Holiday Retail Readiness:  Charting Your Course for 2026 Refrigerant Changes

The holiday season puts every store to the test. HVAC works overtime to keep shoppers comfortable, lights stay on longer as stores stay open longer, and restrooms see more use with more shoppers in the building. When something goes wrong during this busy time, it can mean frustrated customers, lost sales, and a hit to the brand’s reputation. 

But this year, it’s important for facilities leaders to also think past December’s operational needs and be ready for upcoming compliance changes. New refrigerant regulations take effect in January 2026, which means you need to focus on holiday uptime while also preparing for these changes.  

What’s changing with refrigerant rules 

Under the American Innovation and Manufacturing (AIM) Act and new EPA requirements, retailers operating large refrigeration or HVAC systems should expect stricter HFC leak-management requirements starting January 1, 2026. Here are the key changes retail facilities leaders should make note of: 

• Lower thresholds: If a system holds 15 pounds or more of an HFC refrigerant (the high-GWP kind), you must follow EPA leak-repair and recordkeeping rules. The lower threshold means that “standard” commercial cooling equipment is now in scope, not just the biggest supermarket racks or cold storage units. So, anyone who operates a 5-ton HVAC unit, which typically holds between 10 and 20 pounds of refrigerant, should pay close attention as they could be impacted by these new rules.   

• Leak checks and automatic monitors: If a single system holds 1,500 pounds or more, you must install automatic leak detection. Smaller covered systems don’t need sensors, but they must be checked more often, fixed faster, and documented. 

• New equipment rules (what you can buy next): For new comfort-cooling equipment, EPA caps the refrigerant at ≤700 GWP. That effectively rules out R-410A in new units. Most new assets will use A2L refrigerants like R-32 or R-454B, which will require updated safety steps and technician training. 

• Service costs (what to budget for): As HFCs are phased down, older refrigerants will get pricier and harder to find. Expect higher service costs unless you prevent leaks and plan your transition. 

• Extended deadlines in some cases: Some variable refrigerant flow (VRF) or custom-built systems can still be installed in 2027 or 2028 if they were already permitted or use parts made before EPA cutoff dates, so retailers will need to check permit date and the parts’ manufacture dates. 

For years, refrigerant rules mostly mattered to grocery stores, convenience stores, and cold-storage warehouses, businesses with big refrigeration racks and walk-in freezers. But starting in 2026, the circle gets wider. 

Now, any retailer with larger cooling or refrigeration systems could fall under the new EPA rules. That includes: 

• Clothing chains and department stores that use big chillers or centralized HVAC plants to cool large spaces. 

• Home improvement, electronics, and warehouse-style stores that rely on large rooftop or packaged systems. 

• Pharmacies and health-and-beauty retailers with temperature-controlled storage or display cases. 

In short, any retail operation running large, high-GWP systems now has to pay attention. 

Why holiday timing matters 

The holiday rush isn’t the time to be scrambling over refrigerant leaks or compliance paperwork. By auditing your assets ASAP, you can: 

• Identify which stores are using refrigerants subject to the new rules 

• Log refrigerant types, volumes, and leak rates so you’re not caught off guard in January 

• Confirm you have tracking systems in place to monitor usage and meet documentation requirements 

This proactive work also mitigates emergency servicing during the holidays, which helps you avoid costly downtime during one of the busiest times of year. 

Refrigerant tracking as your ESG entry point 

Compliance doesn’t have to be just a cost. In fact, as we explored in “The Sustainable Edge: Turning Compliance into a Competitive Advantage,” regulatory requirements can actually become strategic financial drivers. Refrigerant tracking gives you the data foundation you need to: 

• Extend asset lifecycles with preventative maintenance 

• Reduce OPEX by avoiding refrigerant loss and emergency repairs 

• Build the infrastructure for broader ESG and sustainability reporting 

Sustainable asset management has also been shown to boost both operational efficiency and customer loyalty. Research shows that 55% of Americans would stop using a brand that doesn’t commit to sustainability — a critical insight for retailers whose holiday success depends on loyalty and repeat visits. 

What refrigerant compliance means for retailers 

Here’s how the 2026 refrigerant rules could impact your stores: 

1. HVAC upgrades 

• New locations or replacements can’t use banned refrigerants like R-410A 

• You’ll need to plan for A2L systems and train — or have access to trained — technicians 

2. Higher maintenance standards 

• Even existing systems will require more frequent leak detection, faster repairs, and more detailed documentation 

3. Rising service costs 

• As legacy refrigerants are phased down, expect prices to rise and supply to tighten, making proactive planning essential 

4. Capital planning requirements 

• Remodels that involve major HVAC replacements will qualify as “new systems” and must comply immediately 

5. Brand and sustainability impact 

• Retailers who stay ahead will not only meet compliance requirements but also differentiate themselves as eco-conscious brands. Highlighting sustainability progress in reports or in-store messaging can strengthen customer trust during a season when loyalty is on the line 

Build a solid foundation for 2026 and beyond 

The next few months may be challenging, but they also present opportunities for retail facilities leaders to: 

• Confirm refrigerant tracking is in place 

• Get ahead of leak detection and reporting requirements 

• Incorporate refrigerant compliance into broader ESG and sustainability strategies 

This isn’t just about staying compliant. It’s also about protecting holiday uptime, reducing OPEX, and positioning your brand to thrive under new sustainability standards.