Quick answer. The GWP≤150 limit for self-contained (stand-alone) retail refrigeration — reach-in coolers, glass-door merchandisers, and display cases — took effect January 1, 2025, and EPA’s May 2026 revision did not touch it. That revision only pushed back deadlines for remote condensing units, supermarket rack systems, and cold storage warehouses, giving those categories an interim 1,400 GWP ceiling until January 1, 2032.
Importers of self-contained equipment still need a compliant on-unit refrigerant label under 40 CFR 84.58. They do not need EPA HFC consumption allowances or an ACE “EH2” bulk-import filing — that applies only to bulk refrigerant cylinders, not finished appliances.
Most compliance summaries lump two separate EPA programs together: the HFC phasedown (allowances for bulk gas importers) and the Technology Transitions GWP limits (design restrictions on finished equipment). A container of self-contained display cases charged with R-290 at the factory only touches the second program.
What the May 2026 Revision Actually Changed
On May 21, 2026, EPA signed a final rule revising the December 2023 Technology Transitions Rule, published in the Federal Register on May 26, 2026. The revision does not mention self-contained equipment.
Remote condensing units had been scheduled to hit GWP≤150/300 on January 1, 2026. Under the revision they get an interim GWP≤1,400 ceiling instead, effective July 25, 2026 — 60 days after Federal Register publication. The 150/300 limit now lands January 1, 2032.
Supermarket rack systems get the same 1,400 interim cap; their original January 1, 2027 deadline for 150/300 also moves to 2032. Cold storage warehouse systems, which faced a strict limit in 2026, get an interim 700 GWP ceiling until 2032.
Trade coverage of this rule mostly ran under headlines like “EPA delays HFC refrigerant rule,” without specifying which equipment the delay covers. Table 1 lines up the categories side by side.
If you import self-contained display cases, freezers, or beverage coolers, none of the three right-hand columns after row one apply to your shipment — a distinction worth having ready when a buyer assumes the relief is industry-wide.
| Equipment category | Original GWP≤150/300 deadline | Interim GWP ceiling after May 2026 rule | Revised GWP≤150/300 deadline |
|---|---|---|---|
| Self-contained / stand-alone retail food refrigeration (display cases, reach-ins, beverage coolers) | January 1, 2025 | None — not part of the revision | Already in force since January 1, 2025 |
| Remote condensing units | January 1, 2026 | GWP≤1,400, effective July 25, 2026 | January 1, 2032 |
| Supermarket rack systems | January 1, 2027 | GWP≤1,400, effective July 25, 2026 | January 1, 2032 |
| Cold storage warehouse systems | 2026 | GWP≤700, effective July 25, 2026 | January 1, 2032 |
GWP≤150: The Rule for Self-Contained Units That Never Moved
Self-contained equipment carries its full refrigerant circuit inside one factory-sealed cabinet — no field-run piping, no remote compressor rack. EPA’s December 2023 rule set GWP≤150 for new medium-temperature stand-alone units and GWP≤300 for low-temperature stand-alone units, both effective January 1, 2025.
That threshold has not moved since, and the May 2026 revision explicitly left it alone.
Practically, GWP≤150 rules out R-404A (GWP 3,922) and R-134a (GWP 1,430) for any new self-contained cooler or display case entering U.S. commerce. It also rules out most HFC blends built for markets without an equivalent phasedown, including several charge specs common in Gulf and Southeast Asian equipment.
A factory quote listing R-404A as the charge gas is offering equipment that cannot legally enter new U.S. commerce — not a gray area to negotiate around.
Choosing a Refrigerant Under the 150 GWP Ceiling
Three refrigerants realistically clear GWP≤150 in a self-contained cabinet: R-290 (propane), R-600a (isobutane), and R-744 (CO2). Table 2 compares them on the dimensions that change a purchase order: safety class, charge limit, and the design element that drives cost.
| Refrigerant | ASHRAE safety class | GWP (AR4) | Max charge, closed self-contained case (UL 60335-2-89 Ed. 2) | Primary cost/design driver |
|---|---|---|---|---|
| R-290 (propane) | A3 – flammable | 3 | 300 g per circuit (raised from 150 g under the first edition) | Ignition-source separation; brazed joints only, no flared fittings |
| R-600a (isobutane) | A3 – flammable | 3 | Set by 8× LFL — lower in grams than R-290’s limit, since isobutane’s flammability limit is lower | Same A3 electrical/ignition rules as R-290 |
| R-744 (CO2) | A1 – non-flammable | 1 | Not flammability-limited; limited by pressure design instead | Transcritical loops run up to roughly 120 bar vs. under 20 bar for HFCs — needs CO2-rated compressors and fittings |
| R-404A / R-134a (legacy HFC) | A1 – non-flammable | 3,922 / 1,430 | No flammability limit | Non-compliant for new U.S. self-contained units since January 1, 2025 |
R-290 is the default choice for most self-contained display cases: it clears GWP≤150 by two orders of magnitude, keeps the 300 g charge limit workable for medium-size cabinets, and avoids the pressure-rated components CO2 requires.
The trade-off is the A3 flammability class. UL 60335-2-89 requires ignition-source separation inside the cabinet and brazed refrigerant joints — a manufacturing discipline question, not a paperwork one.
Warehouse staff handling A3 equipment domestically should also be current on OSHA Hazard Communication labeling for compressed flammable gas, since propane-charged units carry the same GHS pictogram set as a propane cylinder.
Customs Documentation: What You Actually Need at the Port
The label EPA requires
Every unit needs a permanent label under 40 CFR 84.58: the refrigerant’s ASHRAE designation (for example, “R-290”), either its numeric GWP or the statement “GWP<150,” and at minimum the four-digit year of manufacture.
The label must survive open-weather exposure and sit on a contrasting background — a silkscreen on the compressor shroud, not a printed sticker that fades in a container.
What EPA does not require for finished equipment
Bulk HFC importers must file through CBP’s Automated Commercial Environment before the shipment arrives — 10 days ahead for marine cargo, 5 days for other modes — and expend consumption allowances against specific HTS codes.
None of that applies to HFCs “contained in a manufactured product such as an appliance,” which is EPA’s own line between bulk and finished-product imports.
A container of factory-charged display cases does not need an ACE HFC filing or an allowance draw; treating it as if it does adds a broker fee and a delay for a filing EPA never asked for.
Safety files a buyer will ask for
For A3 refrigerant equipment, expect purchasing teams to ask for the UL 60335-2-89 (or UL 471, still referenced on older listings) test report and file number, plus the SDS and dangerous-goods declaration the flammable charge requires for ocean freight.
Grocery and foodservice buyers frequently add NSF/ANSI 7 as a separate sanitation and temperature-performance certification — not an EPA requirement, but the standard most U.S. retail buyers check before signing a PO.
What to Ask a Manufacturer Before You Place the Order
Three questions catch most compliance gaps before a container is booked. First, what refrigerant and charge weight is on the nameplate — get the number in grams, not “R-290 compliant.”
Second, does the 40 CFR 84.58 label ship pre-applied at the factory, or is it added at a U.S. warehouse after arrival — pre-applied removes a step where units sit uncleared.
Third, which edition of UL 60335-2-89 the design was tested to, since a first-edition 150 g charge limit and a second-edition 300 g limit are not interchangeable on the same cabinet.
A manufacturer building to order can answer all three before tooling starts, because refrigerant circuit, charge weight, and label placement are decided at the design stage rather than retrofitted onto a catalog SKU.
Our self-contained display case and reach-in cooler specifications list refrigerant class and charge weight per model for this reason — an importer should check GWP compliance against the nameplate before the RFQ goes out, not after the container is on the water.
FAQ
Q: Does the May 2026 EPA rule lower or raise the GWP limit for self-contained display cases?
Neither — it does not apply to self-contained equipment. The GWP≤150/300 limit for stand-alone units has been in force since January 1, 2025 and stays in force.
Q: Do I need EPA consumption allowances to import a container of pre-charged coolers?
No. Allowances apply to bulk HFC refrigerant, not to HFCs contained in a finished appliance. Clearance needs standard entry documents plus the on-unit 40 CFR 84.58 label — no ACE HFC filing, no allowance draw.
Q: How much R-290 can a self-contained display case legally carry?
Up to 300 grams per refrigerant circuit in a closed case with doors, under the second edition of UL 60335-2-89. The first edition capped this at 150 grams, so confirm which edition the unit was tested to.
Q: Is R-404A or R-134a still legal in new self-contained equipment sold in the U.S.?
No. Both exceed GWP 150 by a wide margin (3,922 and 1,430 respectively) and cannot go into new self-contained equipment manufactured or imported for U.S. commerce since January 1, 2025.
Q: What certification should I request beyond the EPA label?
A UL 60335-2-89 (or UL 471) listing with file number for electrical and flammable-refrigerant safety, and, if selling into grocery or foodservice, NSF/ANSI 7 for sanitation and temperature performance. Neither is an EPA requirement, but both are standard PO conditions from U.S. retail buyers.