Understanding the 2026 EPA Refrigerant Mandate: What Facilities Need to Know
The refrigeration industry is entering one of the most significant regulatory shifts in decades. Driven by the American Innovation and Manufacturing (AIM) Act, the United States is rapidly phasing down the use of high–global warming potential (GWP) refrigerants—most notably traditional hydrofluorocarbons (HFCs).
Beginning on January 1, 2026, high-GWP refrigerants will no longer be permitted in new commercial or industrial refrigeration systems. Existing systems may continue operating and can still be serviced, provided repairs do not require a full system replacement.
This mandate has major implications for facility operations, capital planning, maintenance programs, and environmental compliance. Understanding what’s changing—and how to prepare—will help facility leaders avoid disruption and control long-term costs.
Why the EPA Is Making This Change
The AIM Act, passed in 2020, directs the Environmental Protection Agency to reduce HFC production and consumption by 85% by 2036. HFCs, while effective refrigerants, are potent greenhouse gases with significantly higher warming potential than carbon dioxide.
The phasedown began in 2022 and is enforced through the Technology Transition Rule, finalized in October 2023. This rule establishes maximum allowable GWP limits for refrigerants used in newly manufactured equipment across multiple sectors.
By implementing these limits, the EPA aims to:
Reduce the environmental impact of refrigeration systems
Encourage adoption of lower-GWP refrigerant alternatives
Align U.S. standards with global climate initiatives
Drive innovation in equipment design and efficiency
What the 2026 Mandate Means for Your Facility
The impact of the mandate varies depending on equipment type, refrigerant charge size, and application. Different sectors have different GWP thresholds and compliance timelines, making it critical for facility teams to understand how the rule applies to their specific assets.
Below is a simplified overview of key requirements.
Retail & Commercial Refrigeration
For retail and commercial applications, the following limits apply to new systems:
Remote condensing units with refrigerant charges ≥ 200 lbs.
GWP limit: 150
Remote condensing units with refrigerant charges < 200 lbs.
GWP limit: 300
High-temperature side of cascade systems
GWP limit: 300
Self-contained stand-alone units
Required to meet a GWP limit of 150 by 2025
All retail refrigeration systems
Limited to a GWP of 300 by 2027
These changes will significantly influence equipment selection, replacement strategies, and refrigerant availability across retail environments.
Industrial Refrigeration Applications
Industrial facilities face a different set of requirements based on system design and operating conditions:
Industrial process refrigeration (chillers) using existing fluid ≤ -22°F
GWP limit: 700
Industrial process refrigeration not using chillers
GWP limit: 300
Cold storage warehouses
GWP limit: 300
As with commercial systems, these limits apply only to new equipment. Existing systems can continue operating indefinitely unless fully replaced.
Refrigerants Being Phased Out
Several commonly used refrigerants will no longer comply with EPA requirements for new equipment installations due to their high GWP values, including:
R-404A (GWP 3,920)
R-448A (GWP 1,360)
R-134A (GWP 1,430)
Facilities operating systems charged with these refrigerants should begin planning for future transitions, especially if equipment is approaching end-of-life or experiencing frequent leaks.
What Facility Managers Should Do Now
Although 2026 may seem distant, the effects of the mandate are already being felt across the industry. Equipment redesigns, refrigerant supply changes, and evolving service practices are happening now.
A proactive approach can help facilities avoid last-minute decisions and unexpected costs. Key steps include:
Reviewing your current refrigeration inventory and identifying refrigerant types in use
Flagging equipment nearing end-of-life or with recurring leak history
Incorporating refrigerant tracking, leak detection, and documentation into EMS and PM programs
Ensuring technicians and service partners are trained on EPA Section 608 requirements
Monitoring state-level regulations, which may be more restrictive than federal rules
Planning capital budgets with future-compliant equipment in mind
Early preparation allows facility teams to align maintenance strategies, compliance requirements, and long-term planning well ahead of enforcement deadlines.
Preparing for Compliance Is About More Than Equipment
The 2026 EPA Refrigerant Mandate is not just an equipment issue—it impacts operations, documentation, training, and environmental accountability. Facilities that start planning now will be better positioned to maintain compliance, control costs, and minimize disruption as the industry transitions to lower-GWP solutions.
Staying informed and proactive is the key to navigating this regulatory shift successfully.
