Cut Compliance Confusion: Refrigeration Regulations in 2026

Rapid policy evolution, overlapping rulemakings, and ongoing proposals have created confusion across the refrigeration industry. As we start 2026, Henderson is here to help you distinguish what is officially in effect from what remains proposed, so you can make informed, resilient decisions.  

What Is Officially in Effect (Starting January 2026) 

As of January 2026, the only legally enforceable federal requirements governing commercial refrigeration in the United States are those established by the Technology Transitions Final Rule (October 2023) under the American Innovation and Manufacturing (AIM) Act. Under this rule: 

• Remote condensing units used in retail food refrigeration are now required to comply as of January 1, 2026, with refrigerant limits of below 150 GWP for systems with charges of 200lb or greater and below 300 GWP for systems under 200lb or for the high-temperature side of cascade systems.  

• As a result, new RCU installations using higher-GWP blends such as R-448A and R-449A are no longer compliant.  

• Supermarket and central rack refrigeration systems will be subject to the same 150 / 300 GWP thresholds beginning January 1, 2027. 

What Is Proposed (Not Yet in Effect as of January 2026) 

The industry has closely followed the Environmental Protection Agency’s (EPA) October 2025 proposed rule titled Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Under the AIM Act. This proposal would temporarily adjust certain global warming potential (GWP) thresholds for specific refrigeration subsectors. While it has generated significant discussion, this rule has not been finalized or approved. Until a final rule is published in the Federal Register, it has no legal effect, and compliance obligations remain governed by the Technology Transitions Final Rule currently in force. 

Importantly, refrigerant GWP limits are only one component of the broader regulatory landscape. Additional obligations under the AIM Act are already in effect and continuing to expand, including reporting, recordkeeping, and compliance requirements under both the Technology Transitions and Emissions Reduction and Reclamation (ER&R) programs. These requirements include documentation of refrigerant type, system category, charge size, installation date, and applicable compliance pathway, supporting EPA enforcement and long-term tracking of hydrofluorocarbon (HFC) transitions. For many stakeholders, these administrative and compliance expectations will increasingly shape project planning and operational practices. 

Other Parallel Refrigerant Regulations to Watch 

The EPA continues to advance other regulatory actions that influence refrigerant selection and system design, including the proposed rule Protection of Stratospheric Ozone: Listing of Substitutes Under the Significant New Alternatives Policy (SNAP) Program in Refrigeration and Air Conditioning and Fire Suppression. Issued under the SNAP program, this proposal evaluates and updates the listing status of refrigerant substitutes based on environmental impact, flammability classification, toxicity, and use conditions. Although separate from the AIM Act, SNAP listings remain highly influential, as they determine which refrigerants are considered acceptable, or acceptable only with conditions, for specific applications. 

Parallel regulatory frameworks, including HFC phasedown caps, reporting and compliance obligations, SNAP listings, and increasingly stringent state-level requirements, continue to shape the long-term outlook. Even if the 2025 proposed reconsideration were to be finalized, these parallel regulations will continue to challenge the long-term viability of high-GWP HFC refrigerants in commercial refrigeration systems. 

Move Forward with Clarity 

Henderson remains committed to helping you navigate this evolving landscape, move confidently toward sustainability, and make decisions that are technically sound, compliant, and future-ready. We will continue to monitor regulatory developments closely and provide clear, grounded guidance to support the industry through this transition. If you have any questions on staying compliant through project planning and operational practices, we’re here to help.