Now is not the time to put the brakes on your refrigerant transition.

When most of us take a road trip we begin by determining our starting point, destination and desired arrival time. We then map out the route, including spots for food and rest. Of course, once we’re on our way, typically not everything goes as planned. We might hit detours (or worse, a pothole) or discover a favorite restaurant along the interstate is closed for renovations. While these snags aren’t ideal and may cause a short delay, they rarely, if ever, cause us to abandon the trip. In many cases, we prepare for the unexpected—from having GPS offer an alternate route to making sure there are a jack and spare in the trunk in case that pesky pothole does some damage—so we can adjust and continue toward the destination.

The HVACR industry’s transition to low-GWP refrigerants very much parallels this. Since the U.S. EPA began the HFC phasedown under the AIM Act, the “destination” has been the same—an 85% reduction in HFC production and consumption by 2036. However, as stakeholders throughout the industry are aware, the roadmap to getting there is experiencing some modifications and uncertainty. This has in large part been driven by EPA changes to the 2023 Technology Transitions (TT) Rule—finalized in May 2026—coupled with active litigation stemming from petitions filed by HARDI and other parties seeking judicial review of parts of the Rule.

A main concern around the revised TT Rule is that it extends or modifies compliance timelines for several sectors. Enabling certain sectors more time to continue to use products with higher HFC content can delay the transition to lower GWP solutions the industry has already prepared for in anticipation of the next EPA HFC stepdown in 2029. Uncertainty also comes from the EPA not yet finalizing the methodology for allocating HFC allowances available during this next significant phasedown in 2029-2033

It’s important for distributors not to consider regulatory uncertainty and the potential for some sectors to transition more slowly as a signal for them—or their customers—to pause their transition strategy. Instead, distributors can take steps to proactively maintain strong business practices and ensure they are prepared for upcoming EPA decisions and regulatory developments.

Use this time wisely

Even if the transition happens more slowly or experiences delays in certain sectors, the phasedown is happening and, by 2029, allowable HFC production and consumption will drop to 30% of the established baseline. Distributors can use this time as an advantage by:

Reexamining your forecasts and reassessing your inventory. Our teams at Chemours are having plenty of discussions with customers to help them consider what they have on hand, how their next-generation and legacy supply needs may change given the current regulatory landscape, and how they may need to adjust their refrigerant inventory strategies.

Take a cue from leading commercial retailers. What the major players are doing can offer guidance on where demand for A2L refrigerants and equipment is headed—and how quickly.

Continue to learn from your customers. Understand their business objectives and timelines for transitioning as well as their customers’ demands for new-generation and legacy refrigerants.

Continue to educate your customers and help them strategize for transition. Keep customers aware of industrywide factors that could impact refrigerant availability and pricing, answer their questions about your strategies to ensure necessary stock of new-generation and legacy refrigerants and the equipment that uses them, and offer case studies to increase confidence in A2Ls.

Make sure your staff receive proper A2L training for safe handling, storage, labeling, etc.

Follow the rules of the road

Historically—across many industries—factors such as regulatory uncertainty, high demand, reduced supply and price increases have opened doors for activities that can present risk to would-be “innocent bystanders.” For HVACR specifically, the current environment raises concerns about the emergence of counterfeit refrigerants, grey-market imports, mislabeled cylinders, and noncompliant products. All these can create risk for distributors, their contractor customers, and end-users. It’s critical that distributors remain vigilant, establish procedures to mitigate risk, and deal only with trusted, industry-respected suppliers.

Keep your “alerts” on

With key regulatory and legal decisions still to come, staying informed will help distributors understand how new developments could impact their businesses—then make necessary adjustments. Stay on top of EPA announcements, monitor news from industry trades, and pay attention to updates from HARDI and other trusted industry organizations and thought leaders.

A Smoother Refrigerant Transition Starts With Preparation

The transition to lower-GWP refrigerants has been progressing relatively smoothly. A2L-based solutions are no longer being evaluated for their viability—they are being successfully implemented. Although recent regulations may allow for a slower transition in some sectors, to consider this as a time to “wait and see” would be like sitting in your car until the road crew paves the potholes so you can pass, or for the restaurant to reopen. Not using this time wisely could prevent companies from advancing their business and sustainability goals, and impede their ability to remain compliant effectively and efficiently. Distributors and their customers can experience a “smooth drive” not by postponing their plans, but by preparing for what lies ahead.

Don’t put the brakes on your transition. Connect with Chemours for the refrigerant expertise, training, and technical support you need to keep moving forward with confidence.