HFC Deadlines on January 1, 2027: What Applies

By Yevhen Kovalchuk · Updated September 2, 2026 · 5 min read

Short answer

Two HFC dates fall on January 1, 2027. New supermarket refrigeration systems face a revised interim GWP limit of 1,400, after EPA's May 2026 rule relaxed the original 150 or 300 limit. And under a December 2024 rule, certain variable refrigerant flow (VRF) systems built with pre-2026 components can only be installed until that date. Confirm the details for your equipment on EPA's pages.

Two HFC dates matter on January 1, 2027. The first is the start of the interim global warming potential (GWP) limit for new supermarket refrigeration systems, which EPA set at 1,400 in its May 2026 rule. The second is the last date to install certain variable refrigerant flow (VRF) systems that use components made or imported before 2026. Both come from rules under the AIM Act, and both have exceptions, so check the sector page on EPA’s site for your project.

What is the supermarket refrigeration deadline?

The original 2023 Technology Transitions rule set a GWP limit of 150 or 300, depending on charge size and system type, for new supermarket systems starting January 1, 2027. In May 2026 EPA revised that: law-firm summaries of the final rule report an interim limit of 1,400 for new installations from January 1, 2027, with the lower 150 or 300 limits returning on January 1, 2032. See the Technology Transitions rule update for the full context.

Why it matters: a 1,400 GWP limit is low enough to rule out R-404A (about 3,900) and R-507A, but high enough to allow certain HFC and HFO blends that were out of reach under the original limit.

Refrigerant	Approximate GWP	Under a 1,400 limit?
R-404A	about 3,900	No
R-407A / R-407F	about 1,700–1,900	No
R-448A	about 1,300–1,400	At or near the limit; check basis
R-449A	about 1,300–1,400	At or near the limit; check basis
CO2 (R-744)	1	Yes
Ammonia (R-717)	0	Not an HFC

GWP values vary by assessment report, so use the GWP basis in EPA’s rule. See R-404A replacements for details.

What about remote condensing units and cold storage?

Summaries report related changes:

Remote condensing units: an interim limit of 1,400, reported as effective from July 27, 2026.
Cold storage warehouses: an interim limit of 700 through January 1, 2032, which reports say excludes R-448A and R-449A.

If your project is a warehouse or a freezer plant, the 700 limit is the one to design to. These dates and limits come from secondary summaries; confirm them on EPA’s sector page.

What is the VRF deadline?

In December 2024 EPA published a rule on HFC use in variable refrigerant flow air conditioning and heat pump systems. Under it, new VRF systems must meet a GWP limit of 700, with a sell-through period: certain systems using components manufactured or imported before January 1, 2026 can still be installed until January 1, 2027. This is why VRF projects started in 2026 need a firm install date.

VRF is common in offices, hotels and healthcare buildings. If you are planning one, ask the manufacturer for the system’s refrigerant, the manufacture date of the components and the planned installation date. For how VRF compares with a central plant, see how a chiller works.

What about chillers and air conditioning?

The 2023 rule also set limits for comfort-cooling systems and chillers. Residential and light-commercial air conditioning moved to A2L refrigerants for new equipment; see A2L refrigerants explained. Chiller dates differ by type and use, so check EPA’s table for your chiller. For general chiller basics, see air-cooled vs water-cooled chillers.

A checklist for owners and designers

Date of each key event. Equipment manufacture date, installation date and system start-up date can all matter.
Refrigerant and GWP. Get it in writing from the manufacturer and compare it with the limit for your sector.
Sector classification. A grocery store rack, a remote condensing unit and a cold storage warehouse can be in different categories.
Contracts. Write the refrigerant and compliance date into purchase orders so a delay does not push you past a deadline.
Safety and codes. CO2, ammonia and A2L systems have their own code requirements. Check local mechanical codes; Texas adopted the 2024 editions in 2026 and local enforcement varies.
Plan for 2032. Interim limits revert to lower values; choose equipment that can last until then.

Is the date likely to move again?

It can. EPA has changed these requirements before, and some pieces of the 2026 rule drew legal and industry comment. Write contracts with an eye to the regulation in force at the time of installation, and check EPA’s pages before final purchase.

Frequently asked questions

Does January 1, 2027 ban R-404A?

No. It restricts the refrigerants allowed in new supermarket systems installed after that date. Existing R-404A systems can continue to run and be serviced.

Is 1,400 GWP a permanent limit?

Reports say it is an interim limit for new supermarket systems; the lower limits return on January 1, 2032.

Do the dates apply to equipment already installed?

Generally they apply to new equipment and installation dates, not to existing systems. Confirm for your category.

We follow these dates as SpecServis plans to enter the Central Texas market. We are looking for technicians, partners and a company to buy. See our open positions or partnership options.