Heating, Air-conditioning & Refrigeration Distributors International (HARDI) and two other HVACR trade groups filed a legal challenge to portions of the Environmental Protection Agency’s Technology Transitions Reconsideration Rule.

HARDI, Plumbing-Heating-Cooling Contractors – National Association (PHCC) and Air Conditioning Contractors of America (ACCA) announced the challenge June 25, saying amended provisions in the EPA rule will increase demand for hydrofluorocarbon refrigerants in supermarket, retail food and cold storage applications while HFC supply is being reduced under the American Innovation and Manufacturing Act.

The groups said the final rule’s treatment of commercial refrigeration is at odds with the AIM Act and could destabilize refrigerant markets. The Technology Transitions program is the EPA framework that restricts the use of higher-global warming potential HFCs in certain sectors and subsectors as the U.S. transitions toward lower-GWP alternatives.

The EPA’s May 2026 reconsideration rule addressed petitions and requests from companies and trade associations across several subsectors, including refrigerated transport, semiconductor manufacturing-related refrigeration and chillers, retail food refrigeration systems, supermarkets, cold storage warehouses, certain laboratory equipment, and residential and light commercial air conditioning and heat pump systems.

HARDI, PHCC and ACCA said they specifically oppose the EPA’s decision to extend deadlines for major commercial refrigeration applications, which they said allows the continued manufacture of new systems using higher-GWP refrigerants. The groups argued that the extensions will increase demand for legacy refrigerants even as the AIM Act’s statutory phasedown reduces supply.

The associations said the commercial refrigeration changes could reduce refrigerant availability for other sectors, including residential air conditioning. PHCC CEO Cindy Sheridan said the EPA’s own analysis projects a 12% to 24% increase in U.S. refrigerant prices by 2029 as a result of the delays.

The groups also said they support EPA’s decision to provide relief from installation prohibitions for existing split-system residential and light commercial air conditioners and heat pumps. HARDI said that policy avoids stranded inventory and disruption for distributors, contractors, builders and consumers.

The petitioners argued that the rule’s rationale rests on the premise that the original Technology Transitions Rule had already increased grocery costs, even though the commercial refrigeration restrictions at issue had not yet taken effect. They also emphasized that the original rule applied to new equipment and did not require grocery stores, cold storage operators or other businesses to replace existing systems.

MDM Analysis

For HVACR distributors, the key issue to watch is whether the challenge changes the compliance path for commercial refrigeration and how quickly refrigerant supply-and-demand pressure shows up in pricing. Even if the legal dispute narrows around supermarket, retail food and cold storage applications, the downstream effects could reach broader HVACR markets through refrigerant availability, inventory planning, customer guidance and state-level regulatory uncertainty.