HARDI, PHCC, and ACCA Launch Legal Action Against EPA's New Refrigerant Rule
On June 25, 2026, a formidable coalition comprising the Heating, Air-conditioning, and Refrigeration Distributors International (HARDI), the Plumbing, Heating, Cooling Contractors National Association (PHCC), and the Air Conditioning Contractors of America (ACCA) declared their legal challenge against some key aspects of the Environmental Protection Agency's (EPA) Technology Transitions Reconsideration Rule. This regulation introduces amendments that would increase the demand for hydrofluorocarbon (HFC) refrigerants in sectors such as supermarkets, retail food, and cold storage. However, as the law mandates a reduction in the supply of these refrigerants, the rule is viewed as a direct violation of the American Innovation and Manufacturing (AIM) Act, which could destabilize the refrigerant market significantly.
"The EPA's decision to entirely disregard the timelines for transitioning to next-generation refrigerants, as proposed by the industry back in 2021, fundamentally misses the point," stated Talbot Gee, the CEO of HARDI. He criticized the final reconsideration rule's stance on commercial refrigeration as not only legally flawed but also economically reckless. He emphasized that this ruling ignores substantial industry data and over a decade of preparation for this transition, contravening the requirements mandated by the AIM Act. HARDI remains committed to challenging regulatory agencies that infringe upon the law concerning regulations impacting their sector.
The coalition vehemently opposes the EPA's decision to extend the deadlines for significant commercial refrigeration applications, which would permit the ongoing manufacture of new systems utilizing high-global warming potential refrigerants. According to the AIM Act, there should be a phasedown of HFC supply throughout the economy; therefore, while the supply continues to dwindle, the final rule inadvertently raises the demand for these refrigerants.
Cindy Sheridan, the CEO of PHCC, pointed out that the members of PHCC are actively aiding customers in adapting to refrigerant changes daily. Allowing outdated refrigerants to be utilized for extended periods in new commercial refrigeration systems adds confusion for contractors responsible for installing and servicing this equipment, negatively impacting consumers. The EPA's analysis suggests that due to these delays, there will be a 12% to 24% spike in U.S. refrigerant prices by 2029 as the AIM Act will further restrict the availability of these older refrigerants to promote the domestic production of next-generation alternatives.
Additionally, permitting the prolonged use of legacy HFCs in retail food refrigeration and cold storage undermines the refrigerant supply for other essential areas, such as residential air conditioning.
"While ACCA acknowledges the EPA's removal of the installation deadline for R-410A split-system equipment, the postponed refrigeration transition will substantially amplify demand for the already limited supply of HFC refrigerants, leading to rising costs for both contractors and their clients," explained Martin Hoover, ACCA's Interim President and CEO. He cautioned that this policy change might incite a hurried transition to highly flammable A3 refrigerants, prompting a fragmented regulatory landscape across different states.
Interestingly, while the joint petitioners commend the EPA for relieving the installation ban on existing split-system residential and lightweight commercial air conditioners and heat pumps—an initiative they've long advocated to prevent stranded inventory and ensure seamless operation for distributors, contractors, builders, and consumers—they remain critical of the final rule's underlying rationale. They argue that it rests on the inaccurate assertion that the original Technology Transitions Rule led to increased costs for grocery consumers. These restrictions on commercial refrigeration hadn't taken effect when the EPA presented the reconsideration rule, and thus, could not possibly have contributed to soaring grocery prices.
The trade associations reiterated that the initial Technology Transitions Rule pertained exclusively to new equipment, not mandating grocery stores, cold storage operators, or other businesses to replace their existing systems, allowing for continued usage and service of current equipment.
"The EPA's decision to entirely disregard the timelines for transitioning to next-generation refrigerants, as proposed by the industry back in 2021, fundamentally misses the point," stated Talbot Gee, the CEO of HARDI. He criticized the final reconsideration rule's stance on commercial refrigeration as not only legally flawed but also economically reckless. He emphasized that this ruling ignores substantial industry data and over a decade of preparation for this transition, contravening the requirements mandated by the AIM Act. HARDI remains committed to challenging regulatory agencies that infringe upon the law concerning regulations impacting their sector.
The coalition vehemently opposes the EPA's decision to extend the deadlines for significant commercial refrigeration applications, which would permit the ongoing manufacture of new systems utilizing high-global warming potential refrigerants. According to the AIM Act, there should be a phasedown of HFC supply throughout the economy; therefore, while the supply continues to dwindle, the final rule inadvertently raises the demand for these refrigerants.
Cindy Sheridan, the CEO of PHCC, pointed out that the members of PHCC are actively aiding customers in adapting to refrigerant changes daily. Allowing outdated refrigerants to be utilized for extended periods in new commercial refrigeration systems adds confusion for contractors responsible for installing and servicing this equipment, negatively impacting consumers. The EPA's analysis suggests that due to these delays, there will be a 12% to 24% spike in U.S. refrigerant prices by 2029 as the AIM Act will further restrict the availability of these older refrigerants to promote the domestic production of next-generation alternatives.
Additionally, permitting the prolonged use of legacy HFCs in retail food refrigeration and cold storage undermines the refrigerant supply for other essential areas, such as residential air conditioning.
"While ACCA acknowledges the EPA's removal of the installation deadline for R-410A split-system equipment, the postponed refrigeration transition will substantially amplify demand for the already limited supply of HFC refrigerants, leading to rising costs for both contractors and their clients," explained Martin Hoover, ACCA's Interim President and CEO. He cautioned that this policy change might incite a hurried transition to highly flammable A3 refrigerants, prompting a fragmented regulatory landscape across different states.
Interestingly, while the joint petitioners commend the EPA for relieving the installation ban on existing split-system residential and lightweight commercial air conditioners and heat pumps—an initiative they've long advocated to prevent stranded inventory and ensure seamless operation for distributors, contractors, builders, and consumers—they remain critical of the final rule's underlying rationale. They argue that it rests on the inaccurate assertion that the original Technology Transitions Rule led to increased costs for grocery consumers. These restrictions on commercial refrigeration hadn't taken effect when the EPA presented the reconsideration rule, and thus, could not possibly have contributed to soaring grocery prices.
The trade associations reiterated that the initial Technology Transitions Rule pertained exclusively to new equipment, not mandating grocery stores, cold storage operators, or other businesses to replace their existing systems, allowing for continued usage and service of current equipment.
Topics Policy & Public Interest）
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