EPA Signals Change on GWP Refrigeration Thresholds

The regulatory landscape continues to evolve, shaping how building systems, refrigeration, and sustainability strategies are implemented across the industry. As part of the ongoing refrigerant transitions, the U.S. Environmental Protection Agency (EPA) recently published a proposed rule in the Federal Register under the American Innovation and Manufacturing (AIM) Act on October 3, 2025. This proposal outlines notable updates to refrigerant use in commercial refrigeration racks, condensing units, and cold storage facilities.  

At Henderson Engineers, our refrigeration experts help clients stay ahead of these changes. We interpret emerging policies, assess their technical and operational impact, and develop strategies that maintain efficiency and reliability. We help you get the information you need to make informed, data-driven decisions that safeguard your long-term investments and help all of us work towards a more sustainable future.  

Extended Deadlines and Raised GWP Thresholds 

The proposed rule extends compliance deadlines and raises global warming potential (GWP) thresholds for refrigerants. By shifting from earlier, more stringent drafts, the EPA recognizes the practical challenges facing the industry, including equipment availability, workforce training, and capital planning. 

For example, A2L display cases remain limited in the U.S. market. This proposal effectively provides manufacturers, contractors, and end-users additional time to align supply chains and investment strategies as the transition toward lower-GWP systems continues. 

What’s Changing: 

• Cold storage warehouses: Maximum GWP 700 starting in 2026. A GWP limit of 150/300 starting in 2032. 

• Retail food refrigeration and condensing units: Maximum GWP 1400 starting in 2026 for remote condensing units and starting in 2027 for supermarket systems. A GWP threshold of 150/300 starting in 2032. 

• Transitional refrigerants remain allowed (e.g., R-448A, R-449A, R-32), giving operators additional options during the market transition. 

Understanding the Shift 

While this proposal relaxes some near-term restrictions, it underscores the ongoing need for long-term planning. Many commonly used hydrofluorocarbons (HFCs) and hydrofluoroolefins (HFOs) refrigerants have high GWP values and contribute to climate change, making a gradual but steady transition to ultra-low-GWP options inevitable. 

Globally, the transition away from HFCs under the AIM Act remains a cornerstone of climate policy. Although the proposed rule introduces flexibility, the ultimate goal to move toward sustainable, lower-emission systems remains unchanged. 

Henderson Designs Future-Focused Refrigeration 

These regulatory changes reflect a balance between sustainability goals and market readiness. At Henderson, we help our clients interpret evolving rules and turn them into practical, future-ready design strategies. We collaborate closely with facility operators to evaluate refrigerant inventories and retrofit opportunities, align compliance timelines with capital planning, and incorporate low-GWP technologies when feasible.  

Every facility has unique refrigerant needs affected by equipment types, climate zones, and retrofit feasibility. We are here to guide you through a customized path towards compliance, ensuring your systems remain efficient, reliable, and ready for what’s next.