A new white paper released today by Heating, Air-conditioning & Refrigeration Distributors International (HARDI) warns that enforcement of New York’s high-GWP bulk refrigerant prohibition under 6 NYCRR Part 494 could significantly disrupt food retail operations across the state, increasing costs for consumers and threatening access to fresh food in vulnerable communities. The report, Measuring the Impact of New York’s Refrigerant Prohibition and the Impact of Shortages on Food Retail Infrastructure, models the operational and economic consequences of prohibiting the sale of virgin R-404A and R-507A refrigerants beginning March 31, 2026.

HARDI’s analysis finds that enforcement of Part 494 will directly affect an estimated 18,130 refrigeration systems in New York grocery and convenience stores that rely on R-404A and R-507A. Servicing this installed base requires approximately 1.16 million pounds of refrigerant annually, yet historical nationwide reclaimed supply averages only about 606,000 pounds per year — roughly half of New York’s projected needs. Under a moderate disruption scenario, the report estimates an annual reduction of $106.2 million in statewide economic output.

“Refrigeration is not optional for food retailers. It is fundamental to food safety, public health, and community well-being,” said Alex Ayers, vice president of government affairs at HARDI. “This report demonstrates that restricting access to service refrigerants before the market is ready risks unintended economic and community consequences across New York.”

New York is home to more than 24,000 licensed retail food establishments, many of which operate refrigeration systems designed to last 15 to 25 years. If refrigerant access is restricted, routine servicing and emergency repairs may become harder to address. The impacts would likely fall hardest on small and independent grocers, particularly in rural and low-income communities where a single store often serves as the primary source of fresh food. Increased service costs and supply disruptions may ultimately translate into higher consumer prices and reduced food access, compounding economic pressures already facing New York households.

“It is time for the legislature to step in and prevent this crisis from happening while ensuring the same environmental benefits are achieved by aligning New York with the federal phasedown,” Ayers continued. “The Department of Environmental Conservation ignored the increased economic costs associated with Part 494; the legislature can protect communities across the state while protecting its climate leadership by replacing Part 494 before it destroys local small businesses.”

The white paper also highlights Assembly Bill A.9596 and Senate Bill S.9066, which would replace Part 494’s prohibition with the federal transition schedule. According to the analysis, legislative action could prevent a regulatory supply shock and facilitate a coordinated, beneficial refrigerant transition. 

Download the full white paper for more information here.