Contributed by Rebecca Robinson, Environmental Compliance Manager, PPM Consultants
The Cold Open
If you work in industry, whether it’s food processing, cold storage, or keeping millions of gallons of milk from becoming a giant cheese sculpture, you’ve probably heard of the Environmental Protection Agency’s (EPA’s) refrigeration rule. The official EPA rule is found in Title 40 Code of Federal Regulations Part 84 (40 CFR 84). It’s part of the agency’s grand plan to phase down hydrofluorocarbons (HFCs), those powerful greenhouse gases that keep our freezers icy but make the planet sweat.
The EPA, backed by the American Innovation and Manufacturing (AIM) Act of 2020, wants to cut U.S. HFC use by 85% by 2036. That’s not just a small tweak—it’s like telling LeBron James he has to switch to pickleball tomorrow. Bold. Ambitious. Maybe a little sweaty.
But don’t panic! We’re going to break this down with a smile, a few bad puns, and some handy visuals.
Meet the AIM Act
In December 2020, Congress passed the AIM Act. It gave EPA three superpowers:
- Allowance Allocation Program – Sets a cap on HFC production/import and ratchets it down year after year. Think of it as your refrigerant diet plan.
- Technology Transitions Program – Establishes rules for moving industries toward low-Global Warming Potential (GWP) refrigerants in new systems.
- Reclamation & Emissions Reductions – Encourages recycling refrigerants, cutting leaks, and reducing waste.
For industry, this means: your coolers, freezers, and HVAC systems are stepping into a brand-new league.
Technology Transition
Starting January 1, 2025, EPA’s Technology Transitions Rule kicked in. Translation: new equipment must ditch the high-GWP refrigerants (like R-410A and R-404A) and move to lower-GWP alternatives.
Here are some highlights for industry:
- Stand-alone food retail refrigeration: Must use refrigerants with GWP ≤150.
- Remote condensing units: Must meet limits between 150–300 GWP by 2026.
- Chillers, residential air conditioners, and heat pumps: Same story—GWP thresholds apply.
If you’re installing a brand-new system in your plant, warehouse, or grocery store, it must comply—or be labeled “For servicing existing equipment only.”
Emissions Reduction & Reclamation
By 2029, EPA wants at least 85% of HFCs used for servicing to come from reclaimed stock—not virgin. That means reclaimers (EPA-certified companies that clean old refrigerant back to purity standards) are suddenly industry VIPs.
So, if your plant’s chiller needs a top-off in 2030, odds are you’ll be using refrigerant that’s already lived a past life. Think of it as a pair of second-hand jeans, but colder.
What This Means for Industry
Here’s the to-do list for industry leaders, maintenance managers, and facilities pros:
- Audit your systems now – Know what refrigerants you’re running and their GWP.
- Plan for replacements/retrofits – Especially for equipment nearing end of life.
- Train your techs – Many next-gen refrigerants (like A2Ls) are mildly flammable, requiring updated safety standards and codes.
- Source reclaimers – Get cozy with a reliable reclamation company. They’re about to become your new best friend.
- Budget for the transition – Yes, costs are involved. But efficiency gains and futureproofing make up for it.
Refrigerant Rising Stars
The old-school refrigerants (R-410A, R-404A) are out. Who’s in?
- Hydrofluoroolefins (HFOs) like R-454B and R-32 blends – Lower GWP, less heat-trapping power.
- Hydrocarbons like propane (R-290) and isobutane (R-600a) – Eco-friendly but flammable.
- CO₂ (R-744) – Great for industrial cold storage, with bonus eco points.
- Ammonia (R-717) – The original industrial refrigerant, still going strong.
It’s like a talent show—except instead of singing, contestants are judged on flammability, pressure, and climate impact.
Drama in the Courts
Of course, no rule is complete without some legal drama. Some manufacturers argued that EPA went too far. But in August 2025, a federal appeals court upheld the HFC phasedown rule. Translation: It appears the EPA rule is here to stay (for now), so industry better grab its compliance gloves.
Section 608—The Unsung Hero
Long before AIM, there was Section 608 of the Clean Air Act (since 1990), which still runs the show:
- Technicians must be certified (Types I–III or Universal).
- Leaks over 20% annually must be repaired pronto.
- Venting refrigerant is a big no-no.
- Records of servicing systems with ≥50 lbs refrigerant must be kept.
Think of Section 608 as the health inspector of the refrigeration world—always watching.
Why It’s Not All Doom and Gloom
Sure, the transition means costs, training, and change. But it also means:
- Lower operating costs – Newer systems are more energy-efficient.
- Future-proof equipment – No more scrambling when refrigerant bans hit.
- Better corporate sustainability scores – Green creds matter more than ever.
- Cleaner air – And, you know, helping the planet survive. Not bad perks!
The Icy Curtain Call
The EPA refrigeration rule may sound like government alphabet soup, but at its heart it’s a nudge toward greener, leaner, and safer cooling for industry. It’s about turning your cold storage warehouse or production floor into a climate-conscious operation—without melting your profits.
So, the next time you walk past a compressor humming away, picture it giving you a wink. It’s not just keeping things cold, it’s helping keep the Earth cool, too.
If you would like to discuss how these rule impact your facility, please feel free to contact me at Rebecca.Robinson@ppmco.com or (225) 410-9836.
Further Reading on This Topic
Protecting Our Climate by Reducing Use of HFCs | US EPA
New EPA Refrigerant Regulations 2025 Explained | TRADESAFE
Restrictions on the Use of Certain HFCs under Subsection (i) of the AIM Act