Author: Michael Rosenberg

The One Big Beautiful Bill Act made 100% bonus depreciation permanent for qualified property acquired and placed in service after January 19, 2025. There is no phase-down to race against anymore, which removes the old urgency of buying before the rate drops. What has not changed is the annual cutoff. A deduction is claimed in the tax year the asset is placed in service, so a compressor package that is ready to run on December 30 and one that is ready on January 4 land in different tax years.

Why Q4 Timing Matters More in 2026

For a plant that has the cash and the need this year, that difference can matter. Pulling a large deduction into 2026 reduces this year’s taxable income; missing the cutoff pushes the same deduction a full year out. The IRS issued interim guidance on the permanent 100% rate in Notice 2026-11 on January 14, 2026, and it keeps the existing regulatory framework while updating the key dates to January 19 and January 20, 2025.

Used Equipment Qualifies, With Three Conditions

Bonus depreciation has covered used property since the 2017 tax law changes, and the 2025 law kept that treatment. Used equipment generally qualifies when three things are true:

• Your business, or a predecessor, never had a depreciable interest in the asset before this purchase.
• You did not acquire it from a related party, such as a commonly controlled company or certain family members.
• You did not acquire it in a carryover-basis or other nontaxable transaction, such as a gift or a like-kind exchange.

A compressor, condenser, evaporator, vessel, or chiller bought from an unrelated dealer such as Refrigeration Equipment Pros typically fits that pattern. The binding contract date also matters: property is treated as acquired when a written binding contract is in place, and contracts signed on or before January 19, 2025 fall under the older rules.

What Placed in Service Actually Means

This is where most year-end plans fail. Treasury regulations treat property as placed in service when it is in a condition or state of readiness and availability for a specifically assigned function. It does not have to be running, but it has to be ready to run for the job you bought it for.

The Tax Court has applied that test strictly. In one well-known case summarized by the Journal of Accountancy, an aircraft delivered and titled to the buyer in late December was held not placed in service that year because modifications the owner considered necessary for its intended use were not finished. The court looked at whether the asset was available for its specifically assigned function, not whether the buyer owned it.

Translated to refrigeration, a reasonable reading for most buyers is that the following are different things:

• Signed purchase order: establishes the acquisition date, not the placed-in-service date.
• Delivered to your dock: the asset is yours, but a crated screw package sitting in a warehouse is usually not ready for its assigned function.
• Set, piped, wired, and ready to start: this is much closer to the standard for an asset whose function requires installation.

Your tax advisor should decide where your specific asset falls, especially for equipment that becomes part of a larger system. Document the date each asset reached a ready state: startup reports, contractor sign-offs, and photos help.

Bonus Depreciation and Section 179 in 2026

Section 179 is the other immediate-expensing route. For tax years beginning in 2026, Revenue Procedure 2025-32 sets the maximum Section 179 deduction at $2,560,000, reduced dollar for dollar once total qualifying property placed in service exceeds $4,090,000, and fully phased out at $6,650,000. Section 179 is also limited to taxable business income.

Bonus depreciation has no dollar cap and no business income limit, so it can create a loss. Many plants use the two together, and the right mix depends on income, state conformity, and plans for future years. That is a conversation for your CPA, not your equipment dealer.

Working Backward From December 31

If the goal is a 2026 deduction, plan the purchase from the placed-in-service date backward. On a used package, the long poles are rarely the equipment itself; they are everything around it.

• Electrical: starters, drives, and switchgear can take far longer than the compressor. Our piece on why switchgear, not the compressor, now sets the schedule covers the reported lead times and what to buy with the package.
• Contractor availability: refrigeration and electrical crews book up in December. Get installation dates in writing before you commit.
• Refrigerant and compliance: confirm charge handling and refrigerant rules before the unit moves. See what the 2026 Technology Transitions rule means for used buyers.
• Freight and rigging: allow for crating, transport, and crane time, and for weather delays in northern sites.
• Startup: build in time for leak testing, evacuation or pump-down, and commissioning by your contractor.

A practical rule: if the equipment is not on site by early December with installation crews scheduled, assume it is a 2027 deduction and plan cash accordingly. Equipment that is already in stock can be inspected and shipped far faster than a new build, which is the main reason used buyers have a realistic shot at a December 31 deadline at all.

Where Used Equipment Fits a Year-End Plan

The strongest year-end candidates are replacements and like-for-like additions: a second compressor on an existing rack, a matching evaporator for a room expansion, or a condenser swap where the piping and power are already in place. These install fastest and carry the least schedule risk. Larger projects such as a cold storage retrofit instead of a new build or a refrigerant conversion usually span the year boundary and are better planned around the following year.

If you are on the other side of the transaction, year end is also a good time to clear idle equipment. Surplus created by CO2 and low-charge ammonia conversions is moving to buyers now. Browse current inventory in the shop, submit equipment you want to sell, or call or text 201-805-1441 to talk through a specific unit.

About the Author

Michael Rosenberg writes for Refrigeration Equipment Pros, a supplier of surplus and used refrigeration equipment for ammonia and freon systems that has served contractors and plants for more than 25 years. The company buys and sells compressors, condensers, evaporators, vessels, chillers, and complete refrigeration plants, and provides logistics, export crating, removal, evaluation, and storage from warehouses in Newfield, New Jersey; Houston, Texas; and Patterson, California.

Sources

1. BDO, IRS Issues Interim Guidance on Bonus Depreciation Rules (Notice 2026-11)
2. BPM, IRS Notice 2026-11: Interim Guidance on Permanent 100% Bonus Depreciation
3. National Tax Tools, Section 179 Deduction (Rev. Proc. 2025-32 limits)
4. Journal of Accountancy, Bonus Depreciation for Used Property
5. Journal of Accountancy, Placed-in-Service Date (Tax Court aircraft case)
6. The Tax Adviser, Bonus Depreciation Denied for Asset Used but Not Considered Placed in Service

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

Buyers price used vessels on steel, volume, and MAWP. The expensive variable is paperwork, and it is settled at the destination. The same is true of the freezing equipment those vessels often come with.

The National Board’s NB-57 puts it plainly: vessels manufactured for use in the US or Canada must comply with the jurisdictional laws of their installation location. Jurisdictions are not only states. The National Board’s synopsis covers cities and counties as distinct jurisdictions, including Chicago, Buffalo, and Miami-Dade County.

Three states, three problems

Ohio Administrative Code Rule 4101:4-9-01, effective July 1, 2024, is the sharpest example. Paragraph (L) prohibits relocation within Ohio of a vessel that does not bear the appropriate ASME symbol, was not registered with the National Board, and has no Ohio boiler number. Paragraph (K) gives the route for a secondhand ASME-stamped vessel: apply for the installation, file the manufacturer’s data report with the state, and have an inspection performed before operation.

Rhode Island puts the gate earlier. Under 260-RICR-30-10-2 section 2.5.21, a used vessel must be inspected by a qualified or National Board commissioned inspector before it can be shipped for installation in the state. Nevada handles it through permitting: NAC 455C.142 cancels the operating permit for a vessel moved from the site at which it was inspected and requires a new inspection and permit on reinstallation.

One lesson, three mechanisms. Confirm the destination jurisdiction’s requirements in writing with its chief inspector before the vessel ships.

What the paperwork actually proves

The Manufacturer’s Data Report is a construction record, not a condition warranty. Form U-1A is the alternative form for single chamber shop or field fabricated vessels, which is what most receivers and accumulators carry. Form U-1 is more likely on a multi-chamber intercooler.

The fields to match against the nameplate are manufacturer serial number, National Board number, year built, MAWP at maximum temperature, minimum design metal temperature, and test pressure. The Authorized Inspector’s certification states the vessel was built to ASME Section VIII Division 1 and expressly disclaims any warranty about it. A mismatch signals an undocumented alteration or rerate.

The 45 dollar asymmetry

The National Board sells copies of registered Manufacturers’ Data Reports at a flat 45 dollars per National Board number. What it needs is the original manufacturer’s name and the National Board number, plus serial number and year built if available. IIAR’s own IIAR 9 checklist says the same thing.

Lose the file and you have a 45 dollar problem. Lose the nameplate and you have a different problem entirely.

Form NB-136 governs replacement of stamped data. It is completed with a true facsimile of the legible part of the nameplate, submitted to the jurisdiction where the equipment is installed, approved by that jurisdiction, and concurred in by the original manufacturer if it is still in business, with a commissioned inspector witnessing the re-stamping. That is why a nameplate rubbing belongs on the pre-shipment checklist. Where documentation is gone entirely, the remaining path is a state special application with general arrangement drawings, design calculations demonstrating equivalency to ASME construction, and an inspection addressing weld integrity and damage mechanisms.

Repair, alteration, and the form that goes with each

A repair is documented on Form R-1, Report of Repair. An alteration is documented on Form R-2, Report of Alteration. A rerate is treated as an alteration, so it travels on an R-2.

Both require an organization holding a National Board R Certificate of Authorization, which is held by organizations rather than individuals and requires an inspection agreement with an authorized inspection agency, a written quality system, and an onsite review. Verify any firm’s credentials in the National Board’s Manufacturer and Repair Directory.

Pressure relief valve repair is separate and requires a VR Certificate of Authorization. A valve rebuilt by anyone other than a VR holder is not a code acceptable repair, so ask who did it and for their VR number.

The trap specific to refrigeration: MDMT

A rerate qualifies equipment for operating conditions that exceed its original stamped pressure or temperature rating, or that fall below its minimum design metal temperature. Moving a vessel built for warmer duty into low temperature ammonia recirculation service is a downward MDMT change. That is a rerate, which makes it an alteration, which puts it in R-stamp and R-2 territory with code calculations and a new nameplate.

Check MDMT against the intended suction condition before you buy, not after the vessel is on the pad. Our guide to vessels and heat exchangers covers the spec side.

The overlays that attach once it is installed

ANSI/IIAR 2 governs safe design of closed-circuit ammonia systems and ANSI/IIAR 6 covers inspection, testing, and maintenance. ANSI/IIAR 9 is the one most relevant to a used vessel: it sets minimum safety requirements for existing systems and gives a methodology for evaluating compliance. OSHA notes these are consensus standards rather than regulations, though they function as recognized good engineering practice and are widely adopted into state and local codes.

On relief valves, the conventional five year replacement interval for valves discharging to atmosphere originated with IIAR and carried into ANSI/IIAR 6, which also recognizes a sample bench testing alternative. Valves relieving internally into the closed circuit are treated differently: IIAR Interpretation 2020-2 states they are maintained per the manufacturer’s recommendations. Confirm against the edition of IIAR 6 in force.

Finally, a threshold worth running before you buy. OSHA’s process safety management standard lists anhydrous ammonia at 10,000 pounds, and EPA’s Risk Management Program lists it at the same figure, with aqueous ammonia at 20 percent or greater at 20,000 pounds. Those are system charge tests, not per-vessel tests, so adding a relocated recirculator can push an entire facility across the line.

What to demand before it ships

• The ASME Manufacturer’s Data Report, U-1 or U-1A as applicable.
• Nameplate photographs and a physical rubbing.
• National Board number, manufacturer name, serial number, and year built.
• Confirmation that nameplate data matches the data report on MAWP, MDMT, year, serial, and test pressure.
• Repair and alteration history with R-1 and R-2 forms and the R Certificate holder’s number.
• Relief valve make, model, set pressure, capacity, date, and the VR number of anyone who repaired one.
• The most recent signed and dated inspection report, with deficiencies noted.
• Service history: refrigerant and oil held, operating pressures and temperatures, and years in service.

None of this is exotic. It is the file a well-run plant already has, alongside the refrigerant documentation. When a seller cannot produce it, that is the finding, and it belongs in the price.

Refrigeration Equipment Pros sells surplus industrial refrigeration vessels, heat exchangers, compressor packages, and complete plants, and we supply the documentation that travels with them. Browse inventory at refrigerationequipment.net/shop, list equipment you are removing on our Sell To Us page, or call or text 201-805-1441. Inspections, repairs, alterations, and re-stamping are performed by R and VR Certificate holders, National Board commissioned inspectors, or the jurisdiction, and we will point you to the right one.

About the Author

Michael Rosenberg writes on the industrial refrigeration equipment market for Refrigeration Equipment Pros, a surplus and used equipment dealer with more than 25 years in ammonia and halocarbon systems, plant decommissioning, and equipment valuation. The company operates warehouse locations in Newfield, New Jersey, Houston, Texas, and Patterson, California. This article is general information about code and jurisdictional requirements and is not engineering or legal advice.

Sources

1. National Board, NB-57 The National Board and ASME Guide: https://www.nationalboard.org/SiteDocuments/NB-57.pdf
2. National Board, Synopsis of Boiler and Pressure Vessel Laws, Rules and Regulations (NB-370): https://www.nationalboard.org/viewallsynopses.aspx
3. National Board, Manufacturers’ Data Report copies and ordering: https://www.nationalboard.org/index.aspx?pageID=113&ID=442
4. National Board, Registration of pressure retaining items: https://www.nationalboard.org/index.aspx?pageID=9
5. National Board, R Certificate of Authorization: https://www.nationalboard.org/index.aspx?pageID=115&ID=160
6. National Board, VR Certificate of Authorization: https://www.nationalboard.org/index.aspx?pageID=115&ID=161
7. National Board, Manufacturer and Repair Directory: https://buscenter.nationalboard.org/MfgRepDir.aspx
8. National Board, Form R-1 guide NB-66 and Form R-2 guide NB-229: https://www.nationalboard.org/SiteDocuments/Online%20Ordering/R-1Form_NB-66_Guide.pdf and https://www.nationalboard.org/SiteDocuments/Online%20Ordering/R-2Form_NB-229_guide.pdf
9. National Board, Form NB-136 Replacement of Stamped Data: https://www.nationalboard.org/SiteDocuments/Online%20Ordering/NB-136.pdf
10. ASME, Form U-1A Manufacturer’s Data Report for Pressure Vessels: https://www.asme.org/wwwasmeorg/media/resourcefiles/aboutasme/standards_certification/bpvc%20data%20forms/bpvc_viii-1_u-1a.pdf
11. Ohio Administrative Code Rule 4101:4-9-01, effective July 1, 2024: https://codes.ohio.gov/ohio-administrative-code/rule-4101:4-9-01
12. Rhode Island 260-RICR-30-10-2, Boiler and Pressure Vessel Rules: https://rules.sos.ri.gov/Regulations/part/260-30-10-2?reg_id=10729
13. Nevada Administrative Code Chapter 455C: https://www.leg.state.nv.us/nac/nac-455c.html
14. The Equity Engineering Group, Basics of Rerating Equipment, June 27, 2023: https://e2g.com/industry-insights-ar/basics-of-rerating-equipment/
15. Becht, State Approval of Used or Relocated Pressure Vessels, July 3, 2015: https://becht.com/becht-blog/entry/state-approval-of-used-or-relocated-pressure-vessels/
16. IIAR 9 Checklist, data report and relief valve provisions: https://www.iiar.org/common/Uploaded%20files/iiar_docs/iiar%20standards/Addendum/IIAR_9_Checklist.pdf
17. IIAR Standards Committee Interpretation 2020-2, internally relieving pressure relief valve replacement, August 24, 2020: https://www.iiar.org/common/Uploaded%20files/IIAR_Docs/Standards/Standards%20Interpretations/Interpretation%202020-2%20%20Internally%20Relieving%20Pressure-Relief%20Valve%20Replacement-%20Final.pdf
18. OSHA, 29 CFR 1910.119 Appendix A, list of highly hazardous chemicals and threshold quantities: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.119AppA
19. EPA, List of Regulated Substances under the Risk Management Program, updated April 24, 2026: https://www.epa.gov/rmp/list-regulated-substances-under-risk-management-program

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

Frozen food sales exceeded 87 billion dollars in 2025, up 27.4 billion since 2019, and the GCCA Global Top 25 now operate 7.76 billion cubic feet of temperature-controlled space, up 6.3 percent in a year. At the same time, plant consolidation keeps releasing equipment. The JBS and Pilgrim’s closures announced in June 2026 affected at least 2,000 workers across value-added beef and poultry facilities, which are exactly the plant types that run spirals and blast cells.

That is the supply side of the secondary market. Here is how to buy from it.

Match the machine to the product, not to the tonnage

• Spiral belt freezers handle long dwell times in a small footprint and dominate continuous lines. Capacities run from packaged units around 1,000 to 2,000 pounds per hour up to site-assembled machines well above 10,000.
• Straight belt and tunnel freezers suit shorter dwell and simpler product handling, with continuous air blast typically operating at minus 35 to minus 40 degrees C.
• Impingement freezers use high velocity air jets and are effective only on flat product, generally no taller than 20 mm.
• Fluidized bed freezers are the IQF answer for raw fruits and vegetables and small free-flowing pieces.
• Horizontal plate freezers handle prepacked cartons and fillet blocks at 32 to 100 mm thickness with contact on both faces. Vertical plate freezers handle whole fish and bulk product at 25 to 130 mm, typically on a three to four hour cycle.
• Blast cells and rooms freeze palletized or carton product over 24 hours to several days.

Freezing time is the parameter buyers underestimate. Per FAO’s technical guidance, for products under 50 mm thick, doubling the thickness may more than double the freezing time, and past 100 mm doubling it may increase freezing time fourfold. Thickness, not tonnage, drives the machine.

The sizing math a seller will not do for you

Throughput on a belt machine is effective belt area multiplied by loading density and divided by retention time. Effective belt area is belt width times effective belt length, which is less than total belt length once infeed and outfeed are deducted. Raising throughput at a fixed retention time requires more belt area or denser loading. Cutting retention time only raises throughput if the refrigeration system can pull the heat out in the shorter dwell, which is why coil size and belt length must be evaluated together.

Carton blast design gives a useful sanity check on air side capacity. Published design data shows solid fibreboard cartons at 150 mm and 27 kg need roughly 5 meters per second at minus 30 degrees C to freeze within 24 hours, while corrugated cartons need about 7 meters per second at close to minus 40 degrees C for the same result. Evaporators on 24 hour units are sized at least 50 percent above the average refrigeration load, with fin spacing no more than four fins per inch and pumped rather than direct expansion feed.

Sanitation is where older machines fail

Under 21 CFR 117.40, equipment must be adequately cleanable, food contact surfaces must be corrosion resistant and nontoxic, seams must be smoothly bonded to minimize accumulation, and equipment must be installed so that it and the space around it can be cleaned. USDA FSIS adds a requirement in 9 CFR 416.3(b) that is easy to miss in a tight retrofit: equipment must not be located or operated in a way that prevents inspection program employees from inspecting it.

For meat and poultry equipment, NSF/ANSI/3-A 14159-1-2024 sets hygienic design requirements. Note its scope: it does not address mechanical belt conveyors, so it is not the standard that governs the spiral belt itself.

There is also a formal route for previously accepted equipment. USDA AMS Form DA-157 validates a prior meat and poultry equipment acceptance, worth pursuing on a machine that carried one in its first life.

What to inspect, and what the belt OEM says to look at

Ashworth, which makes the belts these machines run on, publishes maintenance guidance that doubles as an inspection list. Check belt tension and overdrive, since overdrive changes as the belt stretches. Read take-up height as a tension indicator. Inspect belt support wear strips for elongation that creates catch points and metal-on-metal contact. Inspect cage bar caps throughout, most intensely at the top and bottom tiers where tension is highest. Physically inspect bearings, because remote grease lines can freeze from condensation and never deliver lubricant.

Drive architecture matters at resale. On a positive drive spiral, belt speed always matches drum speed and overdrive is eliminated, and one published Ashworth specification lists maximum allowable tension of 400 pounds through a turn and 800 pounds in a straight run. A low tension overdrive spiral and a positive drive spiral are not interchangeable in belt, cage, or spare parts terms.

Beyond the belt, look at coil condition and the defrost system, insulated panel condition and moisture ingress, the drive and motor and starter package, and how the machine was taken out. Site-assembled spirals were built in place and must be rebuilt in place.

Footprint and elevation

In a brownfield retrofit the replacement footprint is often smaller than the machine coming out, and inlet and discharge conveyor elevations frequently differ. Both need an upstream and downstream process review before purchase, not after delivery.

The refrigerant question when the machine changes hands

This is commonly stated wrong, so be precise. Under EPA Section 608, recycling means extracting refrigerant and cleaning it for reuse in equipment of the same owner. Recovered and recycled refrigerant can go back into the same system or other systems owned by the same person without being reclaimed. Once the refrigerant changes owners, that allowance no longer applies and reclamation to the purity specification in AHRI Standard 700-2016 by an EPA-certified reclaimer is the pathway.

For equipment dismantled on site, including industrial process refrigeration, refrigerant must be recovered before disposal, and where equipment enters the waste stream charged, the final person in the disposal chain carries the recovery obligation. We covered the mechanics in detail in refrigerant reclamation and recovery and the 2026 reclaim rules. Ammonia machines sit outside those rules, because ammonia is not an HFC. The governing documents are ANSI/IIAR 8 for decommissioning and ANSI/IIAR 9, which sets minimum safety requirements for existing closed-circuit ammonia systems. IIAR 9 is the right framework for judging whether an older ammonia freezer can be brought into compliance, and any vessels that come with it carry their own jurisdictional requirements.

Refrigeration Equipment Pros sources and sells surplus freezing and refrigeration equipment from food plant decommissionings across North America. Browse inventory at refrigerationequipment.net/shop, list a line you are taking out of service on our Sell To Us page, or call or text 201-805-1441 with product, throughput, and entry and exit temperatures.

About the Author

Michael Rosenberg writes on the industrial refrigeration equipment market for Refrigeration Equipment Pros, a surplus and used equipment dealer with more than 25 years in ammonia and halocarbon systems, plant decommissioning, and equipment valuation. The company operates warehouse locations in Newfield, New Jersey, Houston, Texas, and Patterson, California.

Sources

1. FAO, Freezing and refrigerated storage in fisheries, freezing equipment and freezing time chapters: https://www.fao.org/4/v3630e/v3630e05.htm and https://www.fao.org/4/v3630e/V3630E06.htm
2. F.J. Bowater, Design of Carton Air Blast Freezing Systems, presented to the International Institute of Refrigeration: https://www.fjb.co.uk/wp-content/uploads/2018/02/Design-of-Carton-Air-Blast-Freezing-Systems.pdf
3. Air Products, Choosing the right freezing technology, May 2014: https://www.airproducts.com/-/media/files/en/332/332-09-015-gb-may14-cold-feat-choosing-the-right-freezing-technology.pdf
4. 21 CFR 117.40, Equipment and utensils, eCFR: https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-117/subpart-B/section-117.40
5. 9 CFR 416.3, Equipment and utensils, eCFR: https://www.ecfr.gov/current/title-9/chapter-III/subchapter-E/part-416/section-416.
6. 6. ANSI Blog, NSF/ANSI/3-A 14159-1-2024, Hygiene Requirements for the Design of Meat and Poultry Processing Equipment, January 9, 2025: https://blog.ansi.org/ansi/nsf-ansi-3a-14159-1-2024-meat-processing-equipment/
7. USDA AMS, Equipment Review programs and Form DA-157: https://www.ams.usda.gov/services/auditing/equipment and https://www.ams.usda.gov/resources/da157
8. Ashworth, Seven Preventative Maintenance Checklist Tips for Spiral Belts: https://www.ashworth.com/the-feed/seven-preventative-maintenance-checklist-tips-for-spiral-belts/
9. Ashworth, PosiDrive Spiral technical bulletin TECH-119, revised June 17, 2020: https://www.ashworth.com/media/udrfh4fz/tech-119.pdf
10. Refrigerated & Frozen Foods, Overcoming Processing Bottlenecks with Spiral Freezers, March 24, 2025: https://www.refrigeratedfrozenfood.com/articles/103300-overcoming-processing-bottlenecks-with-spiral-freezers
11. Refrigerated & Frozen Foods, Refrigerated, Frozen and Flourishing: State of the Cold Chain, July 8, 2026: https://www.refrigeratedfrozenfood.com/articles/104496-refrigerated-frozen-and-flourishing-state-of-the-cold-chain
12. GCCA, At the Top of Global Warehouse Capacity, June 19, 2026: https://www.gcca.org/magazine-article/at-the-top-of-global-warehouse-capacity/
13. Food Dive, JBS beef plant closures and Pilgrim’s layoffs, June 15, 2026: https://www.fooddive.com/news/jbs-beef-plant-closures-layoffs-pilgrims-manufacturing/822910/
14. EPA, Stationary Refrigeration Refrigerant Reclamation Requirements, updated March 24, 2026: https://www.epa.gov/section608/stationary-refrigeration-refrigerant-reclamation-requirements
15. EPA, Recovering, Recycling and Reclaiming Refrigerants, updated August 26, 2026: https://www.epa.gov/section608/recovering-recycling-and-reclaiming-refrigerants
16. EPA, Stationary Refrigeration Safe Disposal Requirements, updated March 23, 2026: https://www.epa.gov/section608/stationary-refrigeration-safe-disposal-requirements
17. IIAR Standards catalog, including ANSI/IIAR 8 Decommissioning and ANSI/IIAR 9 Minimum System Safety Requirements for Existing Systems: https://www.iiar.org/

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

Buyers spend their diligence on the compressor. Then the job stalls waiting on a transformer. The chiller lead time story gets the coverage, but the electrical package is usually the longer pole.

The most widely cited numbers come from a Wood Mackenzie survey conducted with American Clean Power in the second quarter of 2025: power transformers at 128 weeks, generator step-up units at 143 weeks, switchgear at 44 weeks, distribution transformers at 30 weeks. Those figures are more than a year old and are still being quoted as current by national law firms in September 2026, which tells you nothing has displaced them.

Newer 2026 figures exist but come from a single contractor’s procurement book rather than a survey: 52 to 80 weeks for medium voltage switchgear and 40 to 65 weeks for pad-mount distribution transformers. Published forecasts of relief have repeatedly been wrong. A 2024 analysis projected medium voltage switchgear falling toward 24 weeks by 2027, and it went up instead.

Why it is not getting better soon

Demand for power transformers rose roughly 116 percent between 2019 and 2025 and generator step-up units rose 274 percent, while actual US electricity demand grew about 7 percent. This is not a demand-for-power story, it is a demand-for-hardware story. Wood Mackenzie modeled a 30 percent shortfall for power transformers in 2025.

Underneath it sits grain-oriented electrical steel. Cleveland-Cliffs’ Butler Works in Pennsylvania is the only domestic source, and domestic GOES tops out at 920 mm width while large core makers increasingly want more than 1,000 mm. Announced North American capacity expansions are real but land in 2027. That is the arithmetic: new gear ordered today arrives after a used package could be installed and running.

What actually transfers with a used compressor package

On screw compressor packages the motor is typically integral and flange-mounted, which eliminates coupling alignment. Starters and variable speed drives are usually options rather than standard, so they may or may not come with the skid. Confirm this in writing before you assume the package is complete.

For reference on what these motors look like new: Baldor’s ammonia compressor motor line runs 150 to 1000 HP, 460 V for 150 to 600 HP and 2300 or 4160 V for 400 to 1000 HP, open drip proof, 1.15 service factor at 40 degrees C ambient, Class F insulation with Class B temperature rise, at 3600 RPM. ABB’s Baldor-Reliance line covers 150 to 500 HP at 460 V in frames 405TS through 449TS, specified for high starting torque on reciprocating and screw compressors and for across-the-line or wye start delta run starting.

One detail that ends deals: wye-delta starting requires all six motor leads brought out. A used motor with three leads cannot be wye-delta started, no matter what the old starter did.

Starting method and what it costs you

Rockwell’s published comparison is the clean reference. Across-the-line starting draws about 600 percent of full load current at 100 percent of full load torque. Wye-delta drops inrush to about 200 percent but delivers only 33 percent starting torque, and open-transition designs momentarily disconnect the motor during changeover. A solid-state soft starter gives an adjustable 150 to 600 percent current limit, about 34 percent torque at a 350 percent limit, and never removes the motor connection. Match the starting torque to the compressor’s breakaway requirement.

Putting a used drive in front of a used motor

This is where buyers destroy windings. NEMA MG 1 Part 31 sets withstand levels for inverter-fed motors: at 600 V and below the peak voltage limit works out to about 3.1 times rated voltage, with a partial-discharge-free limit near 2.23 times rated. Above 600 V the limit is roughly 2.04 times rated. An older motor that was never built as inverter duty was not designed to those levels, so check the nameplate for an inverter duty rating before you put a drive on it.

The same standard covers bearing currents. Shaft voltages above 300 millivolts peak warrant bearing insulation, and inverter common-mode voltage can produce peaks of 10 to 40 volts shaft to ground, calling for insulating both bearings or adding filters, grounding brushes, or an isolation transformer.

Two derates get overlooked on export projects. Per ABB’s published drive documentation, output current derates roughly 1 percent per 100 meters above 1,000 meters of altitude and roughly 1 percent per degree C above 40 degrees C ambient. At Bogota’s elevation that is roughly a 16 percent derate before ambient. A drive sized correctly at sea level is undersized at altitude, which matters on the projects in our cold chain sourcing outlook.

What the code says about reused electrical gear

The 2023 NEC handles this explicitly. Section 110.20 permits reconditioned equipment except where prohibited, and each equipment article states its own rule.

• Permitted: motors (430.2), switchboards and switchgear (408.2), medium and high voltage circuit breakers and protective relays (245.2).
• Prohibited: panelboards (408.2), molded-case circuit breakers and low voltage fuseholders (240.2), GFCI and AFCI devices (210.2), surge protective devices (242.2), fire pump controllers and transfer switches.
• Marking: under 110.21(A)(2) reconditioned equipment must carry the reconditioner’s name or trademark, the date of reconditioning, and the word reconditioned, and the original listing mark must be removed or made permanently illegible.
• Motors specifically: 430.2 permits reconditioned motors where the work followed manufacturer instructions or nationally recognized standards, and the Informational Note names ANSI/EASA AR100.

The molded-case breaker prohibition is the one that catches people. A used low voltage lineup with reconditioned MCCBs in it is not a bargain.

Write ANSI/NETA ATS acceptance testing by an accredited testing organization into the purchase agreement. That converts an unknown-condition asset into a documented one before it is energized.

Two things worth knowing about rewinds and old transformers

A rewind is not automatically an efficiency penalty. The EASA and AEMT study of 23 motors from 50 to 300 HP found that best-practice repair holds efficiency within plus or minus 0.2 percent. The killers are burnout temperature that is too low, poor control of mean length of turn, core damage during coil removal, and over-greasing bearings. Ask the shop for the burnout temperature record and the core loss test taken before and after. EASA warns the guidance does not extend to explosion-proof motors. On transformers, the governing date is July 2, 1979. Under 40 CFR 761.2 a mineral-oil transformer built before that date must be assumed PCB-contaminated absent testing, and an unknown manufacture date forces the most conservative category. As with a relocated pressure vessel, a missing nameplate is not a cosmetic defect. Test the fluid before you buy.

Refrigeration Equipment Pros stocks surplus motors, starters, compressor packages, and complete refrigeration plants. Browse current inventory at refrigerationequipment.net/shop, list equipment you need to move on our Sell To Us page, or call or text 201-805-1441 with horsepower, voltage, and enclosure requirements.

About the Author

Michael Rosenberg writes on the industrial refrigeration equipment market for Refrigeration Equipment Pros, a surplus and used equipment dealer with more than 25 years in ammonia and halocarbon systems, plant decommissioning, and equipment valuation. The company operates warehouse locations in Newfield, New Jersey, Houston, Texas, and Patterson, California. This article is general information and is not a substitute for a licensed electrical engineer or your authority having jurisdiction.

Sources

1. Wood Mackenzie, Mind the gap: tackling supply chain challenges in the electric T and D sector, October 15, 2025: https://www.woodmac.com/news/opinion/mind-the-gap-tackling-supply-chain-challenges-in-the-electric-td-sector/

2. POWER Magazine, Transformers in 2026: Shortage, Scramble, or Self-Inflicted Crisis?, January 2, 2026: https://www.powermag.com/transformers-in-2026-shortage-scramble-or-self-inflicted-crisis/

3. Foley & Lardner via National Law Review, The Grid’s Bottleneck Isn’t Just Money, It’s Materials, September 3, 2026: https://natlawreview.com/article/grids-bottleneck-isnt-just-money-its-materials

4. Wood Mackenzie press release, Power and distribution transformers will face supply deficits of 30% and 10% in 2025, August 14, 2025: https://www.woodmac.com/press-releases/power-transformers-and-distribution-transformers-will-face-supply-deficits-of-30-and-10-in-2025/

5. Breakthrough Journal, America Makes the Wrong Steel for the Grid, August 14, 2026: https://www.breakthroughjournal.org/p/america-makes-the-wrong-steel-for

6. TD World, Medium Voltage Switchgear Supply and Demand, June 26, 2024: https://www.tdworld.com/distributed-energy-resources/article/55091365/medium-voltage-switchgear-supply-and-demand

7. ANSI/NEMA MG 1, Motors and Generators, Part 1 and Part 31: https://www.nema.org/docs/default-source/standards-document-library/mg-1-part-31-watermark.pdf

8. Rockwell Automation, Motor Starting Methods, Publication 150-AT005A-EN-P, July 2016: https://literature.rockwellautomation.com/idc/groups/literature/documents/at/150-at005_-en-p.pdf

9. Baldor, Ammonia Compressor Motors product literature: https://s3.amazonaws.com/www.motionusa.com/baldor/Ammonia_Compressor_Motors.pdf

10. ABB, Ammonia refrigeration compressor motors: https://www.abb.com/global/en/areas/motion/motors-generators/low-voltage-motors/nema-ac-motors-portfolio/definite-purpose-motors/ammonia-refrigeration-compressor

11. ABB, ACS550 drive user documentation (altitude and ambient derating): https://library.e.abb.com/public/3759982378ebbdb4852577970076592c/3AUA0000004067_REVB.pdf

12. IMEG, 2023 NEC: Using Reconditioned Equipment, Buyer Beware, April 6, 2023: https://imegcorp.com/insights/blog/2023-nec-using-reconditioned-equipment-buyer-beware/

13. Electrical Contractor Magazine, Reconditioning Requirements: How the NEC Handles This Type of Electrical Equipment, July 15, 2024: https://www.ecmag.com/magazine/articles/article-detail/reconditioning-requirements-how-the-nec-handles-this-type-of-electrical-equipment

14. UL Solutions, Reconditioned Electrical Equipment NEC Guide, August 29, 2019: https://www.ul.com/news/reconditioned-electrical-equipment-2020-nec-guide

15. ANSI Blog, ANSI/NETA ATS-2025 Electrical Power Testing, updated March 13, 2026: https://blog.ansi.org/ansi/ansi-neta-ats-2025-electrical-power-testing/

16. EASA and AEMT, The Effect of Repair/Rewinding on Motor Efficiency, ACEEE Summer Study proceedings, 2003: https://www.aceee.org/files/proceedings/2003/data/papers/SS03_Panel4_Paper_04.pdf

17. EASA, Good Practice Guide to Maintain Motor Efficiency: https://easa.com/resources/resource-library/good-practice-guide-to-maintain-motor-efficiency

18. 40 CFR 761.2, PCB assumptions for electrical equipment, eCFR: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-R/part-761/subpart-A/section-761.2

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

Chiller procurement in 2026 is not what it was three years ago. Turner Construction’s SourceBlue Q1 2026 cost index, published in May, put air-cooled chillers at 7 to 52 weeks and water-cooled chillers at 12 to 60 weeks. The prior period showed 8 to 40 and 10 to 47. The bottom of the range barely moved. The top went up by roughly a quarter.

Where the demand is coming from

CBRE reported 7,481 MW of data center capacity under construction in North America in the first half of 2026, up 24.8 percent and a record, with vacancy at 1.4 percent. That load has to be cooled, and the orders show up in OEM backlogs.

In Q2 2026 Trane Technologies reported a record backlog of 12.1 billion dollars, up 70 percent year over year, with applied bookings up 130 percent and data center orders up more than 300 percent. Carrier reported a backlog above 8 billion dollars, up roughly 40 percent, also with data center orders up more than 300 percent. Johnson Controls reported a 20 billion dollar backlog, up 26 percent organically.

Worth noting fairly: Trane’s chief executive said on that call that the company is not turning away orders and has capacity for the orders out there. Both things are true. The plants are not out of capacity. You are standing behind a long line of hyperscale buyers, and the electrical gear that goes with the machine is queued behind the same demand.

Cost pressure on top of schedule pressure

Copper traded at 6.30 dollars per pound on September 14, 2026, after a record 6.83 dollars in August, up more than 35 percent year to date. A shell and tube chiller is a copper-intensive machine. Section 232 duties on steel, aluminum, and copper articles were restructured in 2026 so that duty applies to the full customs value of an article rather than only its metal content.

We are not going to publish a headline tariff rate for chillers, because published sources disagree on which rate applies to commercial and industrial equipment as opposed to residential HVAC. Price your own landed cost with your customs broker. A used machine already sitting in a domestic warehouse is not an import, and it is not in anyone’s production queue.

What the EPA rules do and do not do to a used chiller

EPA’s Technology Transitions restrictions apply to new equipment. Existing operational chillers are not affected, there is no mandate to replace or retrofit, and owners may continue to repair existing systems, including replacing major components. A used R-134a machine is legal to own, run, service, and resell. It simply cannot be replicated as new equipment, which is a supply argument for the secondary market rather than a compliance problem for the buyer. We went through that rule, and the litigation now pending against it, in our piece on the HFC rollback in court.

New chillers face a 700 GWP limit: comfort cooling from January 1, 2025, industrial process refrigeration above minus 30 degrees C from January 1, 2026, and the minus 50 to minus 30 degrees C tier from January 1, 2028. R-513A at 630 GWP, R-1233zd(E) at roughly 5 to 7, and R-514A at 7 clear that bar. R-134a at 1,430 and R-410A at 2,090 do not.

The two refrigerants with a clock on them

R-22 virgin production and import ended January 1, 2020. Existing equipment can still run and be serviced, and reclaimed R-22 remains legal. R-123 is the sharper one: low pressure centrifugals made before January 1, 2020 can still be serviced, but HCFC-123 faces complete phaseout in 2030 with limited exceptions. Price that horizon in, or buy knowing you will convert.

What to inspect before you buy

Trane’s CenTraVac service literature recommends eddy current inspection of condenser and evaporator tubes every three years. That gives you a clean question: when was the last eddy current report, and can I see it? A machine several years past its last test has an unpriced tube bundle.

• Purge pump-out time on a low pressure machine. Cumulative purge run time is the chiller’s own leak log. Ask for it.
• Leak inspection records. Under the EPA rules effective January 1, 2026, appliances at or above 500 pounds of charge require quarterly leak inspections and those from 15 to 500 pounds require annual inspections, with three years of records retained. A compliant seller has these, and their absence is itself a finding.
• Control panel generation. Trane declared the Tracker, VariTrac central control panel, and thermostat control module obsolete effective April 4, 2018, with parts on last-time-buy inventory only. On many used machines the panel, not the compressor, is the real obsolescence clock.
• Run hours, starts counter, and documented rebuild history with parts lists and the servicing contractor named.
• Dated motor winding insulation resistance readings on all three phases plus phase to ground, with a starter and drive inspection report.

ASHRAE service life data puts packaged centrifugal chillers at a median 23 years and packaged reciprocating chillers at 20. Those are medians, not verdicts on a specific unit. Condition and records beat age.

One argument that gets missed: machinery room ventilation

ASHRAE Standard 15 sizes machinery room leak exhaust as Q equals 100 times the square root of G, where G is the refrigerant weight per circuit in pounds. For A2L refrigerants the requirement jumps. One published worked example puts a 250 ton chiller on R-1234ze at 19,000 CFM of exhaust against 3,162 CFM for the R-134a equivalent, and A2L systems also require detection that triggers emergency shutdown at 25 percent of the lower flammability limit.

If your machinery room was built for an A1 refrigerant, replacing that machine with a new A2L unit can trigger a ventilation upgrade that costs more than the gap between a new and a used chiller. Run the number before you assume new is simpler.

On price

There is no credible published cost comparison between new and used industrial chillers, and we are not going to invent a percentage. Price the specific machine. What you can put a number on is the cost of waiting: the schedule you miss, the temporary cooling you rent, and the production you do not run.

One specification note before you shop. Nameplate tonnage is a rating at AHRI 550/590 standard conditions, and capacity at your leaving chilled water temperature, condenser water temperature, fouling factor, and altitude will differ. Ask for the original selection printout, not just the nameplate. For brand level guidance see our guides to used air-cooled chillers from Trane, Carrier, and York and the most reliable used chiller brands.

Refrigeration Equipment Pros carries surplus chillers, compressors, condensers, and complete refrigeration plants pulled from decommissioned facilities across North America. Browse inventory at refrigerationequipment.net/shop, list equipment you need to move on our Sell To Us page, or call or text 201-805-1441 with a tonnage, a voltage, and a date.

About the Author

Michael Rosenberg writes on the industrial refrigeration equipment market for Refrigeration Equipment Pros, a surplus and used equipment dealer with more than 25 years in ammonia and halocarbon systems, plant decommissioning, and equipment valuation. The company operates warehouse locations in Newfield, New Jersey, Houston, Texas, and Patterson, California.

Sources

1. SourceBlue (Turner Construction), Q1 2026 Cost Index Report, May 7, 2026: https://sourceblue.com/news-insights/q1-2026-cost-index-report
2. CBRE, North American Data Center Demand Continues to Outpace Supply Despite Record Construction Activity, August 27, 2026: https://www.cbre.com/press-releases/north-american-data-center-demand-continues-to-outpace-supply-despite-record-construction-activity
3. Trane Technologies Q2 2026 earnings call transcript, July 30, 2026: https://www.fool.com/earnings/call-transcripts/2026/07/30/trane-technologies-tt-q2-2026-earnings-call-transcript/
4. HVACR Trends, Carrier and Trane Q2 Earnings: Data Centers Drive Record Backlogs Amid Rising Input Costs, August 1, 2026: https://hvacrtrends.com/carrier-and-trane-q2-earnings-data-centers-drive-record-backlogs-amid-rising-input-costs/
5. Johnson Controls, Q2 FY26 results, May 6, 2026: https://www.prnewswire.com/news-releases/johnson-controls-reports-strong-q2-results-raises-fy26-guidance-302763526.html
6. Trading Economics, copper price, September 14, 2026: https://tradingeconomics.com/commodity/copper
7. KPMG, New rules for calculating Section 232 tariffs on steel, aluminum, copper, April 2, 2026: https://www.kpmg.com/us/en/taxnewsflash/news/2026/04/united-states-new-rules-calculating-section-232-tariffs-steel-aluminum-copper.html
8. EPA, Technology Transitions HFC Restrictions by Sector, updated August 28, 2026: https://www.epa.gov/hfcs/technology-transitions-hfc-restrictions-sector
9. EPA, SNAP Substitutes in Centrifugal Chillers, updated March 19, 2026: https://www.epa.gov/snap/substitutes-centrifugal-chillers
10. EPA, Commercial Refrigeration and Air Conditioning Equipment Frequent Questions (R-22), updated April 2, 2026: https://www.epa.gov/ods-phaseout/commercial-refrigeration-and-air-conditioning-equipment-frequently-asked-questions
11. EPA, Management of HCFC-123 through the Phaseout and Beyond, August 2020: https://www.epa.gov/sites/default/files/2020-08/documents/us_management_of_hcfc-123.pdf
12. EPA, Emissions Reduction and Reclamation leak repair fact sheet, January 2026: https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-leak-repair-2026-01-13_1.pdf
13. Trane, CVHH CenTraVac Installation, Operation and Maintenance manual, CVHH-SVX003E-EN, December 2024: https://elibrary.tranetechnologies.com/public/commercial-hvac/Literature/Installation%20Operation%20and%20Maintenance/CVHH-SVX003E-EN_12202024.pdf
14. Trane Commercial HVAC Help Center, Tracker, VariTrac CCP, TCM Obsolescence and Availability, January 29, 2025: https://support.trane.com/hc/en-us/articles/16077725086349-Tracker-Varitrac-CCP-TCM-Obsolescence-and-Availability
15. ACHR News, ASHRAE Standard 15-2022 Plays Crucial Role in Refrigerant Transition, September 6, 2023: https://www.achrnews.com/articles/163224-ashrae-standard-15-2022-plays-crucial-role-in-refrigerant-transition
16. AHRI Standard 550/590 (I-P), Performance Rating of Water-Chilling and Heat Pump Water-Heating Packages: https://www.ahrinet.org/search-standards/ahri-550590-i-p-and-551591-si-performance-rating-water-chilling-and-heat-pump-water-heating-packages

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

In May 2026, EPA finalized a reconsideration of its Technology Transitions rule under the American Innovation and Manufacturing Act, published at 91 Fed. Reg. 31284 and effective July 27, 2026. It pushed several compliance deadlines out and raised the interim global warming potential ceilings that new refrigeration equipment has to meet. We covered what changed in our earlier piece on what the 2026 Technology Transitions rule means for used equipment buyers. Since then the rule has been challenged from both directions, and buyers planning capital purchases around the extended deadlines are right to ask what happens if it does not survive.

Five petitions, and they do not all want the same thing

What makes this litigation unusual is the alignment. This is not environmental groups on one side and industry on the other. Per EPA’s docket of petitions for judicial review, five petitions are now pending in the D.C. Circuit:

• HARDI, PHCC, and ACCA filed June 24, 2026 (No. 26-1168), arguing that extending demand for legacy refrigerants while AIM Act supply caps tighten will disrupt the market and raise refrigerant costs.
• AHRI and the Alliance for Responsible Atmospheric Policy filed June 25, 2026 (No. 26-1174).
• The Natural Resources Defense Council filed July 20, 2026 (No. 26-1188), arguing EPA extended purchase deadlines by five or more years in violation of the AIM Act.
• Eighteen state attorneys general, the District of Columbia, and the City of New York filed July 21, 2026.
• ALTA Refrigeration and CUSER filed July 24, 2026 (No. 26-1202).

On the other side, a retail coalition including the Retail Litigation Center, FMI, the American Frozen Food Institute, and the National Grocers Association moved to intervene in support of EPA. Supermarket operators want the extra runway. Contractor and manufacturer groups want the certainty of the original schedule. As of this writing no court has ruled, no stay has been sought or granted in any public filing we could locate, and the rule is in effect.

Read the regulation, not the headline

The Technology Transitions restrictions live at 40 CFR 84.54, and the section is built in three parts. Paragraph (a) prohibits manufacture and import of covered products. Paragraph (b) prohibits sale and distribution of those products, effective three years after the paragraph (a) dates. Paragraph (c) prohibits installation of covered systems. There is no paragraph restricting use, operation, or continued operation, and EPA’s sector guidance says the same thing: the restrictions apply to new equipment, with no mandate to replace or retrofit what is already installed.

That structure matters more to a used equipment buyer than the litigation does. Cold storage warehouse systems, supermarket systems, and remote condensing units appear in paragraph (c) only. They are field-assembled, so the rule governs who may install them, not who may sell them. Industrial process refrigeration chillers and non-chiller IPR products do appear in paragraph (a), so a sale restriction attaches, but it is offset three years from the manufacture and import date.

The exposure is in the installation restriction

Paragraph (c) is worth quoting because of who it reaches: no person may install any system, nor have any such system be installed through their position as a designer, owner, or operator. The prohibition runs to the owner and the operator, not only the mechanical contractor holding the wrench.

The provenance of the hardware is irrelevant to that paragraph. It is written about the act of installing a system, so a used high-GWP system field-assembled after the applicable date is restricted conduct exactly as a new one would be. The date you complete and charge the circuit is the date that counts.

The current interim ceilings are 700 GWP for cold storage warehouse systems and 1,400 GWP for supermarket systems and remote condensing units. All three drop to 150 GWP at or above a 200 pound charge, and 300 GWP below it, on January 1, 2032. Those 2032 limits were not moved by the reconsideration rule, and no petitioner is asking the court to move them.

What a vacatur would and would not do

Nobody can tell you how the D.C. Circuit will rule. What we can say is what the closest precedent shows. In Clean Air Council v. Pruitt, decided July 3, 2017, the D.C. Circuit vacated EPA’s stay of methane rule requirements and the original compliance deadline sprang back into effect.

The comparison is imperfect. That case involved a short administrative stay. The May 2026 rule is a final legislative rule that amended the codified text at 40 CFR 84.54 through notice and comment. Whether vacating it would restore the prior text, produce a remand without vacatur, or take prospective effect only is not a question any published legal commentary we found has answered. Treat the pre-May-2026 deadlines as a live possibility, not a certainty, and price accordingly.

The equipment that is unaffected either way

Every restriction in section 84.54 applies to equipment using a regulated substance, meaning the listed HFCs. EPA’s preamble to the May 2026 rule states that CO2, hydrocarbons, and ammonia are not fluorinated chemicals. Ammonia (R-717) and CO2 (R-744) carry no GWP limit under this rule. Whatever the court does, a surplus ammonia screw package or a used chiller on an A1 refrigerant is outside the fight.

Our pieces on transcritical CO2 versus ammonia for industrial refrigeration and low-charge ammonia systems go into where each one fits.

What to do while the case is pending

• Separate the purchase decision from the installation decision. Buying a used high-GWP system is not the restricted act. Completing and charging its circuit after the applicable date is.
• Get the charge weight and refrigerant in writing before you buy. The 200 pound threshold sets the 2032 tier, and the refrigerant decides whether the rule touches the machine at all.
• Do not confuse this rule with the refrigerant handling rules, which we covered in the 2026 reclaim rules and refrigerant reclamation and recovery.
• If your timing sits close to a deadline, price the schedule against the original dates as well as the extended ones. For a project that has to be insulated from the outcome entirely, specify ammonia or CO2.

The rule is in force today, and its deadlines are the ones you have to meet now. But a compliance case built on an interim ceiling that five parties are asking a federal court to throw out is thinner than it looks. Confirm the refrigerant and charge, and keep the rest of the documentation that travels with the asset in order.

Refrigeration Equipment Pros stocks surplus ammonia, CO2, and halocarbon equipment from plant decommissionings across North America. Browse current inventory at refrigerationequipment.net/shop, submit equipment you need to move through our Sell To Us page, or call or text 201-805-1441 to talk through a specific machine with someone who knows the equipment.

About the Author

Michael Rosenberg writes on the industrial refrigeration equipment market for Refrigeration Equipment Pros, a surplus and used equipment dealer with more than 25 years in ammonia and halocarbon systems, plant decommissioning, and equipment valuation. The company operates warehouse locations in Newfield, New Jersey, Houston, Texas, and Patterson, California. This article is general information about federal regulation and is not legal advice.

Sources

1. Federal Register, Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act, 91 Fed. Reg. 31284, May 26, 2026: https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under
2. 40 CFR 84.54, Restrictions on use of regulated substances in sectors or subsectors, eCFR: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-B/section-84.54
3. EPA, Petitions for Reconsideration and Judicial Review of the October 2023 Technology Transitions Rule, updated August 13, 2026: https://www.epa.gov/hfcs/petitions-reconsideration-and-judicial-review-under-aim-act
4. EPA, Technology Transitions HFC Restrictions by Sector, updated August 28, 2026: https://www.epa.gov/hfcs/technology-transitions-hfc-restrictions-sector
5. NRDC, NRDC Sues EPA Over Costly Refrigerant Rollback, July 20, 2026: https://www.nrdc.org/press-releases/nrdc-sues-epa-over-costly-refrigerant-rollback
6. State Petition for Review, Commonwealth of Massachusetts, et al. v. EPA, filed July 21, 2026: https://coag.gov/app/uploads/2026/07/State-Petition-for-Review-HFCs.pdf
7. ACHR News, EPA Faces New Lawsuits Over HFC Refrigerant Rule Rollback, July 23, 2026: https://www.achrnews.com/articles/166470-epa-faces-new-lawsuits-over-hfc-refrigerant-rule-rollback
8. ACHR News, HVACR Trade Groups Challenge EPA Refrigerant Rule in Federal Court, June 25, 2026: https://www.achrnews.com/articles/166367-hvacr-trade-groups-challenge-epa-refrigerant-rule-in-federal-court
9. ACHR News, Grocers Fight to Keep EPA’s Refrigerant Deadline Extensions, July 29, 2026: https://www.achrnews.com/articles/166494-grocers-fight-to-keep-epas-refrigerant-deadline-extensions
10. Holland & Knight, EPA Finalizes Changes to Technology Transitions Provisions, May 26, 2026: https://www.hklaw.com/en/insights/publications/2026/05/epa-finalizes-changes-to-technology-transitions-provisions
11. Beveridge & Diamond, EPA Finalizes Targeted Relief from HFC Technology Transitions Rule, May 29, 2026: https://www.bdlaw.com/publications/epa-finalizes-targeted-relief-from-hfc-technology-transitions-rule/
12. Clean Air Council v. Pruitt, No. 17-1145 (D.C. Cir. July 3, 2017): https://law.justia.com/cases/federal/appellate-courts/cadc/17-1145/17-1145-2017-07-03.html

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

The conversion numbers

ATMOsphere published its natural refrigerant market data in May 2026. The North American picture: [1]

• 6,360 supermarket and industrial sites using R744 in 2025, up 28 percent year over year, representing 1,390 new systems added between 2024 and 2025.
• 5,120 supermarkets and grocery stores on transcritical CO2, roughly 6 percent of the approximately 85,110 stores across the US and Canada.
• Approximately 1,240 industrial facilities on transcritical CO2, up 42 percent year over year and 2.5 times the 2023 figure.
• Roughly 1,480 low charge ammonia systems and about 5.1 million self contained hydrocarbon cabinets in service.

The industrial growth rate is the number worth sitting with. Forty two percent year over year in industrial transcritical CO2 means the conversions are no longer concentrated in retail food. They are happening in the plants that run the equipment this market trades in.

Why conversion equipment is different from distressed equipment

There is a meaningful distinction between the two main sources of used industrial refrigeration equipment, and it changes what you should expect on the receiving dock.

Distressed equipment comes out of a plant that stopped. A bankruptcy, a line shutdown, a facility that ran to failure. The equipment may be fine, but it was often sitting before it was pulled, maintenance may have tapered in the final period, and documentation is frequently incomplete because the people who kept it are gone.

Conversion equipment comes out of a plant that is still operating. A cold storage operator moving to CO2 or low charge ammonia is executing a capital project, usually with a funded budget, an engineering firm involved, and a commissioning schedule for the replacement. The outgoing machines are typically running the week they are disconnected, and the maintenance records exist because the plant needed them right up to cutover.

That is a quality argument you can verify. Ask which of the two situations the package came from, and ask for the maintenance history and the run hours. On a conversion package, both should be available.

What carries over and what does not

When a plant converts, not everything that comes out is worth the same to the next buyer. The dividing line is generally how refrigerant specific the component is.

Usually transfers well

• Motors and starters. Electrically agnostic, long service life, and frequently the item with the worst new equipment lead time relative to cost.
• Control panels and switchgear, subject to the caveat below on controls integration.
• Condensers and cooling towers. Evaporative condensers in particular hold value well when the coil and basin are sound.
• Vessels, liquid receivers, and separators, where pressure rating and code stamping suit the new duty.
• Pumps, valve groups, and general auxiliary equipment.
• Ammonia compressor packages in general. An ammonia screw or reciprocating machine coming out of a plant converting to low charge ammonia or CO2 is often a straightforward fit for another ammonia operation.

Requires closer evaluation

• Refrigerant specific components. Anything sized, rated, or materially selected for the original refrigerant needs verification against the new duty rather than assumption.
• Evaporators. Circuiting, tube material, and defrost arrangement are application specific. Evaporators often transfer, but check the design conditions against yours.
• Safety systems, relief devices, and detection. Set points and sizing follow the original design. Treat these as items to be re-engineered rather than reused as configured.
• Controls software and integration. The panel may be excellent hardware and still require substantial work to talk to your system.

Our used compressor buyer checklist covers the mechanical inspection in detail, and it applies to conversion equipment the same as anything else.

Timing the market

Plant conversion packages do not sit. They come available on the conversion project schedule, which means a window of a few weeks between the decision to sell and the rigging date, and they move to whoever is ready.

If you have a known capacity need coming, the practical move is to tell a dealer what you are looking for before the package exists rather than after. Specifications, tonnage range, refrigerant, voltage, and footprint constraints. That way the match happens when the plant calls. This is how most cold storage expansion projects get equipped on schedule.

This is also the supply side reason the reclaim rules matter to buyers. Conversions are exactly the situation those rules were written for, and a conversion package handled by a seller who documented the refrigerant recovery properly is a cleaner asset than one that was not.

What this means if you are the one converting

If your plant is moving to transcritical CO2 or low charge ammonia, the outgoing equipment is an asset on a clock. Its value is highest while it is still running and documented, and it declines from the moment it comes out and sits.

Get a valuation before the rigging contractor is scheduled, not after the equipment is in a yard. That sequencing alone is usually worth more than any negotiation on the price. Submit your equipment or see how we buy used refrigeration equipment. On the buy side, browse current inventory or call 201-805-1441 with your specifications. Conversion packages move quickly, and the buyers who get them are the ones already on the list.

About the Author

Michael Rosenberg works with buyers and sellers of surplus and used industrial refrigeration equipment at Refrigeration Equipment Professionals, which has supplied ammonia and freon systems directly to contractors and plants for more than 25 years. His day to day work covers plant decommissioning packages, compressor and chiller sourcing for food processing, cold storage, brewing, and industrial refrigeration operations, and equipment valuations for owners liquidating or upgrading a refrigeration plant. Reach him at 201-805-1441 or through the contact page.

Sources

1. ATMOsphere, Refrigeration: Commercial and Industrial Refrigeration with Natural Refrigerants (May 2026), reported by NaturalRefrigerants.com. https://naturalrefrigerants.com/news/adoption-transcritical-co2-north-america-increased-28-in-2025/
2. IIAR Condenser, The Design of CO2 Refrigeration Systems Using Ammonia System Design Principles. https://iiarcondenser.org/the-design-of-co2-refrigeration-system-using-ammonia-system-design-principles/
3. U.S. EPA, Emissions Reduction and Reclamation Program fact sheet on reclaim requirements (January 2026). https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-reclaim-2026-01-13.pdf

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

The fundamentals say build. The cost structure says do not.

The demand picture for temperature controlled space is about as strong as it gets in industrial real estate. Development Magazine reported this summer that temperature controlled facilities represent only 2 to 5 percent of total US industrial inventory, vacancy is often below 2 percent, rents run 100 to 200 percent above conventional industrial space, and cap rates reach 7.65 percent, a 50 to 100 basis point premium over dry warehouses. [1]

The US cold storage market was roughly 44 billion dollars in 2025 with projections approaching 125 billion by 2034, driven by online grocery, pharmaceutical cold chain requirements including storage at minus 20 to minus 80 degrees Celsius, and frozen food capacity. [1]

Now the other side of the ledger. Cold storage construction runs 130 to 350 dollars per square foot, and 250 to 400 dollars per square foot for advanced automated facilities. That is two to three times the cost of dry warehouse for the same footprint. [1] Layer on elevated equipment costs, with tariff driven increases reported in the 15 to 30 percent range for commercial HVAC and refrigeration equipment, and long manufacturer lead times worsened by data center cooling demand competing for the same production capacity, and the ground up build stops penciling for a lot of operators. [2] [3]

The market has responded. Speculative cold storage development has corrected, and the operators who still need capacity are looking at what they already own. [4]

The fleet you already have is the opportunity

Over 75 percent of US cold storage predates 2000, and the average facility is around 37 years old. [1] Read pessimistically, that is an obsolescence problem. Read accurately, it is an installed base of buildings in the right locations with the right zoning, the right power service, the right dock configuration, and refrigeration plants that were sized for a different throughput than they carry today.

A 1990s ammonia plant in a well located building is not a liability. It is a foundation with an envelope, a slab, a machine room, and a utility service already in place. Those are the expensive parts of cold storage, and replacing them is what drives the 130 to 350 dollar per square foot number.

What those plants usually need is capacity, efficiency, or both. That is an equipment problem, and equipment problems are solvable on a timeline that a construction project cannot match.

Where the tonnage actually comes from

De-bottlenecking an existing plant follows a predictable order. In most facilities the constraint is one of four things, and the fix for each is available on the secondary market.

Compression capacity

The most common constraint and usually the most expensive to solve new. A matched screw compressor package or an added reciprocating machine on the existing suction group can add substantial tonnage without touching the building. Our comparison of screw and reciprocating compressors covers where each makes sense.

Evaporator surface

Frequently the real limit in older freezers, especially where product mix has shifted toward faster pulldown. Adding evaporator surface is the cheapest tonnage in the plant when the compression capacity is already there, and it is often the first thing an energy audit finds.

Heat rejection

An undersized or fouled condenser raises head pressure and steals capacity from every machine in the room. Condensers and cooling towers are frequently available in good condition from plant conversions, and the payback on right sizing heat rejection is usually the shortest in the project.

Vessels, controls, and the rest

Liquid receivers and separators, valve groups, control panels, and motors and starters are the components that turn a compressor purchase into a working capacity increase. They are also the components with the longest new equipment lead times relative to their cost, which is exactly where surplus earns its keep.

One regulatory note that works in favor of this approach: under the 2026 Technology Transitions rule, a capacity increase of 15 percent or less is not treated as an installation for compliance purposes. That gives incremental expansion more room than a full system replacement would have.

The schedule argument

The cost comparison is the one that gets presented to the board. The schedule comparison is the one that usually decides it.

A ground up cold storage project runs years from site selection to first pallet. An expansion inside an existing envelope runs months, and a targeted capacity project can run weeks when the equipment is on the ground. In a market with vacancy under 2 percent, capacity you can use this season is worth more than capacity you can use in three years, and the difference is not close.

That is the argument for sourcing surplus specifically rather than simply expanding rather than building. New equipment lead times are the binding constraint on a lot of expansion projects right now. Equipment that already exists does not have a lead time, it has a freight schedule. [3] That also drives year end tax timing.

What to check before you commit

• Electrical service headroom. Added compression means added connected load. Confirm the service and the switchgear before you buy the machine, not after.
• Machine room space and code clearance. Adding a package to a room designed for what is already in it is where projects stall.
• Refrigerant strategy. If the plant is on HFCs, understand what limits apply and when. If it is on ammonia, understand what the added charge does to your PSM and RMP position.
• Insulation and vapor barrier condition. More tonnage into a leaking envelope is money spent on the wrong problem. This is the one item where the answer is sometimes that the building really does need replacing.
• Control system compatibility. Older plants often run controls that will not talk to a modern package without an interface. Budget for it up front.

We supply matched packages and components for exactly this kind of project, including full refrigeration plants from facility conversions. Browse current inventory or call 201-805-1441 with your capacity target and existing plant configuration, and we will tell you what we have that fits. Our overview of why surplus works covers the broader case, and our piece on the food and beverage cold chain looks at the same problem from the processing side.

About the Author

Michael Rosenberg works with buyers and sellers of surplus and used industrial refrigeration equipment at Refrigeration Equipment Professionals, which has supplied ammonia and freon systems directly to contractors and plants for more than 25 years. His day to day work covers plant decommissioning packages, compressor and chiller sourcing for food processing, cold storage, brewing, and industrial refrigeration operations, and equipment valuations for owners liquidating or upgrading a refrigeration plant. Reach him at 201-805-1441 or through the contact page.

Sources

1. Michael Delaney, Cold Storage Investment: The Case for Temperature-controlled Real Estate, Development Magazine, Summer 2026. https://www.credaglobal.org/research-and-publications/magazine/2026/Summer-2026/finance/cold-storage-investment-the-case-for-temperature-controlled-real-estate
2. Facilities News, Multi-Site Operators and Capital Planners Feel the Squeeze as Tariffs Push HVAC Costs Up 15-30%. https://www.facilitiesnews.com/news/tariffs-hvac-equipment-costs-multi-site-capital-planning
3. The Cooling Report, Where Cooling Components Come From and Why They Are Late: The 2026 Data Center Cooling Supply Chain Guide. https://thecoolingreport.com/intel/data-center-cooling-supply-chain-guide-2026.html
4. Westside Construction Group, Cold Storage Construction: What a Market Correction Tells Us About the Next Build Cycle (2026). https://www.buildwcg.com/blog-posts/cold-storage-construction-market-correction-2026

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

Scope and thresholds

The rule applies to refrigerant containing appliances with a full charge of 15 pounds or more that use HFCs or HFC substitutes with a global warming potential above 53. Residential and light commercial air conditioning and heat pump systems are exempt. [1]

The leak rate thresholds are set by application, not by equipment type:

• Industrial process refrigeration: 30 percent
• Commercial refrigeration: 20 percent
• Comfort cooling and refrigerated transport: 10 percent

Exceed the applicable threshold and the clock starts on repair, with retrofit or retirement planning required if the repairs do not hold. [2] The thresholds are annualized leak rates, which means a system that loses a large charge quickly can cross the line well inside a year.

The inspection burden is the real cost

The repair obligation gets the attention. The inspection schedule is what shows up in the operating budget every year.

• 500 pounds or more: inspections once every three months, continuing until leak rate calculations show the appliance has stayed under the applicable threshold for four consecutive quarters.
• 15 to 500 pounds: annual inspections, with the same one year of compliant operation standard.
• Comfort cooling: annual inspections.
• Automatic leak detection (ALD): can be used as a compliance option in place of the inspection requirements.
• Recordkeeping: three years, paper or electronic.

On a large ammonia free HFC plant, quarterly inspection of every covered appliance is not a trivial line item, and it does not go away until the system demonstrates four clean quarters. A system with a history of chronic small leaks can sit in quarterly inspection indefinitely.

What this does to used equipment due diligence

The mechanical inspection you already do on a used package has not changed. What has changed is that several of the findings now carry a quantifiable recurring cost instead of a vague one.

Ask for the leak history, not just the service records

Records are kept for three years, which means on most recently operating equipment the leak history exists. A seller who cannot produce it is either not looking or not telling you something. Request the leak rate calculations, not just the repair invoices, because the calculation is what determines inspection frequency.

Price the seals and gaskets against the threshold, not against the repair cost

A shaft seal replacement is a known number. What matters more is whether the system’s leak profile is going to hold under the applicable threshold once it is running in your facility, because that determines whether you inspect quarterly or annually. The same repair carries a very different downstream cost depending on which side of the threshold the system settles.

Evaluate whether ALD can be retrofitted

Automatic leak detection is available as an alternative to the inspection schedule. On a large system, that trade can be worth more than the detection hardware costs. Assess during due diligence whether the machine room layout, the control panel capacity, and the system architecture make an ALD retrofit practical, and get a number for it before you close.

Confirm the actual charge against the 15 pound line

Coverage turns on full charge. On smaller condensing units and packaged systems, the difference between an appliance that is covered and one that is not can be a matter of pounds. Verify the real charge rather than the nameplate figure, and remember that the same verification drives your GWP obligations under the 2026 Technology Transitions rule.

The ammonia contrast, stated honestly

R-717 is not an HFC, and ammonia systems fall outside this rule entirely. For an operator weighing a used ammonia plant against a used HFC plant, that is a genuine difference in ongoing compliance burden, and it is one reason ammonia continues to hold its position in industrial applications.

It is not a free pass. Ammonia carries its own regulatory weight. Above threshold quantities, OSHA process safety management and EPA risk management program obligations apply, and those programs are more demanding in aggregate than quarterly leak inspection. [3] [4] Mechanical integrity programs, process hazard analysis, operator training, and emergency response planning are real and ongoing costs.

The honest comparison is not that ammonia has no compliance burden. It is that ammonia’s burden is well established, well understood by the contractors who service it, and stable, while the HFC regulatory picture has moved three times in three years. If your operation already runs ammonia compressors and has a mature PSM program, adding ammonia capacity is a smaller marginal step than most buyers assume. If it does not, the startup cost of a PSM program belongs in the acquisition analysis.

Our comparison of screw and reciprocating compressors covers the mechanical side of that decision. This is the regulatory side of it.

Putting a number on it

For a used HFC system, add these to the acquisition model: inspection labor at the applicable frequency, the cost of an ALD retrofit if it makes sense, seal and gasket work required to bring the leak rate under threshold, and the recordkeeping overhead. For a used ammonia system, add PSM and RMP program cost where threshold quantities apply, or confirm the marginal cost is near zero because the program already exists.

Then compare. In a lot of cases the ammonia package still wins on total cost of ownership, and now there is a defensible compliance reason to put in the file alongside the efficiency argument. If the system in question is going into an existing refrigerated warehouse, run the same numbers against the retrofit versus new construction comparison.

Browse ammonia and freon inventory or call 201-805-1441 to talk through a specific package. If you are moving equipment out, submit it here.

About the Author

Michael Rosenberg works with buyers and sellers of surplus and used industrial refrigeration equipment at Refrigeration Equipment Professionals, which has supplied ammonia and freon systems directly to contractors and plants for more than 25 years. His day to day work covers plant decommissioning packages, compressor and chiller sourcing for food processing, cold storage, brewing, and industrial refrigeration operations, and equipment valuations for owners liquidating or upgrading a refrigeration plant. Reach him at 201-805-1441 or through the contact page.

Sources

1. U.S. EPA, Leak Repair Requirements for Appliances Containing HFCs fact sheet (January 2026). https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-leak-repair-2026-01-13_1.pdf
2. U.S. EPA, Regulatory Actions for Managing HFC Use and Reuse. https://epa.gov/climate-hfcs-reduction/regulatory-actions-managing-hfc-use-and-reuse
3. U.S. OSHA, Ammonia Refrigeration: Evaluation and Control. https://www.osha.gov/ammonia-refrigeration/evaluation-control
4. U.S. EPA, Risk Management Program (RMP) Rule. https://www.epa.gov/rmp

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net

The provision that changes how packages get sold

Most of the coverage of EPA refrigerant rules over the last two years has focused on what you are allowed to install. The ER&R program contains a provision that speaks to something different, which is what you are allowed to transfer.

Equipment containing recovered HFCs cannot be sold to a new owner unless the refrigerant in it meets the reclaimed standard, or the equipment is going to reclamation or destruction. [1] That is a transaction level rule, and it applies whether the asset is a single condensing unit or an entire plant package.

For a food processor closing a line, a cold storage operator converting a plant, or a brewery consolidating capacity, this belongs on the decommissioning checklist alongside lockout tagout and rigging. It is not a technicality that gets sorted out at the buyer end.

What counts as reclaimed refrigerant now

The standard tightened on January 1, 2026, and the details matter because they determine what documentation is worth anything.

• Reclaimed HFCs cannot contain more than 15 percent virgin HFC by weight. Virgin means newly produced.
• Only refrigerant processed by an EPA certified reclaimer that meets the applicable standard qualifies. Recovery alone does not make refrigerant reclaimed.
• Containers must carry a label certifying that the contents do not exceed the 15 percent virgin threshold.
• Certified reclaimers keep records for three years, covering contact information, batch certification, the virgin percentage per batch, fill dates, quantities, container serial numbers, and batch identification.

Recovery and reclamation are different operations, and the distinction is where most sellers get tripped up. A technician who pulls the charge into a recovery cylinder has recovered it. It becomes reclaimed refrigerant only after a certified reclaimer processes it to the standard and certifies the batch. [1] [2]

The 2029 servicing requirement and why it matters now

Beginning January 1, 2029, three subsectors must use reclaimed refrigerant for servicing: supermarket systems, refrigerated transport, and automatic commercial ice makers. [1] Reclaimers, distributors, and wholesalers serving those subsectors report quantities and destinations to EPA, with reports due February 14, 2027 and February 14, 2028.

If you operate in one of those three subsectors, the reclaimed supply chain is about to become your service supply chain. That has a second order effect on the used equipment market that is worth naming: reclaimed refrigerant has to come from somewhere, and decommissioned systems from plant conversions are one of the largest sources. A charge that gets vented or mishandled during a plant teardown is supply removed from a market you will be buying into.

If you run commercial ice equipment, this is a good year to get your recovery and documentation practices in order rather than a good year to improvise.

A seller checklist for a plant decommissioning

Whether you are handling the teardown yourself or working through a dealer, these are the questions that decide whether the package trades cleanly.

• Who recovers the charge, and are they certified? Confirm technician certification and, where reclamation is the path, confirm the reclaimer is EPA certified. Get it in writing before the wrench turns.
• Where is the refrigerant going? Reclamation, destruction, or reuse on site. Each path has different documentation, and the answer determines whether the equipment can be transferred with a charge in it at all.
• What documentation travels with the asset? Batch certification, container labels, quantity recovered per system, and the date. A buyer evaluating a package will discount it if the refrigerant history is undocumented, and they should.
• How is the charge handled at rigging and freight? Equipment that ships dry is simpler to move and simpler to sell. Decide early, because it changes the crating, the paperwork, and sometimes the carrier.
• Is the equipment being sold, reclaimed, or destroyed? These are legally distinct outcomes. Document which one applies to each line item on the asset list rather than treating the plant as one undifferentiated lot.

What this means for buyers

On the buy side, refrigerant documentation is now part of technical due diligence, not paperwork you chase after delivery. Ask for it at the quote stage.

A package that arrives dry, with a certified recovery record showing what was in it and where the charge went, is worth more than an identical package with an undocumented charge and an unclear chain of custody. That difference is real money on a plant sized lot, and it is entirely within the seller’s control.

It also interacts with the equipment rules. The 2026 Technology Transitions rule governs what you can install and by when, and the 15 pound leak repair requirements govern what you have to monitor once it is running. The reclaim rules govern the transfer in between. All three apply to the same asset.

We handle recovery, documentation, and rigging on the packages we buy, and we expect the same standard on the ones we sell. If you are decommissioning a plant, submit your equipment for a valuation or call 201-805-1441. If you are buying, browse current inventory and ask us for the refrigerant history on anything you are evaluating.

About the Author

Michael Rosenberg works with buyers and sellers of surplus and used industrial refrigeration equipment at Refrigeration Equipment Professionals, which has supplied ammonia and freon systems directly to contractors and plants for more than 25 years. His day to day work covers plant decommissioning packages, compressor and chiller sourcing for food processing, cold storage, brewing, and industrial refrigeration operations, and equipment valuations for owners liquidating or upgrading a refrigeration plant. Reach him at 201-805-1441 or through the contact page.

Sources

1. U.S. EPA, Emissions Reduction and Reclamation Program fact sheet on reclaim requirements (January 2026). https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-reclaim-2026-01-13.pdf
2. U.S. EPA, Regulatory Actions for Managing HFC Use and Reuse. https://epa.gov/climate-hfcs-reduction/regulatory-actions-managing-hfc-use-and-reuse
3. Federal Register, Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act of 2020, 91 Fed. Reg. 31284 (May 26, 2026). https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under

Michael Rosenberg

Refrigeration Equipment Professionals (REP) is a trusted supplier of industrial refrigeration systems and surplus/used equipment, offering compressors, chillers, condensers, evaporators, ice machines, freezers, coolers, pumps, motors, complete plants, and services like purchasing, refurbishing, shipping, export crating, and storage/consignment support. With 25+ years of experience and clients across North America, Latin America, the Middle East, and Asia, we deliver reliable, cost-effective refrigeration solutions worldwide.

refrigerationequipment.net