Trump EPA rolls back HFC refrigerant phaseout under AIM Act

Congress passed the American Innovation and Manufacturing Act on December 27, 2020, as part of the Consolidated Appropriations Act, with broad bipartisan support. The law authorizes the EPA to reduce U.S. hydrofluorocarbon production and consumption by 85% from baseline levels by 2036. It also directs EPA to restrict HFC use by sector — a first-of-its-kind authority written specifically to implement U.S. obligations under the Kigali Amendment to the Montreal Protocol.

The Senate ratified the Kigali Amendment on September 21, 2022, with a 69-to-27 bipartisan vote. Under Kigali, developed nations committed to cutting HFC production by more than 80 percent over 30 years. The AIM Act and Kigali together established the legal and diplomatic foundation the Biden EPA used to set sector-specific compliance deadlines.

The Biden EPA finalized the Technology Transitions Rule in 2023, setting GWP (global warming potential) limits on refrigerants used in new supermarket systems starting January 1, 2027, with limits of 150 or 300 GWP depending on system size. Cold storage warehouse deadlines were set for 2026. The rule also established a January 1, 2026, installation deadline for residential and light commercial air conditioners using refrigerants with a GWP above 700.

HFCs are measured by GWP relative to carbon dioxide, which has a GWP of 1. R-410A, the dominant air conditioning refrigerant through 2025, has a GWP of 2,088. HFC-134a, common in commercial refrigeration, has a GWP of 1,430. Some widely used HFCs carry GWPs exceeding 14,000 times that of CO2.

On May 21, 2026, President Trump and EPA Administrator Lee Zeldin announced a final rule revising the Technology Transitions requirements. Zeldin said, "Today, the Trump EPA is fulfilling President Trump's promise to lower costs and is fixing every problem we can under the authority Congress gave us." The rule extended supermarket compliance deadlines from 2026-2027 to 2032 and temporarily raised the allowable GWP limit for supermarket systems from 150-300 to 1,400 — nearly ten times the Biden standard — through January 1, 2032.

For cold storage warehouses, EPA temporarily raised the GWP limit to 700 beginning 60 days after Federal Register publication through January 1, 2032. The administration also removed the January 1, 2026, installation deadline for residential and light commercial air conditioning systems using pre-2025 equipment, allowing contractors to install existing inventory until it runs out.

The Trump White House published a fact sheet claiming the rule changes will generate $2.4 billion in total savings, with over $800 million tied to lower grocery costs. Trump said the rollback would directly reduce what shoppers pay at checkout. Independent economists and industry trade groups disputed the logic: supermarket operators work on razor-thin margins and have no structural mechanism to pass equipment cost savings to customers as lower food prices.

The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and the Alliance for Responsible Atmospheric Policy argued the rollback would likely raise, not lower, refrigerant prices. Manufacturers had already retooled production lines and trained workforces for next-generation low-GWP refrigerants. Extending old-refrigerant deadlines increases demand for refrigerants whose supply is shrinking, which drives prices up, not down.

The Natural Resources Defense Council pushed back sharply on the EPA action. David Doniger, senior strategic director of NRDC's Climate and Clean Energy Program, said EPA had derailed the shift away from climate super-pollutants by catering to a small group of lagging companies. NRDC calculated that each year of delay from the rollback adds HFC emissions equivalent to one million additional cars on U.S. roads.

NRDC had already filed a separate lawsuit against the EPA over the administration's earlier rollback of HFC leak prevention rules. The Technology Transitions rollback announced May 21 is a distinct action affecting sector-specific use deadlines — not the leak rules — and opens a new avenue for legal challenge under the APA's arbitrary-and-capricious standard.

The AIM Act's legal structure constrains how far Trump's EPA can push back on the phasedown. Congress set the 85% reduction target and 2036 deadline in statute — EPA can adjust sector-by-sector compliance schedules within that mandate, but can't eliminate the overall reduction target. The Trump administration's rule explicitly keeps the long-run statutory targets in place while extending the near-term compliance windows.

Legal experts at Harvard Law's Environmental and Energy Law Program have tracked the AIM Act regulatory history and noted that EPA's authority to grant compliance relief must still meet APA notice-and-comment requirements and survive arbitrary-and-capricious review. The Biden-era deadlines were themselves the product of a rulemaking process; unwinding them requires EPA to justify why the record that supported the original rule no longer holds.

Lee Zeldin, a former Republican congressman from New York, was confirmed as EPA Administrator on January 29, 2025, by a 56-to-42 Senate vote. Three Democratic senators — John Fetterman of Pennsylvania, Ruben Gallego of Arizona, and Mark Kelly of Arizona — voted to confirm him. Zeldin had no prior environmental regulatory experience, and environmentalists raised concerns during his confirmation hearings that he would prioritize deregulation over climate commitments.

Since taking office, Zeldin has overseen some of the most aggressive EPA deregulatory actions in the agency's history, including rollbacks of methane rules, particulate matter standards, and now the HFC Technology Transitions deadlines. The HFC rollback is his most significant climate action to date in terms of projected greenhouse-gas impact.

The United States is a party to the Montreal Protocol and its Kigali Amendment, both of which require HFC reductions. The Trump administration's technology transitions rollback doesn't formally violate the Kigali Amendment's 2036 endpoint, since the statutory 85% target remains in law. But slowing the near-term pace of transition has diplomatic implications: the U.S. was credited with leading the global HFC phasedown at Kigali in 2016, and the rollback signals to trading partners that U.S. climate commitments are subject to reversal by executive action.

Industry groups that support the phasedown — including manufacturers who have invested in next-generation refrigerant equipment — warned that regulatory whiplash disrupts investment planning across the entire HVAC and refrigeration supply chain and could make U.S. manufacturers less competitive with European and Japanese firms that have already completed their transitions.

The congressional debate over the AIM Act had unusual cross-party dynamics. Republicans supported HFC regulation as a jobs and competitiveness measure: U.S. chemical manufacturers including Honeywell and Chemours had invested heavily in next-generation low-GWP refrigerants and stood to profit from the transition. The act passed as part of a year-end omnibus without controversy.

Six years later, Trump's EPA positioned the rollback as a cost-of-living win. The same industries that lobbied for the AIM Act's passage are now split: companies that completed their transitions want the deadlines kept, while companies seeking compliance relief backed the rollback. That industry divide contradicts the administration's claim that the rollback is universally good for business.