EPA Scales Back Biden-Era Refrigerant Rule Amid Industry Pushback

The U.S. Environmental Protection Agency (EPA) is rethinking part of its flagship refrigerant policy. One of the most consequential environmental regulations affecting American manufacturing, construction, and the HVAC industry in decades.

In late September, the agency announced a proposal to reform the Biden-era “Technology Transitions” rule, which limits the use of hydrofluorocarbons (HFCs)—chemicals widely used in air conditioning and refrigeration that have high global warming potential. The EPA says the reforms aim to “lower costs for American families” while maintaining progress toward the United States’ long-term climate targets.

At the heart of this policy shift is the American Innovation and Manufacturing (AIM) Act, passed in 2020 with bipartisan support. The law requires the EPA to phase down HFC production and consumption by 85 percent by 2036, aligning U.S. policy with the Kigali Amendment to the Montreal Protocol—an international agreement targeting climate-warming refrigerants.

Under the Technology Transitions Program, finalized in 2023, the EPA set out rules restricting the use of high-GWP HFCs in air conditioning, refrigeration, foam manufacturing, and other industries. Beginning January 1, 2025, many common HVAC systems—particularly those using R-410A—will no longer be eligible for new installation or manufacturing.

That sweeping deadline drew concern from manufacturers, contractors, and builders who warned of inventory disruptions and compliance bottlenecks. The new proposal, introduced in September 2025, responds directly to those pressures.

The proposed rule would extend installation deadlines for certain HVAC systems and grant temporary flexibility for projects already in progress. Specifically, Variable Refrigerant Flow (VRF) systems—common in commercial and multi-unit buildings—could be installed through January 1, 2027, if manufactured before 2026.

Projects with permits issued before October 2023 may be given even more time, with potential allowances extending to January 2028.

The EPA also indicated it may revise the scope of covered products, such as residential ice makers to ensure “the rule does not impose unintended costs on consumers.” These updates are still in the proposal stage and will undergo a formal comment period before taking effect.

While many industry groups have welcomed the EPA’s willingness to revisit the timeline, the uncertainty around final deadlines continues to ripple through supply chains.

Manufacturers have already spent years retooling product lines to accommodate new low-GWP refrigerants like R-32 and R-454B—both classified as “A2L,” meaning mildly flammable and requiring updated safety standards.

The EPA maintains that the original 2023 rule could prevent up to 876 million metric tons of carbon dioxide-equivalent emissions by 2050, roughly the same as taking 200 million cars off the road for a year.

But critics argue that rigid implementation deadlines risk price hikes for consumers and equipment shortages for installers. Some business groups have urged the agency to balance climate ambition with “real-world feasibility.”

In August 2025, a federal appeals court upheld the EPA’s authority to enforce the HFC phaseout under the AIM Act, solidifying its legal foundation.

The proposed reforms are open for public comment before the EPA issues a final decision, expected sometime in early 2026. Until then, the industry remains in a state of transition: navigating legacy systems that rely on banned refrigerants while preparing for the next generation of low-GWP alternatives.

For now, existing HVAC and refrigeration systems can continue to operate legally, but new projects and retrofits must closely follow compliance dates. The EPA has also launched an Emissions Reduction and Reclamation (ER&R) Program to improve refrigerant recovery and recycling, further tightening oversight on the service side.

The refrigerant transition is one piece of a broader climate strategy that seeks to modernize infrastructure while reducing emissions. Whether the EPA’s reforms succeed in balancing affordability and environmental urgency will depend on how swiftly the market adapts and whether contractors, suppliers, and consumers can keep pace.