New EPA Refrigerant Regulations: Three Strategies for Retailers to Prepare for Compliance
Retailers face new EPA requirements that affect HVAC and refrigeration systems across big box stores, grocery chains, and convenience stores. Learn three strategies to reduce emissions, stay compliant, and plan for low-GWP refrigerants.
This Week's Contributor
New EPA Refrigerant Requirements: Implications for Retail Operations
The 2025 refrigerant regulations under the Environmental Protection Agency’s (EPA) American Innovation and Manufacturing Act—intended to reduce global warming impacts from common refrigerants used in heating, ventilation, and air conditioning (HVAC) and refrigeration equipment—are now in effect. Big box retailers, grocery chains, and convenience store chains are primary targets for enforcement because they operate thousands of large retail refrigeration systems that are major sources of high global warming potential (GWP) emissions, primarily from hydrofluorocarbon (HFC) refrigerant leaks.
Retailers, facility managers, and HVAC service providers must adopt low-GWP refrigerants and comply with stricter monitoring, leak detection, and reporting mandates to avoid fines and operational risks. Here are three strategies to plan ahead and embrace these changes now, mitigating associated risks and even leading to competitive advantages.
Strategy 1: Integrate Change Management, Equipment Planning & Future Readiness
The EPA’s strategy for transitioning to lower GWP refrigerants is similar to how electronics manufacturers apply planned obsolescence to encourage replacement of older equipment. This presents new challenges and adds complexity for retailers.
- Be aware of challenges. Unlike past refrigerant transitions, this time no drop-in next-generation HFC replacement refrigerants meet the EPA’s new criteria. Next-generation refrigerants often require hermetically sealed compressors and other specialized components, making them unsuitable and unsafe for use as replacement refrigerants in existing equipment. Organizations should expect more complexity in equipment repair and replacement decision-making. Existing HFC refrigerants will remain available for repairs but are being purposefully phased down by the EPA. Refrigerant manufacturers have production caps that restrict and deter mass production of high-GWP HFC refrigerants. Higher costs and reduced availability of phased-down HFC refrigerants are inevitable.
- Formulate solutions and plan accordingly. Reclaiming untainted refrigerant should be a priority, and this reclaimed refrigerant inventory should be treated as a valuable company asset. Reclaimed refrigerant can be reused in company-owned equipment across an organization, helping reduce refrigerant costs and other leak-related challenges. HFC refrigerant removed from decommissioned equipment should be properly stored by the organization in recovery cylinders. Plan equipment repair and replacement strategies in advance to avoid reactive, on-the-spot repair decisions. Create a standardized equipment purchasing strategy that accounts for equipment obsolesce, adjusting both budgeting and capital expenditure expectations accordingly.
Strategy 2: Implement New Reporting & Regulatory Compliance
Most retail chains will be affected by the new EPA regulations and will need to take quick and decisive action.
EPA-Regulated Equipment Reporting: Enforcement of the new 15-pound refrigerant-charged equipment regulation begins January 1, 2026. Previously only equipment charged with 50 pounds was regulated, the biggest impact for retailers will be felt on medium-sized HVAC equipment, such as rooftop AC units (RTUs), where millions of previously unregulated refrigeration systems must start being tracked and have leaks reported. This requires retailers to first determine which equipment is regulated so they can collect pertinent equipment details and formulate an EPA-regulated equipment reporting plan. Professional assistance may become necessary.
Mandatory Refrigerant Leak Reporting and Follow-Up: Leak reports from regulated appliances are due by March 1 of the following year. Hard or electronic copies of reports must be maintained; include submittals of leak repair and retrofit plans; and document full refrigerant charge, and the type of leak detection used, if any.
Appliances that leak 125% or more of their full charge within a calendar year are considered chronically leaking and have additional reporting requirements. Leak reports must detail efforts taken to locate and repair all leaks, and records should be maintained for three years. There is a 30-day window to report retirement or a retrofit plan for equipment that exceeded the 125% leak rate. Note that these systems commonly require periodic follow-up leak verification tests.
State Program Reporting: Select states, such as California, New York, and Washington, have enacted their own reporting regulations that are generally more stringent than those of the EPA. Building codes in certain states may require additional reporting or special use permitting for equipment charged with refrigerants that have flammability characteristics.
Compliance Reporting: Organizations committed to sustainability reporting should include refrigerant leaks as scope 1 “fugitive” emissions. Best practices include tracking all refrigerant leaks, not only leaks from regulated equipment.
Strategy 3: Recognize Low-GWP Refrigerants as the New Standard
Although HFC refrigerants will remain available for repairs during the EPA phase-down, prohibitive costs and limited availability will drive the purchase of new equipment that uses natural and synthetic next-generation refrigerants. Here are the most relevant next-generation refrigerant types, GWP criteria for new and existing buildings, ideal applications, and notable concerns or limitations by refrigerant type.
Natural Refrigerant Options (GWP From 0 to 3 but Limited Applications):
- Propane (R-290) is an excellent and efficient refrigerant allowed for use in some small self-contained refrigeration units, such as coolers, freezers, ice makers, and coin-operated soda dispensers. Refrigerant charge allowed in equipment is strictly limited for certain equipment applications due to high flammability of the refrigerant.
- Carbon Dioxide (R-744) is a suitable choice for medium to large commercial retail equipment and central refrigeration systems. System characteristics and suitability differ by climate zone. Higher discharge temperatures and heat-transfer properties make CO2 systems ideal for reclaiming usable heat for hot water, dehumidification, and space heating applications.
- Ammonia (R-717) is an excellent and efficient choice for retail refrigerated distribution centers and cold storage facilities. It has higher up-front system installation costs and is not ideal for retail spaces due to refrigerant toxicity and increased Occupational Safety and Health Administration scrutiny.
Synthetic Refrigerants for New Equipment in Existing Buildings (GWP Less Than 700): Utilize various A2L next-generation refrigerants, depending on state building codes. A2L refrigerants are mildly flammable and not suitable as replacement refrigerants for existing equipment; they are for new equipment only.
Synthetic Refrigerant Options for New Facilities (GWP Less Than 150): Only some next generation synthetic refrigerants meet the GWP threshold for new facilities. New facilities will likely need equipment charged with natural refrigerants, very low-GWP A2L refrigerants, or hydrofluoroolefin refrigerants to meet this criterion. Pay attention to state building codes, per-polyfluoroalkyl substances toxicity concerns, and flammability ratings.
Next Steps for Compliance & Efficiency
Amid rapid change and complexity, taking action can feel overwhelming. A helpful first step is to consider a professional refrigeration-focused site audit to assess the needs of a specific facility or to guide organizational-wide planning.
APTIM provides comprehensive support for retail refrigeration compliance, including:
- Refrigeration-focused site audits
- ASHRAE-level audits
- EPA-compliant refrigerant charge verifications
- HVAC and refrigeration capital equipment inspections with usable life projections
- Utility bill data capture with trend analysis
- Utility rate structure verification
- Energy management services
APTIM also assists with targeted equipment optimization, upgrade recommendations, retro-commissioning audits, and refrigeration load versus capacity (“load calc”) analysis for rack systems. We help organizations implement strategies that reduce risk, improve efficiency, and support sustainability goals.
Learn more about APTIM’s sustainability solutions or contact our team to schedule a site audit and take the first step towards efficient, compliant, and sustainable refrigeration operations.
Published December 2025
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