The landscape for cold storage refrigeration is undergoing a significant transformation, driven by aggressive new Environmental Protection Agency’s (EPA) refrigerant regulations aimed at reducing the use of high Global Warming Potential (GWP) refrigerants. Under the American Innovation and Manufacturing (AIM) Act, the EPA is phasing down hydrofluorocarbons (HFCs), fundamentally altering equipment choices and maintenance practices for cold storage facilities. 

This regulatory shift is compelling owners, operators and designers to rethink their cold storage refrigeration strategies—moving away from a one-size-fits-all approach to a more nuanced, project‑specific methodology. A key change for new cold storage warehouses is the proposed GWP limit of 150, which took effect on January 1, 2026. This signals a decisive move away from high-GWP synthetic refrigerants and is causing a shift in equipment design, with a trend towards using multiple smaller units rather than large, centralized systems. 

For facilities with existing HFC-based systems, the future is equally complex. While immediate replacement isn’t mandated, maintaining aging closed‑loop systems will become increasingly difficult and costly as refrigerant production ceases and supply dwindles. 

3 Headwinds Redefining Cold Storage Development 

Demand for cold storage remains strong, even as many existing facilities are reaching the end of their useful life. At the same time, three major pressures are reshaping how the industry plans and delivers new projects. 

1. A More Cautious Investment Climate

Investor interest in cold storage remains solid, but deal criteria are changing. Capital is shifting toward: 

• Lower-risk investments 
• Long-term reliable tenants 
• Facilities with resilient infrastructure 

As inflation moves inventory from grocers to producers, the need for reliable storage grows, making secure facilities with solid leases the most competitive assets. Post-pandemic, Refrigerated Public Warehouse demand has softened, and these facilities often don’t meet the specialized needs of many growers and producers.

2. Power Constraints

Power availability has become a critical constraint across every major market, largely due to the booming demand from AI and data centers causing 8-to-16-month delays for utility services, posing a significant risk to project timelines.  

As a result, operators and developers are exploring on-site microgrids and battery storage, offering immediate power, long-term savings and flexible financing options (CapEx or OpEx).

3. Labor Challenges

Cold storage is facing a dual labor crisis: 

• A shortage of technicians with the specialized expertise required to safely operate and maintain complex refrigeration systems 
• Warehouse staff turnover rates reaching up to 150% 

 Together, the shortage of skilled technicians and high workforce turnover in a demanding environment are pushing many operators to invest in automation and consider alternative refrigeration strategies. 

Selecting the Right Cold Storage Refrigerant for Your Facility: Synthetic, Ammonia or CO₂? 

Selecting the right refrigerant is a critical business decision that affects long-term operating expenses, regulatory adherence and environmental responsibility. Below is a high-level comparison of key refrigerant options and their typical applications, recognizing that final decisions should reflect each facility’s unique requirements.  

Synthetics 

Multiple, smaller units are located on the roof or just outside the building, each directly serving a specific zone or piece of equipment inside via shorter pipe runs. 

Cost: $ 

Advantages:

• Human-made chemical refrigerants  
• Developed to be a less toxic, non-flammable and inexpensive alternative 
• Works well for smaller systems  
• Facilities can easily increase their cooling capacity by adding additional units as needed 
• Performs well in temperatures as low as -10°F to -30°F

Considerations: 

• Current options have a high GWP (up to 3,900+) and are being phased down by regulations 
• Regulations will push synthetics towards A2L safety classification which indicates mild flammability 
• Building size is a constraint due to strict regulations limiting the refrigerant charge per unit 
• Lower GWP synthetics are less efficient than current refrigerants resulting in higher electrical loads and larger equipment 

Regulations: 

• Regulated by ASHRAE Standard 34 as well as the EPA  
• Currently, CFC’s are prohibited and HFC’s are regulated with the intent of phasing them out  
• Regulations on GWP’s took effect January 2026 

Equipment & Maintenance: 

• Pure and blended synthetic options are not interchangeable 
• Evolving regulations present maintenance challenges, often prohibiting the replacement of a system’s original synthetic and potentially necessitating a refrigerant or system change 
• Reliance on multiple, smaller units increases both the maintenance workload and the number of potential failure points 

Best when… 

• Used in small- or medium-sized facilities 
• Central plant is not practical 
• You need to serve multiple, smaller or varied temperature zones 
• You need the flexibility to easily add more cooling capacity 
• Lower initial investment and simpler installation are preferred 
• Phased expansion or future growth are key business considerations 

Ammonia 

A “central plant” houses all the large refrigeration equipment, with an extensive network of pipes running along the roof to distribute the refrigerant. 

Cost: $$ 

Advantages:  

• Highly energy-efficient and natural 
• Excellent heat transfer properties 
• Can result in lower operating cost 
• Has been used for over a century 
• Zero Ozone Depletion Potential (ODP) and zero Global Warming Potential (GWP) 
• Performs well in temperatures as low as -80°F to -90°F 

Considerations: 

• Toxic / flammable under certain conditions (Hazardous material) 
• Requires stringent safety protocols 
• Needs specialty trained personnel 
• Risk to food product with exposure 
• Order of magnitude more efficient refrigerant 

Regulations: 

• Hazardous material regulated by the IIAR (International Institute of All-Natural Refrigeration) and IIAR compliance required by International Fire Code and the International Mechanical Code  
• Additional regulation by the EPA and OSHA 

Equipment & maintenance:  

• Equipment is consolidated in one dedicated, climate controlled “room”  
• Equipment is accessible, on ground floor and away from daily operations 
• Simplified safety protocols, such as leak detection, as systems are concentrated in one primary location 
• IIAR requires detailed maintenance/reporting logs over 10,000 lbs. 

Best when… 

• Used in large-sized facilities that can support a central plant 
• It is desired to have maintenance centrally located and accessed at the ground level 
• Where compliance with IIAR requirements and a Process Safety Management (PSM) plan is manageable 

Carbon Dioxide 

Cost: $$$ 

Advantages: 

• Natural, non-flammable and non-toxic 
• Efficient performance at very low temperatures 
• Typically less equipment needed 
• Large amount of heat reclaim that can be reused for other things 
• No product risk if exposed to Carbon Dioxide 
• Performs well in temperatures as low as -50°F to -60°F 

Considerations: 

• Operate at very high pressures, requiring more robust and specialized equipment 
• Large units require reinforced roof structural support  
• Not regulated, and future regulations could impact maintenance/current systems 
• Highly inefficient in warm, humid climates

Regulations: 

• Currently not regulated but it is anticipated that regulations are forthcoming 

Equipment & maintenance: 

• Original installing contractor remains on-site to manage service needs for the first six months 
• Potential to build in redundancy to keep the system running even while individual units are being serviced  
• Units need to be serviced from the roof 

Best when… 

• Used in medium-sized facilities 
• Projects that cannot support a central plant configuration or IIAR safety plan 
• Need to accommodate both medium and very low temperatures 
• Trying to avoid hazardous materials or EPA regulations 

Staying Ahead of New EPA Refrigerant Regulations & the Shifting Landscape

With regulatory pressures increasing, power constraints intensifying, and labor markets tightening, the cold storage industry is entering a new era where success depends on adaptive, data-driven decision-making. Refrigeration strategies must now be tailored not only to compliance requirements but also to workforce realities, investment conditions and infrastructure constraints. 

Owners, operators and developers who take a more project-specific approach will be better equipped to manage what’s ahead and build facilities that perform long term.