Rules and Refrigerants

EPA's 700-GWP limit for new data center cooling equipment arrives Jan. 1, 2027

EPA's May rule moved deadlines for supermarkets, cold storage and home air conditioning. The data center date stayed put.

By The Gradient Report Staff

Key points

  • New data center cooling equipment must use refrigerants with a GWP under 700 starting Jan. 1, 2027, according to EPA's sector table.
  • EPA's May 2026 rule pushed back several other sectors' deadlines but left data centers alone.
  • Five lawsuits challenge the May rule in the D.C. Circuit. No ruling had appeared as of Nov. 3.
  • Washington applies a stricter 150-GWP limit to data center equipment holding more than 50 pounds of refrigerant, and won't enforce it before Jan. 1, 2027.

Starting Jan. 1, 2027, new data center cooling equipment in the United States will have to use refrigerants with a global warming potential (GWP) under 700, according to EPA's table of restrictions by sector, last updated Aug. 28.

The table lists a GWP limit of 700 for "data centers, computer room air conditioners and IT equipment cooling," covering both products manufactured or imported and systems installed on or after Jan. 1, 2027. EPA says the table is informational and that the binding requirements are in 40 CFR Part 84, Subpart B.

The limit is part of EPA's Technology Transitions program under the American Innovation and Manufacturing (AIM) Act. EPA's regulatory actions page describes its October 2023 Technology Transitions rule as restricting HFC use "in specific sectors or subsectors," with "compliance deadlines and GWP limits" that "vary based on sector and subsector."

Demand for the equipment is rising. Carrier said in its third-quarter results on Oct. 29 that its data center orders rose about 300% from a year earlier.

Compliance deadlines by sector

Compliance dates (Jan. 1) from EPA’s sector table and the May 2026 rule. The data center row is highlighted.

DateSectorLimit or change
2025Comfort cooling chillers700 GWP
2026Industrial process chillers, exiting fluid at or above −30 °C700 GWP
2027Data centers, computer room AC, IT equipment cooling700 GWP
2027Variable refrigerant flow systems, installed700 GWP
2028Laboratory centrifuges and shakersMoved from 2026
2030Certain industrial process refrigeration, semiconductor chillersMoved by May rule
2032Cold storage warehouses700 GWP interim until then
2032Supermarket systems, remote condensing units150 or 300 GWP, 1,400 interim

Sources: U.S. EPA, Technology Transitions HFC Restrictions by Sector, updated Aug. 28, 2026; Holland & Knight, May 26, 2026. Some sectors have other dates and limits not shown. Table: The Gradient Report.

May rule moved other deadlines

In May, EPA finalized a reconsideration of the Technology Transitions rule that pushed back several deadlines. The rule was published in the Federal Register on May 26 (91 FR 31284) and took effect July 27.

The law firm Holland & Knight's summary lists these changes:

  • The installation deadline is gone for new residential and light commercial air conditioning and heat pump systems that use refrigerants with a GWP of 700 or more, as long as their components were manufactured or imported before Jan. 1, 2025.
  • Supermarket systems and remote condensing units now have until Jan. 1, 2032 to meet their 150 or 300 GWP limits, with an interim limit of 1,400 GWP until then.
  • Cold storage warehouses also moved to Jan. 1, 2032, with an interim limit of 700 GWP.
  • Certain industrial process refrigeration equipment and chillers used in semiconductor manufacturing got until Jan. 1, 2030.
  • The deadline for laboratory centrifuges and shakers moved from Jan. 1, 2026 to Jan. 1, 2028.

Data center cooling is not on Holland & Knight's list, and the published rule text does not mention data centers, computer rooms or IT equipment. EPA's sector table, updated a month after the rule took effect, still shows Jan. 1, 2027.

The reconsideration rule is being challenged in court. The Natural Resources Defense Council filed a petition for review on July 20 in the U.S. Court of Appeals for the D.C. Circuit, Case No. 26-1188. EPA's litigation page, updated Aug. 13, lists five petitions against the rule: from NRDC, from industry groups including HARDI and AHRI, and from a group of states led by Massachusetts.

The court has consolidated the five cases, according to an Aug. 18 motion to expedite filed by AHRI and other petitioners. The motion proposed final briefs by Nov. 24 and oral argument at the court's December sitting, and said, "AHRI Petitioners do not seek a stay of the Rule." It said NRDC and the petitioners in No. 26-1193 opposed the proposed schedule, and that EPA opposed the motion. No order on the motion, and no ruling on the merits, appeared in the public records The Gradient Report checked on Nov. 3.

Other dates on the same table

EPA's sector table also lists these limits:

  • Comfort cooling chillers: 700 GWP, in effect since Jan. 1, 2025.
  • Industrial process chillers with exiting fluid at or above -30 degrees C: 700 GWP since Jan. 1, 2026.
  • Variable refrigerant flow (VRF) systems: 700 GWP for systems installed from Jan. 1, 2027. EPA allows installation until Jan. 1, 2028 in buildings with a permit issued before Oct. 5, 2023, if the components were manufactured or imported before Jan. 1, 2026.
Computer room air conditioners and other data center cooling equipment fall under EPA's 700-GWP limit from Jan. 1, 2027.
Computer room air conditioners and other data center cooling equipment fall under EPA's 700-GWP limit from Jan. 1, 2027.AI-generated illustration

Washington sets a lower limit

In a February 2025 interpretive statement, the Washington Department of Ecology said it treats data center cooling as "industrial process refrigeration" under state rules. Those rules prohibit refrigerants with a GWP above 150 in new equipment with a full charge of more than 50 pounds, and Ecology said it would not enforce that prohibition for data center equipment until Jan. 1, 2027. The statement is advisory, not a regulation.

In May, Ecology opened a rulemaking on its HFC rules that it says "will also evaluate requirements for specific facility categories, including data centers." Its rulemaking page expects a proposed rule in winter 2028 and adoption in summer 2028.

Sources

Continue Reading