Heating, Air-conditioning & Refrigeration Distributors International (HARDI) strongly opposed announced changes to the Environmental Protection Agency’s Technology Transitions Rule as it applies to commercial refrigeration, including retail food refrigeration and cold storage. The changes would significantly increase demand for refrigerants that are facing a statutory decrease in supply under the American Innovation and Manufacturing (AIM) Act. These new restrictions apply to refrigeration systems used by supermarkets, retail food establishments, and cold storage warehouses when new equipment is needed; no business is required to replace systems under the AIM Act.

HARDI said the changes undermine the market certainty needed to support the ongoing HFC phasedown and risk increasing refrigerant demand beyond what the industry is legally allowed to supply.

According to HARDI estimates, the increased demand for these refrigerants could cost the refrigeration industry nearly $8 billion in refrigerant costs alone, with economic ripple effects increasing the total cost to $13 billion. HARDI warned that the impacts will not be limited to supermarkets or cold storage facilities, but will affect the broader HVACR market, including contractors, distributors, building owners, manufacturers, and consumers.

HARDI's analysis indicates that the changes will likely produce the opposite of their stated goal. Rather than lowering costs or easing the transition, extending the use of high-GWP refrigerants in major commercial refrigeration applications will increase demand for refrigerants whose supply is already being reduced by law, putting upward pressure on prices and increasing the likelihood of shortages across the HVACR market.

"This outcome is deeply disappointing, and it did not have to go this way," said Talbot Gee, CEO of HARDI. "HARDI, along with manufacturers and other industry partners, submitted data-driven comments demonstrating the real-world supply and cost consequences of allowing extended high-GWP refrigerant use in commercial refrigeration. And yet the final rule appears to reflect the preferences of a narrow segment of the food retail sector that supported the changes over the well-being of the most-affected HVACR businesses and their customers. That is not how sound rulemaking should work."

HARDI said the decision is particularly concerning because many food retailers are already moving toward lower-impact refrigeration systems, and advocacy efforts to delay the transition are increasingly disconnected from the direction many businesses have already chosen.

“The HVACR industry was preparing for this transition even before the AIM Act was signed by President Trump in 2020,” Gee added. “So it is frustrating to see those concerns sidelined in favor of changes that will increase costs for everyone. A responsible transition can’t happen smoothly with last-minute policy changes that upend the market.”

The announced rule changes did include a HARDI-supported change to repeal the installation date deadline as it applies to residential and light commercial air conditioners and heat pumps. The installation date prohibition would have had a negative impact on HVACR wholesale distributors.

Once the final changes to the rule are published, they will not take effect until 60 days after the publication date.

HARDI will continue to engage with the EPA, Congress, and all relevant parties to ensure that rulemaking reflects factual analysis and represents the needs of the full HVACR distribution community.