After years of advocacy and engagement, FMI welcomed major Trump administration actions to revise the Technology Transitions Rule and reconsider the Leak Management Rule, extending refrigeration compliance timelines and reducing burdensome requirements on food retailers.
By Jennifer Hatcher, Chief Public Policy Officer, FMI, and Stephanie Harris, Chief Regulatory Officer and General Counsel, FMI
After years of sustained advocacy, litigation and engagement across multiple administrations, FMI and its members are seeing meaningful progress through an announcement in the Oval Office of the White House led by President Trump and EPA Administrator Lee Zeldin on two of the most consequential EPA regulations impacting supermarket refrigeration systems: the Technology Transitions Rule and the Leak Management (Refrigerant Management) Rule.
This milestone reflects a deliberate, multi-year strategy involving numerous FMI members visiting Members of Congress, EPA and White House leadership to ensure that environmental objectives are advanced in a manner that is both operationally feasible and economically sustainable for the food industry.
A Multi-Administration Effort to Drive Change
Under the Biden administration, FMI engaged EPA, the White House Office of Management and Budget and the Small Business Administration through meetings and provided comments to the proposed rules. Despite our best efforts, EPA finalized the rules without adequately considering the challenges associated with the timeline under the Technology Transitions Rule. As a result, FMI was forced to initiate a legal challenge to the Rule, raising concerns about implementation timelines and practical feasibility. As the regulatory landscape evolved, and our concerns became realized, FMI worked with the new team in the Trump administration to intervene and pause the litigation and secure reconsideration of key provisions around the unrealistic implementation compliance dates.
In parallel, FMI continued to pursue a legislative solution under the Congressional Review Act and then when time expired for that type of action, we sought administrative solutions to the Leak Management Rule. In November 2025, the organization formally petitioned the EPA for targeted changes to the Leak Management Rule, advocating for:
- Higher coverage thresholds to better align with operational realities and prioritize highest impact rather than lowest impact appliances
- More realistic leak-rate standards and time to repair
- Reduced administrative burdens associated with recordkeeping and reporting
These burdensome requirements apply to existing equipment and impose incredibly costly and unnecessary regulatory requirements for the very systems that are being phased out under the Technology Transitions Rule. One of our members likened the requirement to renovating a house you planned to tear down and rebuild. All of these efforts, including the incredible advocacy from FMI members, set the stage for recent executive and regulatory action at the highest levels of government – featuring the President and EPA Administrator, clearly demonstrating the economic impact of this adjustment.
A Significant Policy Shift
In a White House ceremony, President Trump finalized updates to the Technology Transitions Rule. Shortly thereafter, EPA also announced its intent to reconsider the Leak Management Rule—a pair of actions that collectively represent a significant victory for FMI and the broader food industry.
Technology Transitions Rule: Extended Timeline, Maintained Goals
Under the revised rule, the EPA has extended compliance deadlines for supermarket systems transitioning to low-global warming potential (low-GWP) refrigerants:
- Remote condensing systems: from January 2026 to January 2032
- Supermarket systems: from 2027 to January 2032
This extension is critical. It provides the industry with the time needed to:
- Deploy next-generation refrigeration technologies
- Address supply chain and infrastructure constraints
- Allow for necessary building code updates and regulatory alignment
Importantly, the rule preserves the long-term environmental objective of transitioning to low-GWP systems—while sequencing implementation in a way that supports real-world adoption.
From a legal and economic standpoint, the impact is substantial. FMI estimates that the revised timeline will save the industry and ultimately, customers, hundreds of millions of dollars, while still achieving the intended environmental outcomes.
Leak Management Rule: Relief and Reconsideration
At the same time, the Administration announced a proposed rule to exempt Transport Refrigeration Units (TRUs) from the Leak Management Rule—an important step in reducing regulatory burden in areas where requirements have proven duplicative or impractical.
The EPA also confirmed that it will reconsider the broader Leak Management Rule, many elements of which have already technically taken effect. While this rule was designed to address refrigerant emissions, it has imposed significant compliance challenges due to:
- Expansive equipment coverage
- Stringent and, in some cases, unworkable leak-rate thresholds
- Extensive reporting and recordkeeping requirements
The announced reconsideration offers both near-term relief from enforcement pressures and a meaningful opportunity for stakeholders to shape a more balanced regulatory framework.
FMI’s Continued Advocacy
FMI’s November 2025 petition provides a clear roadmap for reform, emphasizing the need for:
- Threshold adjustments that focus regulatory requirements on the highest-impact systems
- Leak-rate standards grounded in operational feasibility
- Streamlined compliance obligations that reduce unnecessary administrative burden
As the EPA moves forward with reconsideration, FMI will continue to engage constructively with policymakers—advancing solutions that both address environmental priorities and reflect the realities of supermarket operations.
What This Means for the Industry
Taken together, these developments signal a shift toward smarter, more practical regulation—one that recognizes the complexity of large-scale refrigeration systems and the importance of achievable timelines and solutions that work and do not compromise food safety.
For retailers and suppliers, the implications are clear:
- Greater flexibility to plan and invest in compliant systems
- Reduced near-term capital and compliance pressures
- Increased opportunity to influence the next phase of regulatory design
Looking Ahead
FMI has issued a public statement underscoring the significance of these actions and the cost savings they will deliver to the industry and ultimately consumers. Members are encouraged to reinforce support for these policy changes and to engage in the upcoming rulemaking processes.
The progress achieved to date reflects the collective effort of FMI members who have contributed their expertise, advocacy, and persistence over many years. As regulatory reconsideration moves forward, continued industry engagement will be essential to ensuring durable, effective outcomes.
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