Final rule revises HFC use restrictions and compliance timelines for specific subsectors

On May 26, 2026, the Environmental Protection Agency (EPA) finalized a rule (2026 Final Rule) revising regulations on the use of hydrofluorocarbons (HFCs) in certain subsectors. The final rule specifically amends requirements established by the 2023 Technology Transitions Rule under the American Innovation and Manufacturing Act of 2020 (AIM Act).

EPA also published a proposed rule to exempt road and intermodal container transport refrigeration units (TRUs) from leak repair requirements set by the 2024 Emissions Reduction and Reclamation (ER&R) Rule.

Who’s impacted?

The 2026 Final Rule applies to entities that are subject to the 2023 Technology Transition Rule requirements (40 CFR 84.54) for these subsectors:

• Refrigerated transport — intermodal containers,
• Industrial process refrigeration (IPR) and chillers for IPR used in semiconductor manufacturing,
• Retail food — supermarket systems,
• Retail food — remote condensing units,
• Cold storage warehouses,
• Residential and light commercial air conditioning and heat pumps (RACHP), and
• IPR (not using chillers) — refrigerated laboratory centrifuges and refrigerated laboratory shakers.

The 2026 proposed rule applies to refrigerant-containing road and intermodal container transport refrigeration units (TRUs) regulated by the 2024 ER&R Rule.

What are the changes?

The 2026 Final Rule:

• Adjusts the lower bound temperature and measurement location for refrigerated transport intermodal containers from -50°C to -35°C;
• Extends the compliance dates to January 1, 2030, for restrictions on uses of HFCs and HFC blends by IPR and chillers for IPR in semiconductor manufacturing process equipment (limited to equipment with a charge size of 100 pounds or less);
• Allows retail food supermarket systems to increase the cooling capacity of existing systems by up to 15 percent without triggering new installation requirements;
• Establishes temporary, relaxed interim global warming potential (GWP) limits (implementing stricter GWP limits starting on January 1, 2032) for:
  • Retail food supermarket systems,
  • Retail food remote condensing unit systems, and
  • Cold storage warehouses.

• Allows RACHP equipment using specific components that were domestically manufactured or imported before January 1, 2025, to continue to be installed; and
• Delays the compliance dates to January 1, 2028, for restrictions on uses of HFCs and HFC blends by refrigerated laboratory centrifuges and refrigerated laboratory shakers.

Please note that the final rule states that EPA maintains existing requirements for new condensing units used as replacements in the RACHP subsector.

What’s the proposed rule?

The 2024 ER&R Rule added leak repair requirements (84.106) for refrigerant-containing appliances with a charge size of 15 pounds or more containing an HFC or a specific HFC substitute, which took effect on January 1, 2026. Examples of the requirements include leak inspections, appliance repairs, and reporting.

EPA proposes to exempt all refrigerant-containing road and intermodal container TRUs from the leak repair provisions (regardless of charge size).

Key to remember: EPA has issued a final rule revising HFC use restrictions for certain subsectors and has proposed a rule exempting transportation refrigeration units from leak repair requirements.