Advocacy Tracker

June 18, 2026

Advocacy Tracker provides background on all NAFEM advocacy efforts addressing energy, environment, regulations, supply chain, taxes, tariffs and trade.

Visit NAFEM’s Advocacy Action Center to communicate with state and federal elected officials on these or other topics. The Center also offers a state policy map where members can search for proposed regulations and legislation potentially impacting their businesses. 

For urgent or timely information, join NAFEM’s Facebook Community Group and visit our LinkedIn page. 

Energy
 Issue Docket No./Link Status/Notes 
NAFEM and the Air-Conditioning, Heating and Refrigeration Institute (AHRI) are continuing to work jointly on potential energy conservation standards for commercial refrigeration equipment and walk-in coolers / freezers. These proposals set the stage for additional discussions with Department of Energy (DOE) officials on the next round of standards. Members interested in participating should contact advocacy@nafem.org.   
Other energy-related items

State energy-efficiency standards 

  • The California Energy Commission (CEC) is still in the pre-rulemaking phase of considering energy- and water-efficiency standards for commercial dishwashers. CEC is interested in industry concerns and recommendations. Submit comments via the link above or directly to Alejandro Galdamez in the Appliances Office Efficiency Division.  
  • The CEC requires manufacturers to certify the performance of refrigeration products sold in California via its Modernized Appliance Efficiency Database System (MAEDbS). Manufacturers must submit data directly to CEC’s database from a CEC-recognized testing lab or submit a form for each product category that authorizes the testing lab as their representative for submitting appliance data. UL Solutions 
  • The following states, plus Washington, D.C., have energy-efficiency standards for a variety of commercial foodservice equipment: California, Colorado, Connecticut, 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. 
  • SASD and MAEDbS do not share information, so manufacturers must register with both databases to sell products in the covered states. 

ENERGY STAR® activities delayed during transition  

  • NAFEM continues monitoring for updated news from ENERGY STAR following the program’s transfer from the U.S. Environmental Protection Agency (EPA) to the DOE. Also, ENERGY STAR reports delays in posting the shipment data forms for calendar year 2025. Monitor energystar.gov/unit-shipment-data for updates. 
  • 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. 

Lithium-ion battery use resources  

  • As more operators use lithium-ion batteries to shave peak demand or maintain consistent power during brownouts and outages, NAFEM’s Fuels (F) Task Group continues to evaluate the trend. The Task Group recommends a National Fire Protection Association (NFPA) podcast on the proper use and handling of the batteries in commercial and residential applications. Battery Council International (BCI) also has useful online information about lithium-ion batteries. 
Environment
  IssueDocket No./LinkStatus/Notes
1
Revisions to the 2023 Technology Transitions Rule extended compliance deadlines for the use of certain hydrofluorocarbons (HFCs) and made a wider variety of refrigerants available. 		– Final: EPA-HQ-OAR-2025-0005 
– Fact sheet 		-Final rule May 21 
-Compliance dates vary from Jan. 1, 2027 to Jan. 1, 2032 
2EPA issued an interim final rule delaying the PFAS reporting period under the Toxic Substances Control Act (TSCA). Any company that manufactured (including imported) PFAS for a commercial purpose from Jan. 2011 – Dec. 2022 are required to report.EPA-HQ-OPPT-2020-0549– Interim final rule issued May 13, 2025.
– Submissions are due October 13. Certain small businesses importing PFAS only in articles have until April 13, 2027.
2Substitute refrigerants acceptable in refrigeration systems are listed in the proposed Significant New Alternative Program (SNAP) Rule 27.– EPA-HQ-OAR-2024-0503
– Fact sheet		– Comment period closed Dec. 26, 2025.
4EPA proposes amending the procedural framework rule for conducting existing chemical risk evaluations under the Toxic Substances Control Act (TSCA).– EPA-HQ-OPPT-2025-0260– Comment period closed Nov. 7, 2025.
Other environment-related items

Products and equipment using HFCs and HFC blends must be labeled 

  • Refrigeration and other equipment that uses HFCs and HFC blends must meet EPA AIM Act labeling requirements for each subsector. Jan. 1, 2026 was the effective date for chillers and industrial process refrigeration equipment; and Jan. 1, 2027 is the effective date for ice machines and refrigerated food processing and dispensing equipment. The EPA provides a detailed fact sheet with labeling examples.

California environmental impact reporting deadline approaching 

  • The California Air Resources Board (CARB) issued modified language and additional information for proposed amendments to the cap on greenhouse gas emissions and market-based compliance. Comments were due April 29. SB 253 requires US companies with total annual revenues in excess of $1 billion that do business in California to annually disclose their Scope 1, 2 (by Aug. 10, 2026) and Scope 3 (in 2027) GHG emissions for the prior fiscal year. Legal challenges are ongoing, but the reporting deadlines have not changed.  
  • Companion legislation – SB 261 – requires large companies (>$500M revenue) doing business in California to disclose climate-related financial risks every two years. The Climate-Related Financial Risk Act is currently paused due to litigation. 
Regulations
Federal regulation-related items
  IssueDocket No./LinkStatus/Notes
1OSHA’s proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.– OSHA-2021-0009
– Transcripts of June/July virtual hearings are available online 		– Post-hearing comment period closed Sept. 30, 2025.
2The Heat Workforce Standards Act of 2026 was introduced in the Senate as a preferred alternative to the above proposed Rule.
– S 4427
– HR 6213		– NAFEM letter of support for S 4427
– NAFEM letter of support for HR 6213

Global Market Access Requirements

Participating in international markets is essential to remaining competitive, but entry is more complicated than ever with safety, sanitation, sustainability, cybersecurity and other requirements. Stay current with NAFEM’s Global Market Access and Conformity Guide.

Other Regulatory-related items

Administration releases national AI policy framework; states considering regulations

  • The administration’s National Policy Framework for Artificial Intelligence outlines policy considerations for lawmakers developing a national AI framework. Recommendations include removing barriers to innovation, protecting content creators, prioritizing children’s online safety and shielding communities from increased electricity costs. The U.S. Chamber of Commerce supports a national framework to “prevent a 50-state patchwork and provide clarity to entrepreneurs and businesses of all sizes.”
  • Also on the AI front, numerous states have or are considering AI-related restrictions, that generally prohibit “AI-generated algorithmic discrimination” in hiring, promotions and other decisions. NAFEM encourages members to closely monitor these requirements to ensure compliance.

PFAS updates 

  • Before concluding the spring session, Illinois legislators advanced HB 2955 to the Senate Environment and Conservation Committee and referred the bill to the Senate Assignments Committee. The bill would hold PFAS manufacturers (not defined) fully responsible for the costs of monitoring, containing and eliminating PFAS from wastewater systems, including any expenses tied to future state and federal regulatory requirements. It also would create a committee to calculate these costs and develop a framework for passing them directly to manufacturers. 
  • Minnesota Governor Walz’s signed SF 4612, which exempts manufacturers from PFAS reporting requirements on products manufactured before July 1, 2023.  
  • May 25 was the deadline to submit comments on the European Chemicals Agency’s (ECHA) draft opinion regarding the PFAS Restriction Proposal. The Complex Products Manufacturers Coalition, of which NAFEM is a member, will continue to monitor the results and share updates.  
  • The regularly updated Complex Products Manufacturers Coalition spreadsheet includes current and proposed state and federal regulations addressing PFAS.  

California Prop 65 labeling requirements require regular 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. Members should review Prop 65 requirements to determine how the law affects their businesses.  
Taxes, Tariffs & Trade

Find the latest tariff information, including that below, on the Taxes, Tariffs and Trade page of nafem.org. While NAFEM regularly updates this resource page, we recommend regular communication with your customs broker for the most current tariff information relative to your business and its products.  

  IssueDocket No./LinkStatus/Notes
1The U. S. Trade Representative (USTR) completed its Section 301 investigation and determined that certain Brazilian policies and practices unfairly burden or restrict U.S. commerce.-USTR is proposing potential actions, including tariffs on Brazilian imports – Comments due July 1
– Public hearing July 6
2The USTR opened a Section 301 investigation into Vietnam’s intellectual property protection and enforcement. USTR-2026-0364 
Comments due July 2 
3The USTR concluded its Section 301 unfair trade practices investigations into the use of forced labor by 60 countries. Based on the findings, USTR proposes tariffs of 10-12.5% on imports from all countries.  Report – Comments due July 6 
– Public hearing July 7 
4The Securities and Exchange Commission (SEC) proposed reducing corporate filer classifications from five to two: large, accelerated filers and nonaccelerated filers with a public float below $2 billion.  Fact sheet – Comments are due July 27 
5The U. S. Trade Representative (USTR) opened a Section 301 investigation into excess industrial capacity in manufacturing sectors that could give foreign companies an unfair advantage or restrict U.S. commerce. 
 
Countries include China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan and India. 		USTR-2026-0067 and USTR-2026-0068  – Comment period closed April 15 
– Public hearing May 5 
6The U.S. International Trade Commission (ITC) is investigating revoking permanent normal trade relations (PNTR) treatment for all Chinese imports. The review will assess how higher tariffs would affect U.S. trade flows, domestic production and prices in the most directly impacted industries. The ITC also is evaluating an alternative approach that would revoke PNTR only for a defined set of national security-related products from China, with tariffs phased in over five years. 332-609 – Comment period closed April 15 
– No public hearing scheduled 
7The U.S. Secretary of Commerce initiated a Section 232 investigation under the Trade Expansion Act to assess whether imports of robotics and industrial machinery, and parts/components, pose a risk to national security.  250924-0161 – Comment period closed Oct. 17, 2025 
– Report due March 2026 
8The USMCA is up for the mandatory six-year review in 2026. If any country objects to an extension, it triggers an annual approval process and a countdown to the USMCA’s end in 2036. Bilateral talks began in March.USTR-2025-0004 and USTR-2025-0005 – Comment period closed Nov. 3, 2025 
– Public hearing held Nov. 17, 2025 
– NAFEM letter of support 
Other Taxes, Trade & Tariff-related items

10% surcharge under scrutiny

  • The Court of International Trade issued a permanent injunction against the 10% Section 122 tariffs. However, it only applies to the plaintiffs; the government can continue to collect 10% tariffs from non-plaintiff importers. NAFEM is watching to see if the Court requires Customs and Border Protection to apply the ruling more broadly, as it did for the IEEPA tariffs. The administration is expected to appeal.
  • For those still impacted, the White House announcement includes exceptions “because of the needs of the U.S. economy” in Annexes I and II.

EEPA Refund Process Begins 

  • The first phase of the IEEPA tariff refunds claim portal opened to process certain unliquidated entries and entries within 80 days of liquidation. Payments are expected within 45-90 days. CBP also posted an overview and FAQs.

OTHER TOPICS?

If there is a topic you would like NAFEM to address, please contact us at advocacy@nafem.org.