Cooling Down HFCs: How New Refrigerant Regulations Are Reshaping the U.S. Ice Machine Industry

Commercial ice machines are undergoing a quiet transformation — not in form or function, but in what flows inside them. As environmental regulations take sharper aim at high-global-warming-potential (GWP) refrigerants, the ice machine industry finds itself caught in a regulatory phase change.

The American Innovation and Manufacturing (AIM) Act — signed into law in 2020 and taking effect over the past few years — mandates a phasedown in the production and consumption of hydrofluorocarbons (HFCs), a class of potent greenhouse gases used in refrigeration systems, including ice machines.

As of April 2025, the U.S. has completed its first mandated step: cutting HFC use to 90% of baseline levels. More aggressive cuts are coming — and they will have long-term implications on system design, safety protocols, sourcing decisions, and innovation cycles for commercial foodservice equipment manufacturers.

This article explores what these regulations mean specifically for the commercial ice machine sector, why the transition isn’t as simple as replacing one fluid with another, and how startups like Rockhopper Ice Collective are positioning themselves to innovate under a changing refrigerant landscape.

A Brief History of Refrigerants in Ice Machines

First, what is a Refrigerant?

A refrigerant is a specialized fluid used in cooling systems to absorb and release heat as it cycles between gas and liquid states. In an ice machine, the refrigerant pulls heat out of water in the evaporator until it freezes into ice. Without refrigerants, there’s no heat exchange — and no ice. The chemical properties of the refrigerant determine how efficiently the machine operates, how safe it is, and how much environmental impact it creates.

From CFCs to HFCs — and Now to Low-GWP Alternatives

Refrigerants have evolved dramatically over the past decades:

• CFC Era: Early commercial ice machines used chlorofluorocarbons (CFCs) such as R-12 and R-502. These compounds were valued for their non-toxic and non-flammable nature; however, they were later banned globally under the 1987 Montreal Protocol for destroying the ozone layer.

• HCFC Transition: The industry shifted to hydrochlorofluorocarbons (HCFCs) like R-22 in the 1990s. Although HCFCs posed less of an ozone problem, they were only an interim solution.

• The HFC Age: By the 2000s, HFCs (e.g., R-134a, R-404A, and R-410A) became prevalent because they spared the ozone layer. Yet, many HFCs are extremely potent greenhouse gases. For example, R-404A can have a GWP of about 3,900 — meaning a small leak can equal the warming effect of several tons of CO₂.

• The Low-GWP Push: As climate concerns mounted, attention turned to refrigerants with very low GWPs — often under 150 — to reduce greenhouse gas impact. These include hydrofluoroolefins (HFOs), natural refrigerants like propane (R-290) and carbon dioxide (R-744), and a variety of blends.

Understanding the AIM Act and Its Implications

Key Provisions of the AIM Act

The AIM Act mandates a steep phasedown of HFCs over the next decade:

• Phase-Down Schedule: Based on a 2011–2013 baseline, the law required a reduction to 90% of that baseline by 2024 (10% reduction), 60% by 2029, 30% by 2034, and finally, down to 15% (an 85% reduction) by 2036.

• Product-Specific Rules: The EPA has also implemented product-specific restrictions through its Technology Transitions rule. Notably:

  • Small Ice Machines: Units up to approximately 1,000 lbs/day (or up to 1,200 lbs/day for continuous systems making flake or nugget ice) must use refrigerants with a GWP below 150 from January 2026 onward.

  • Large Ice Machines: For these systems, EPA’s rule effectively prohibits many legacy HFC refrigerants altogether starting January 2027.

Why Different Limits for Small vs. Large Machines?

The divergence in refrigerant regulations between small and large machines largely comes down to safety risk and refrigerant charge size — particularly when flammable refrigerants like R-290 (propane) are used.

• Small Units: These machines typically have charge sizes below 150 grams (5.3 oz) of refrigerant per sealed refrigeration circuit, which was historically the maximum allowed under UL standards for flammable refrigerants (A3). As of 2024, updated UL/IEC standards and EPA SNAP Rule 26 now allow up to 500 grams (~17.6 oz) of R-290 per sealed circuit in certain commercial refrigeration applications, including ice machines. These relaxed limits make it feasible for OEMs to design small- to medium-capacity machines using propane, provided they segment the system into separate sealed loops.

• Large Units: These machines often require more than 500 grams of refrigerant, and depending on the design, a single loop might exceed that threshold. Higher charges of flammable refrigerants increase the risk of explosion or fire in the event of a leak, especially in confined spaces. This leads to complex safety engineering (e.g., gas detection, ventilation, ignition control), which is not always practical or cost-effective. As a result, EPA regulations opt for a ban on specific high-GWP refrigerants rather than relying solely on a GWP threshold. This provides a simpler, enforceable pathway to force innovation while protecting public safety.

What are the Proposed Alternatives?

Each refrigerant alternative for ice machines has unique properties:

• R-290 (Propane)

  • GWP: ~3

  • Flammability: A3 (High)

  • Type: Natural refrigerant

  • Glide: Minimal

  • Notes: Excellent energy efficiency, very low GWP. Widely used in smaller machines. Flammable, so charge limits apply and safety standards must be met.

• R-744 (Carbon Dioxide / CO₂)

  • GWP: 1

  • Flammability: A1 (None)

  • Type: Natural refrigerant

  • Glide: None

  • Notes: Very high operating pressure. Excellent heat transfer properties. Works well in larger, more complex systems. Non-flammable and ozone-safe.

• HFO-1234yf

  • GWP: <1

  • Flammability: A2L (Mild)

  • Type: Synthetic (HFO)

  • Glide: Minimal

  • Notes: Common in automotive air conditioning. Promising for stationary systems, but less proven in commercial ice makers.

• HFO Blends (e.g., R-513A, R-449A)

  • GWP: Varies (100–700)

  • Flammability: A1 or A2L

  • Type: Synthetic (HFO + HFC blends)

  • Glide: Moderate to high

  • Notes: Easier retrofit option for some HFC systems. But high glide can complicate evaporator performance, and some blends may not meet long-term regulatory limits.

A Primer on Refrigerant Classifications

Before diving further, it’s important to understand the labeling system:

• Modern Chemical Families:

  • HFCs: Synthetic, non-ozone depleting, but high GWP.

  • HFOs/Blends: Newer synthetics with low GWP; often blended with small amounts of HFCs.

  • Natural Refrigerants: Include propane (R-290), carbon dioxide (R-744), and water (R-718).

• Safety Classifications:

  • A1: Non-flammable refrigerants (e.g., many HFCs).

  • A2L: Refrigerants with mild flammability (often used for some HFOs and blends).

  • A3: Highly flammable refrigerants (for example, propane — R-290).

• R-numbers: Designations like R-290 for propane, R-744 for carbon dioxide, and R-718 for water are part of an industry-wide naming system. These numbers indicate the composition and properties of the refrigerant.

Below is a simple visual that places these classifications into context:

Note: HFCs generally fall into the A1 category. HFOs are designed for low GWP but are often classified as A2L, while natural refrigerants like propane are A3 and require strict safety controls.

Why the Transition isn’t “Plug and Play”

Switching refrigerants isn’t as simple as changing one fluid for another. Two key components underscore this complexity:

Compressor Considerations

• Oil Compatibility: Refrigerants require oils for lubrication in compressors. A change in refrigerant can demand a new oil type, and the wrong oil can reduce efficiency or damage components.

• Pressure and Temperature Differences: Compressors designed for one refrigerant may not tolerate the operating pressures or temperature characteristics of another.

The Evaporator Challenge

• Evaporator Function: In an ice machine, the evaporator is critical — it extracts heat, facilitates ice formation, and directly affects ice quality.

• Design Specifics: The heat exchange surface, tubing dimensions, and fin spacing are all optimized for a particular refrigerant’s thermodynamic properties. Changing refrigerants means these parameters might no longer be ideal.

• Impact on Ice Quality: A refrigerant with a different temperature glide or evaporation profile may lead to inconsistencies in ice crystal formation — resulting in altered ice texture or production rates.

• OEM Reluctance: Many OEMs design and manufacture their own proprietary evaporators. These components are the result of years of optimization. Altering an evaporator’s design is a significant undertaking — it can require redesigning core aspects of the machine, re-certification (UL, NSF, etc.), and even retooling production lines. In short, the evaporator is both a technical and economic pain point, discouraging changes unless absolutely necessary.

What about Glide?

Temperature glide refers to how much a refrigerant’s evaporation/condensation temperature changes during phase change.

• Single-component refrigerants like R-290 have virtually no glide — they boil and condense at a single temperature.

• Blends often exhibit significant glide (e.g., 5–10°F), which can complicate control and lead to inconsistent ice formation if the evaporator isn’t designed to handle it.

Why it matters: Ice machines rely on tight temperature control. High-glide blends may reduce efficiency, cause incomplete freeze cycles, or alter ice shape/clarity.

Current Policy Landscape in 2025: Trump Administration’s Approach

With President Trump back in the White House, the regulatory environment in 2025 continues to follow the AIM Act’s framework. It’s worth noting that the AIM Act was originally signed into law by President Trump in 2020, with broad bipartisan support, as part of a larger appropriations and COVID relief package. The law gave EPA authority to phase down HFCs in alignment with global climate goals — a move that drew backing from both environmental groups and major industry associations.

Despite early expectations of widespread deregulation in 2025, the Trump administration has so far refrained from overturning the phasedown objectives established by the law. Key points include:

• Enforcement and Flexibility: While the administration has signaled potential delays in future schedule milestones (for example, slight extensions in compliance deadlines for new equipment), there has been no concrete rollback of the reductions already in place.

• Industry Signals: Stakeholders have noted that enforcement details (such as documentation and reporting requirements) may be loosened slightly, but the core objectives — such as the 10% reduction by 2024 and subsequent targets — remain intact. The consensus is that major HFC reduction is inevitable, and the administration appears to be taking a “managed transition” approach rather than a full-scale reversal.

• Looking Ahead: This “wait-and-see” stance means OEMs and innovators should plan for the continued implementation of low-GWP refrigerant rules, even if some enforcement flexibilities appear in the short term.

Future-Proofing

Building next-generation ice machines that comply with current and future refrigerant regulations is not just about regulatory compliance — it’s a competitive edge, and soon to be table stakes.

Designing with Future Regulations in Mind

• Choose a Low-GWP Refrigerant from the Start: New machines should avoid legacy HFCs. Whether you opt for R-290, R-744, or an advanced HFO blend, the system must be designed from the ground up for that fluid.

• Embrace Modularity: Instead of a single large refrigeration loop, consider designing multiple smaller, sealed circuits. For example, a modular system could involve separate evaporator loops within the same machine. This not only keeps individual refrigerant charge limits within safe boundaries but also allows easier servicing and potential future refrigerant swaps. Essentially, each module is a self-contained “mini system” that can be optimized independently.

• Watch Energy Efficiency and Stay Informed: It’s essential to closely monitor updates from the EPA and the Technology Transitions Program. One practical recommendation is to join the Technology Transitions Program contact list. By signing up (via EPA’s website), you can receive timely updates about new regulations, upcoming webinars, and policy shifts.

• Anticipate the Evaporator Challenge: Recognize that the evaporator is one of your machine’s most critical — and hard-to-change — components. If your machine’s evaporator is optimized for one refrigerant, switching later will require a significant redesign. This is why OEMs are often cautious about altering evaporator designs; they are the core of the ice machine’s performance and reliability.

Conclusion

The U.S. commercial ice machine sector is at a crossroads. With the phasedown of high-GWP HFCs well underway, manufacturers must adapt quickly to meet stringent new rules — while maintaining performance, safety, and product quality. Understanding how refrigerant choices affect everything from compressor operation to evaporator design is crucial. Even under a managed regulatory approach by the current Trump administration, the trend toward eco-friendly cooling is unstoppable.

Sources:

• [1] EPA AIM Act Overview

• [2] Industry Association Publications

• [3] OEM Press Releases (Hoshizaki, Manitowoc, Scotsman)

• [4] Technical Briefs on Refrigerant Glide and Safety Ratings

• [5] EPA Technology Transitions Program Documentation