What We’re Watching

June 27, 2025

What We’re Watching is your go-to read for background on all NAFEM advocacy efforts, including energy, environment, regulations, supply chain, and taxes, tariffs and trade. What We’re Watching begins with NAFEM’s Federal Advocacy Tracker, a convenient reference list of pending issues with links to docket numbers (where applicable) and comments.

Should your company wish to communicate with state and federal elected officials on these or other topics, the Advocacy Action Center makes it easy to do so. The Center also includes a convenient state policy map for members to search for proposed regulations and legislation potentially impacting their businesses at the state level.

Federal Advocacy Tracker

	Issue	Docket No./Link	Status/Notes
ENERGY
Automatic Commercial Ice Makers
1	DOE issued a notice of proposed rulemaking to rescind the amended water use standards. The proposal will return the standards to the statutory baseline.	EERE-2017-BT-STD-0022	Comments due July 15.
Commercial Refrigeration Equipment
1	Standards withdrawn under the Congressional Review Act		DOE has one year to issue new standardsNAFEM contacted the agency to determine next steps
Walk-in Coolers/Freezers
1	Standards withdrawn under the Congressional Review Act		DOE has one year to issue new standardsNAFEM contacted the agency to determine next steps
Process Rule
1	DOE issued an RFI for comments on the Process Rule that identifies rulemaking process for energy-conservation standards for commercial equipment	EERE-2025-BT-STD-0001-0001	NAFEM comments Joint industry comments
ENVIRONMENT
1	EPA released drinking water standards for municipal water systems and organizations that provide their own drinking water, April 2024.	Final PFAS National Primary Drinking Water Regulation	On hold pending litigationCalls for 5-year implementation period (2029)
2	EPA final rule restrictions on the use of certain HFCs, establishes a process for submitting technology transitions petitions, and establishes recordkeeping and reporting requirements.	EPA-HQ-OAR-2021-0643-0026	Final rule Oct. 5, 2023Compliance dates vary from Jan. 1, 2025, to Jan. 1, 2028
3	The EPA proposes adding 16 individual PFAS and 15 PFAS categories representing more than 100 individual PFAS, to the Toxics Release Inventory. Doing so would identify the PFAS as chemicals of special concern, subjecting their use to more robust reporting requirements, including reporting even for small concentrations.	EPA-HQ-OPPT-2023-0538	Comment period closed Nov. 7, 2024No information provided since
4	EPA issued an interim final rule delaying the PFAS reporting period under the Toxic Substances Control Act (TSCA). Any company that manufactured (including imported) a PFAS for a commercial purpose from January 2011 – December 2022 will be required to report between April 13 and Oct. 13, 2026.	EPA-HQ-OPPT-2020-0549	Interim final rule issued May 13
5	EPA issues pre-publication final rule for the management of certain HFCs and their substitutes	EPA-HQ-OAR-2022-0606	Comment period closed Dec. 18, 2023No information provided since
6	EPA proposes ban on all TCE use	EPA-OPPT-2020-0642-8026	Comment period closed Dec. 15, 2023No information provided since
7	EPA lists final SNAP 26 approved refrigerants	Final rule	Effective July 15 Fact sheet
REGULATIONS
1	OSHA’s proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings	OSHA-2021-0009	Comments closed Jan. 14, 2025The agency is holding daily virtual hearings through July 2
TAXES, TARIFFS, TRADE
1	Given the constantly changing nature of the tariff situation, NAFEM updates the Taxes, Tariffs and Trade page of nafem.org weekly. We recommend visiting this page for information and consult with your customs broker for up-to-the-minute tariff information relative to your business and its products. Members also can send questions to advocacy@nafem.org.

Other items NAFEM is tracking

ENERGY

California considering efficiency standards for commercial fryers

The California Energy Commission (CEC) v issued a Request for Information (RFI) on potential energy efficiency standards for commercial fryers and to assess their prevalence and performance in the commercial food service industry. Comments were due June 23.

States setting energy-efficiency standards

The following states have energy-efficiency standards in place or pending for a variety of commercial foodservice equipment: California, Colorado, Connecticut, Washington D.C., Maine, Maryland, Massachusetts, Nevada, New Hampshire, New Jersey, New York, Oregon, Rhode Island, Vermont and Washington¹.

Multiple states – Massachusetts, Maryland, New Jersey, New York, Rhode Island – and Washington D.C., require manufacturers of dishwashers, fryers, hot food holding cabinets, ovens and steam cookers and other products to register with the State Appliance Standards Database (SASD). Distributors, retailers and installers must verify that required products are listed with SASD before sale, lease, rental or installation.

California also requires manufacturers to certify the performance of refrigeration products sold in the state via its Modernized Appliance Efficiency Database System (MAEDbS). The two databases do not share information, so manufacturers must register with both databases to sell products in the covered states.

ENERGY STAR^® expands component inspection program

The ENERGY STAR component inspection program expands to electric cooktops in 2025. Check here or contact advocacy@nafem.org for more information. Additionally, while there is speculation of EPA phasing out ENERGY STAR, NAFEM continues to be a proponent of the program.
The current program covers commercial steam cookers; dishwashers; convection, combi and gas-rack ovens; commercial electric cooktops; commercial coffee and tea brewers; fryers; griddles and hot food holding cabinets.

ENVIRONMENT

PFAS reduction efforts active at federal and state levels

PFAS is increasingly the focus of federal and state reduction efforts and outright bans. The Complex Products Manufacturers Coalition (CPMC), of which NAFEM is a member, works at the state, federal and international levels to inform regulations that consider the needs of industry to manage PFAS in a responsible manner. These activities are detailed in NAFEM’s State Policy Map in the Advocacy Action Center.

Canada to require PFAS reporting

Beginning this year, Canada will require manufacturing and other facilities to report the use of PFAS to the National Pollutant Release Inventory to improve understanding of how PFAS are used in Canada, help evaluate possible industrial PFAS contamination, and support efforts to reduce environmental and human exposure to harmful substances.

Canada also is seeking comments on its proposal to add and regulate PFAS as a class under its Environmental Protection Act, rather than treating each substance individually. Additionally, Canada is seeking feedback on its three-phase risk-Management Approach that seeks PFAS alternatives and evaluates social-economic as well as technical considerations. Comments were due May 7, but NAFEM sought and secured an extension until August 5 to respond.

EPA provides HFC phasedown data

EPA updated hydrofluorocarbon (HFC) data – including imports, exports, inventory and destruction, as well as allowance transfers and expenditures – is available on the EPA HFC Data Hub.

Extended producer responsibility (EPR) efforts in states

EPR efforts hold producers responsible for the lifecycle of their products. Multiple states have approved EPR plans, including Maine, Oregon, California, Colorado, Washington, New Jersey and Minnesota thus far primarily aimed at recycling and consumer, single-use plastic and packaging. In Quebec, the Commercial Appliance Recovery Society (SORAC) is an extended producer responsibility program focused primarily on recovery and recycling of refrigeration and freezer equipment. SORAC is funded by manufacturers and others.

California climate disclosure bills could impact members

California is implementing two climate disclosure bills. Impacted companies include those that operate and/or sell in the state and meet other requirements highlighted below:

SB 261, Greenhouse Gases: Climate-Related Financial Risk, applies to public and private companies with annual revenues of $500 million or more that do business in California. Companies are to complete the Task Force on Climate-Related Financial Disclosures and post to their websites before Jan. 1, 2026.
SB 253, Climate Corporate Data Accountability Act, applies to public and private companies with annual revenues of $1 billion or more that do business in California. Companies are to report Scope 1 and 2 emissions in 2026 and Scope 3 emissions in 2027.

Fuels Task Group discusses continued decarbonization efforts

Decarbonization efforts continue at the state, federal and international levels and the industry should anticipate continued discussion and regulatory requirements intended to phase out the use of fossil fuels and natural gas. For example:
- The New York ban on natural gas and other fossil fuels applies to new buildings shorter than seven stories by 2026, and taller buildings by 2029.
- More than 100 U.S. cities have moved to restrict gas-powered appliances. Most of these bans focus on new construction. Members should check local requirements as this is an evolving situation.
- The U.S. Department of Energy (DOE) and California Energy Commission (CEC) are investing in strategic electrification research.

Update on EU/UK F-gases

NAFEM has been notified by the U.K. Foodservice Equipment Association that the U.K. does not have a timeline for implementing changes to its F-gas regulations that differ from the EU F-gas regulations. Manufacturers have been urged to find alternative refrigerants to comply with the EU F-gas regulations in 2026.

Washington State Lead in Cookware Law

Gov. Ferguson signed Washington State SB 5628 which gives manufacturers time to lower the ppm of lead in aluminum and brass cookware before new standards go into effect. Final legislation excludes large appliances, such as refrigerators and ranges, which were in earlier drafts. Thanks to NAFEM member Wood Stone Corp., the Association of Home Appliance Manufacturers (AHAM) and the Cookware Sustainability Alliance (CSA) for joining NAFEM in working with elected officials on this positive outcome.

REGULATIONS

Pay transparency laws proliferating

Effective Jan. 1, employers with 30 or more employees in Minnesota must include a pay range or fixed pay rate in all job posts. Similar laws to reduce gender and racial wage gaps already exist in multiple states.

New efforts addressing potential AI discrimination

Colorado became the first U.S. state to govern artificial intelligence (AI) when Governor Polis signed Senate Bill 24-205. The law takes effect in 2026 and requires those developing and using the technology to ensure that AI-generated hiring, banking and housing decisions avoid “algorithmic discrimination.”
Numerous states have or are considering AI-related restrictions.

California Prop 65 labeling requirements require ongoing monitoring

California’s Proposition 65 – The Safe Drinking Water and Toxic Enforcement Act – requires companies to provide warning labels to notify people of exposure to more than 1,000 chemicals known to cause cancer, birth defects or other reproductive harm. While NAFEM regularly reports on proposed changes, members should closely monitor the Prop 65 changes impacting their businesses.

Prevention of heat-related illnesses and injuries addressed in California, Illinois rules; OSHA considering similar regulations

Members should review California , Illinois and proposed federal regulations aimed at reducing heat-related illnesses and injuries:
- California’s Heat Illness Prevention in Indoor Places of Employment rule went into effect July 23. The law applies to indoor environments when the temperature reaches 82° F. California already has regulations addressing those working in outdoor heat.
- Illinois’ Workplace Extreme Temperature Safety Act (SB2501) mandates that the Director of Labor adopt rules for excessive heat and cold standards, with a requirement to establish an occupational temperature-related illness and injury prevention plan by January 1, 2026 https://ilga.gov/ftp/legislation/104/SB/10400SB2501.htm
- See the Federal Advocacy Tracker above for updates on the Occupational Safety and Health Administration’s (OSHA) Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings proposed rule. Comments were due Jan. 14 and virtual public hearings on the proposed rule are taking place through July 2.

SUPPLY CHAIN

Investigation underway on transit “choke points”

The Federal Maritime Commission (FMC) launched an investigation into transit constraints that may be creating unfavorable shipping conditions for U.S. foreign trade. “Choke points” being studied are the Suez Canal, Panama Canal, English Channel, Malacca Strait, Singapore Strait, Northern Sea Passage and Strait of Gibraltar. FMC is looking into laws, regulations and practices of foreign governments or the practices of foreign-flag vessels owners or operators.

Know your supply chain: Restricted entities listed on government database

The International Trade Administration (ITA) maintains the Consolidated Screening List (CSL) of parties with which the U.S. restricts certain exports, reexports or transfers of items, including those addressed under the Uyghur (China) Forced Labor Prevention Act (UFLPA), Russia/Belarus sanctions and others. ITA updates the list daily, and email updates are available at the link above.

TAXES, TARIFFS & TRADE

Tariff updates available at nafem.org

Given the constantly changing nature of the tariff situation, NAFEM updates the Taxes, Tariffs and Trade page of nafem.org weekly. We recommend visiting this page for information and consult with your customs broker for up-to-the-minute tariff information relative to your business and its products. Members also can send questions to advocacy@nafem.org.

Tax reform a top NAFEM priority

If Congress fails to pass legislation to extend or make permanent the tax reform provisions from the 2017 Tax Cuts and Jobs Act, it will result in the largest tax increase in U.S. history. The NAFEM Advocacy Action Center makes it easy to join NAFEM in reaching out to elected officials to relay how important these provisions are to your business, competitiveness and the overall U.S. economy, particularly with the uncertainty due to tariffs.

Commerce investigating security of semiconductors and related products

The U.S. Department of Commerce report on its Section 232 investigation of the security risks of imports of semiconductors, semiconductor manufacturing equipment and their derivative products is due to President Trump Dec. 27, although the administration has stated its intent to move at a faster pace.
Findings are due Nov. 22 for a Section 232 investigation to assess U.S. national security risks arising from the country’s increasing dependence on imported smelted and refined copper.
Findings are due Nov. 26 for a similar Section 232 investigation underway for imports of timber, lumber and their derivative products. According to the White House, “..the current United States softwood lumber industry has the practical production capacity to supply 95% of the United States’ 2024 softwood consumption. Yet, since 2016 the United States has been a net importer of lumber.”