What the EPA’s New Refrigerant Proposal Means for Commercial Kitchens, Foodservice Operations, and Federal Facilities

November 20, 2025
EPA logo over commercial refrigeration equipment hoses highlighting refrigerant regulation compliance.

Summary

This article explains the EPA’s proposed rule on hydrofluorocarbon (HFC) regulations under the AIM Act and how it affects refrigerant use in commercial kitchen equipment. Learn how these changes may impact walk-ins, freezers, ice machines, prep tables, and condensing systems. The post includes key takeaways, safety considerations, FAQs, and a practical checklist to help operators stay compliant and prepared.

Overview of the New EPA Proposal

The Environmental Protection Agency (EPA) recently issued a proposed rule titled:

“Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act.”

(Federal Register Document No. 2025-19438) https://www.federalregister.gov/documents/2025/10/03/2025-19438/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under

This proposal revisits portions of the 2023 Technology Transitions Rule concerning HFC refrigerants—particularly equipment-based restrictions and global warming potential (GWP) thresholds.

For commercial kitchens, restaurants, healthcare foodservice operations, grocery stores, federal facilities, and cold-storage users, the refrigerant you purchase today matters more than ever. This proposed rule clarifies timelines, adjusts certain thresholds, responds to industry feedback, and impacts the availability of refrigeration equipment across the market.

Key Changes Proposed by the EPA

1. Adjusted GWP Limits for Refrigerant-Based Systems

The EPA proposes modifying allowable GWP thresholds for categories such as:

  • Walk-in cooler and freezer systems
  • Supermarket rack systems
  • Remote condensing units
  • Industrial process refrigeration
  • Chillers used in semiconductor manufacturing
  • Refrigerated transport containers

Some sectors would see temporary higher GWP limits before transitioning to lower GWP thresholds later.

2. Additional Compliance Time for Certain Industries

The proposal includes potential deadline extensions for:

  • Semiconductor manufacturing refrigeration
  • Certain industrial process refrigerant systems
  • Some chiller categories
    This helps industries with complex or specialized refrigeration requirements adapt to lower-GWP alternatives.

3. Clarifications for Refrigerated Transport

Changes include:

  • Updating temperature threshold from –50°C to –35°C
  • Measuring temperature at the box rather than refrigerant inlet
    These updates reflect real-world equipment configurations and transportation practices.

4. Relief for Equipment Manufactured Before Certain Cutoff Dates

EPA proposes adjusting the rules for installing equipment made before January 1, 2025—especially for systems transitioning to new refrigerants like R-454B.

Why This Matters for Foodservice, Federal Facilities, and Commercial Kitchens

Refrigerant choice affects cost, compliance, and long-term serviceability

As HFC production phases down and regulations tighten, refrigerant selection becomes a strategic decision—not just a technical detail.

Examples of commercial kitchen equipment affected:

  • Walk-in coolers and walk-in freezers
  • Ice machines
  • Blast chillers
  • Reach-in refrigerators and freezers
  • Undercounter refrigerators & sandwich prep tables
  • Refrigerated chef bases
  • Display cases
  • Condensing units (remote systems)
  • Refrigerated storage rooms & cold-storage warehouses

Even when existing units can still be used, service costs and refrigerant availability may change, potentially increasing lifecycle costs.

How This Impacts Procurement, Projects, and Budget Planning

Procurement Timing Matters

If a facility installs high-GWP refrigerant equipment too close to a regulatory phase-down, retrofits or early replacements may become necessary.

Supply Chain Shifts Are Expected

Manufacturers are adjusting models, redesigning systems, and switching to refrigerants like:

  • R-290
  • R-448A
  • R-455A
  • R-449A
  • CO₂ (R-744)
    Availability and lead times may change as the industry transitions.

Total Cost of Ownership Will Be More Important

Facilities should evaluate:

  • Refrigerant compliance
  • Equipment lifespan
  • Expected refrigerant cost increases
  • Service technician availability for new refrigerants

A short-term savings on a high-GWP system may create long-term costs down the road.

Safety Considerations When Transitioning to New Refrigerants

As the industry shifts to more low-GWP refrigerants, safety becomes even more important. Many next-generation refrigerants—such as R-290 (propane) and various A2L blends—have different handling requirements than traditional HFCs.

1. Know the Refrigerant Flammability Class

  • A1: Non-flammable (R-410A, R-134a)
  • A2L: Mildly flammable (used in many new low-GWP systems)
  • A3: Highly flammable (e.g., R-290 propane)

2. Follow Manufacturer Requirements Precisely

Low-GWP systems require specific:

  • Clearance and ventilation
  • Charge-size limits
  • Electrical spacing
  • Installation procedures

Improper installation is a safety hazard and may void warranties.

3. Train Staff on Basic Refrigerant Awareness

Staff should know:

  • What refrigerant each unit uses
  • How to identify a leak
  • When equipment should be shut down
  • That makeshift fixes are dangerous

4. Maintain Safe Work Areas Around Refrigeration Units

Keep:

  • Airflow clear
  • Combustible materials away from units using R-290
  • Condenser coils clean
  • Access pathways unobstructed

5. Use Certified Technicians Only

Technicians must be trained in:

  • Handling flammable refrigerants
  • Leak detection
  • Correct recovery & charging
  • Safe storage and disposal

6. Update Safety Documentation

Keep:

  • SDS sheets
  • Updated SOPs
  • Emergency procedures
  • Refrigerant logs
  • Technician certifications

Safety should stay front and center as the market transitions to lower-GWP refrigerants.

You can also download this section as a printable compliance checklist.

How Aldevra Helps You Navigate Refrigerant Changes

As a trusted partner for commercial kitchen equipment and government facilities, Aldevra helps customers stay ahead of regulatory shifts.

Our support includes:

1. Specification and Model Selection

We help customers evaluate refrigerant type, GWP rating, charge limits, and manufacturer transition timelines to ensure purchases are future-proof.

2. Compliance-Focused Procurement Planning

We translate EPA proposals and regulatory language into practical steps for your equipment planning, budgeting, and scheduling.

3. Installation & Technical Support

Whether it’s walk-ins, condensing units, ice machines, or cold storage rooms, we ensure installations align with refrigerant requirements and industry best practices.

4. Lifecycle Cost and Risk Analysis

We help identify long-term operational considerations such as refrigerant availability, service tech training, and potential retrofit needs.

Aldevra’s goal is to ensure your next refrigeration investment is compliant today—and resilient tomorrow.

Frequently Asked Questions (FAQs)

1. Which refrigerants are being phased down?

High-GWP HFCs like R-404A, R-410A, and R-134a are the primary focus. These may become harder to source and more expensive over time.

2. Does this proposal require replacing existing equipment?

No—but older systems may face higher operating costs, refrigerant scarcity, and eventual retrofit needs.

3. What types of equipment are most affected in commercial kitchens?

Walk-ins, prep tables, chef bases, ice machines, blast chillers, and remote condensing units are all directly impacted by refrigerant rules.

4. What are good low-GWP refrigerant alternatives?

Examples include:

  • R-290 (common in reach-ins and prep tables)
  • R-448A / R-449A (for medium/low-temp systems)
  • R-455A (certain condensing units)
  • CO₂ (R-744) for larger supermarket-style systems

5. When will the new requirements begin?

This is a proposed rule, not a final rule. The EPA is accepting public comments, and timelines may shift. Planning ahead now minimizes surprises later.

6. How can Aldevra help me stay compliant?

Aldevra supports equipment selection, procurement planning, installation, and long-term lifecycle guidance to ensure your refrigerant-based systems align with regulatory expectations.

Need Guidance on Refrigerant-Compliant Equipment?

Whether you’re planning a new walk-in cooler, outfitting a commercial kitchen, supporting a healthcare facility, or purchasing equipment for a federal agency, Aldevra can help you select the right refrigerant-based system and prepare for regulatory changes.

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