Green America is building on our climate success of moving the entire telecoms industry to clean energy by taking on one of the largest climate polluters: refrigerator gases.

We and our supporters are getting major supermarket chains to deal with their polluting refrigerants, and Walmart, Trader Joe’s, and Kroger are all making progress as a result. But now, Trump's EPA has proposed new rules attempting to stall this progress. So, Green America is pushing back and submitted the following comments:

November 17, 2025 

Administrator Lee Zeldin 

U.S. Environmental Protection Agency 

RE: Docket ID No. EPA-HQ-OAR-2025-0005 

Via: Regulations.gov 

Dear Administrator Zeldin, 

Green America is a national nonprofit organization working with consumers, businesses, and investors to create a green economy.  We have 250,000 individual members and 500 business members nationwide. 

Green America is writing in opposition to the EPA’s proposed rule: Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020 (EPA-HQ-OAR-2025-0005). The proposed rule will create unnecessary delays in phasing out climate warming refrigerants and harm American innovation and job creation that is being created by the current implementation of the AIM Act. 

In the retail sector, changing the January 1, 2027, GWP limit on retail refrigeration equipment to 1400, from its original limit of 150 or 300, depending on charge size and equipment configuration, and delaying the enforcement of stricter limits to January 1, 2032, will dramatically increase climate emissions from refrigeration and increase the risk that stores will adopt refrigerants that produce PFAS substances.  Furthermore, the delay is unnecessary in light of transition efforts underway by retailers and will disrupt plans that are in place by US manufacturers and HVAC companies to scale up production of natural, ultra-low GWP refrigerants, equipment, and services in time to meet the deadlines of the original rule.   

Green America works to encourage the supermarket sector to transition to ultra-low natural GWP refrigerants to reduce the sector’s substantial climate footprint and create U.S. jobs in the transition to these refrigerants. As you know, climate change is already creating a detrimental impact in the U.S. resulting in catastrophic fires, storms, hurricanes, droughts, and rising sea levels. And the growing impacts of climate change, including the number of storms, each causing over a billion dollars of damage, are causing increasing economic harm to business, investors, and consumers.  

The need for the AIM act and EPA regulations to phase down hydrofluorocarbons (HFCs) is clear. For example, a typical supermarket consumes 4,000 pounds of refrigerants each year with a quarter leaking out due to faulty systems. 

Refrigerant leaks from US supermarkets emit 45 million metric tons of greenhouse gases every year (the equivalent of 9.5 million cars on the road).  

Green America urges supermarkets to address the climate impact of refrigerants by:  

• Using only HFC-free, natural refrigerant systems in all new locations; 

• Releasing concrete timelines to phase out HFCs from all facilities by 2030;  

• Rapidly repairing refrigerant leaks and publishing annual leak rates; 

• And ensuring responsible refrigerant disposal to reduce emissions.   

In addition to their strong environmental benefits, utilizing natural, ultra-low GWP refrigerants provide cost savings, including significantly reduced operating costs through higher energy efficiency.  National and local supermarkets are successfully adopting natural, ultra-low GWP natural refrigerants as a result. 

ALDI US announced in 2024 that all its stores will use natural refrigerants in refrigeration systems by 2035.  While this was the first such commitment for a major U.S. supermarket chain, other large grocery chains have made progress in transitioning to natural and low-GWP refrigerants: 

• Walmart – announced a phaseout of all HFCs by 2040. 

• Trader Joe’s -- announced in 2023 that all its new stores will use CO2 refrigerants. 

• Kroger – announced in 2024 that, starting in 2025, all its new stores will use CO2 refrigerants.  

In addition, many local grocery stores and regional chains have made progress in adopting ultra-low GWP refrigerants: 

• DeCicco & Sons: This small, family-owned New York-based grocer installed its first HFC-free system using CO2 in 2016 and has since expanded the technology to other locations, noting significant energy cost savings 

• Midwest chain Coborn’s installed new sustainable refrigeration systems in two of its locations, which will lower the electricity consumption and CO₂ emissions at the two stores by 3 million kWh and 934 tonnes, respectively. Together, the new refrigeration systems will save roughly 1,160 tonnes of CO₂ emissions 

• Healthy Living Market & Café: This Northeast-based company has incorporated CO2 refrigeration systems in its newer stores to significantly reduce its carbon footprint. CO2 refrigerant systems and other efficiency upgrades are expected to save $86,400 per year in electricity costs.  

• Sprouts Farmers Market:  piloted sustainable technology in its stores, including a Woodstock, GA, location that features a CO2 ejection refrigeration system.  In 2024 the company transitioned 32 stores to refrigeration systems with lower global warming potential (GWP). 

Additional small grocery chains taking action to lower their climate footprint from refrigerants include:  

• Ralph’s Supermercado y Mayorista in Puerto Rico;  

• Raley’s, Stater Bros. Market, and Erewhon in California;  

• PCC Community Markets in Oregon;  

• Kwik Trip and Caputo’s in Minnesota;  

• Weis Markets in Pennsylvania;

• Cingari Family Markets' ShopRite stores in Connecticut ;

• Big Y Foods in Massachusetts 

The Food Industry Association and the National Grocers Association are ignoring this progress and have voiced their support for the EPA’s new rulemaking to reconsider the Technology Transitions Rule, claiming that the current regulations place an undue burden on grocery stores, and in particular smaller stores. 

Furthermore, industry trade groups allege that CO2 (R-744), ammonia, and other low- or ultra-low GWP systems present significant drawbacks.  Per the EPA: “These food retailers asserted that R-744 technologies in their current state expend a significant amount of energy to function at a cooling level comparable to commonly used HFCs.”  Also, these trade groups allege “that such technologies are unreliable, that leaks are difficult to detect and repair, and that such leaks can be catastrophic to the system's performance.” 

However, the examples above demonstrate that large supermarket chains, smaller regional chains, and independent grocers are all successfully making the transition to ultra-low GWP systems, with many of these grocery chains using CO2 systems, and that these energy efficient systems result in cost savings over time, including lower energy bills. The adoption of CO2 and other natural refrigerants also avoid a significant drawback of HFOs (Hydrofluoroolefins) as a replacement for, or addition to, HFCS.  While HFOs have a lower climate footprint than HFCs, HFOs can ultimately create PFAS substances, also known as “forever chemicals,” that can pollute groundwater, and ultimately impact human health. 

Research demonstrates that CO2 systems can use significantly less energy than HFC systems and that these CO2 systems, with their high heat transfer properties, are ideal for systems with long pipe runs, such as grocery stores. 

The ability to transition to natural refrigerants in grocery stores is also made clear by the evidence from Europe where 90,700 food retail stores are using transcritical CO2 systems (as of December 2024), representing a market penetration of 30%, up from 22.9% in 2023.  

There is also growth in North America, where transcritical CO2 installations increased by 40% from 2023 to 2024.  There, a total of 4,100 stores using such systems in 2024, with 2,800 in the US. This growth may now be slowed if the EPA reconsiders the timeline for adoption of non-HFC systems. 

In regard to concerns raised that “that future regulation of per- and polyfluoroalkyl substances (PFAS) could require retailers to change systems again from certain compliant fluorinated refrigerants to others,” the simple solution for retailers is to transition directly to natural refrigerant systems that do not produce PFAS substances. Significantly, the EPA’s proposal to change the January 1, 2027, GWP limit on retail refrigeration equipment to 1400, from its original limit of 150 or 300, would allow for the installation of HFC/HFO blends that have a GWP of up to 1400.  While these blends have a lower climate footprint than HFCs alone, these refrigerants are not a true climate solution as compared to natural refrigerants with ultra-low GWP that are available and being installed nationwide. As noted above, HFOs can lead to the production of PFAS substances that pose a significant public health risk. 

The AIM Act was passed with broad bipartisan support.  It was also passed with strong industry support, including support from the U.S. Chamber of Commerce, the American Chemistry Council, and the Air-Conditioning, Heating, and Refrigeration Institute (AHRI). The AIM Act received such strong support because it is developing climate-friendly HFC alternatives, creating jobs, and ensuring U.S. competitiveness in the global market. The current EPA implementation of the Act is fully in line with this bipartisan mandate. 

The AIM act and EPA implementation of the Act are succeeding as intended, and there is no reason for the EPA to reconsider regulatory requirements at this time.  

Thank you for your consideration of these comments. 

Sincerely,  

Todd Larsen, Executive Co-Director 

Dan Howells, Climate Campaigns Director