learn more about what system may be right for your business or need help navigating the changing regulatory landscape, our refrigeration experts are here to help.

Please reach out to our team here: Kyle.Klahre@c-p.com.

See more in our Grocer’s Guide to Refrigeration Regulations.