ACCA submitted comments last week supporting EPA’s proposal to eliminate the January 1, 2026, installation deadline for residential and light commercial R-410A equipment — and urging the agency to extend the same relief to VRF and VRV systems.
Filed on November 21, the comments argue that calendar-based installation cutoffs serve no environmental purpose while stranding legally manufactured equipment and creating unnecessary financial risk for small businesses.
Making the case against installation deadlines
Manufacturing and import limits already regulate the amount of R-410A equipment entering the market. Once those systems are built, an installation deadline doesn’t change the environmental outcome. It just determines whether functional equipment gets installed or wasted.
EPA’s proposal recognizes this. By removing the deadline for residential and light commercial systems, the agency would let contractors work through existing inventory without racing against the calendar.
VRF and VRV systems need the same grace
ACCA’s comments push for extending deadline relief to VRF and VRV equipment, which currently face a January 1, 2027, cutoff for systems manufactured before 2026.
These systems involve:
- Longer project timelines tied to building construction schedules
- Higher capital costs that make stranded inventory especially painful
- Installation dates that depend on factors outside contractor control
Contractors and developers who ordered VRF equipment months or years ago shouldn’t be penalized for following the rules at the time. Treating VRF and VRV systems differently from other light commercial equipment drives inconsistency that serves no real environmental purpose.
Supply chain reality check
The supply shortages contractors experienced this summer showed what happens when regulatory timelines move faster than equipment availability. Installation deadlines force contractors to either dump inventory at fire-sale prices or risk enforcement action, resulting in higher costs and longer delays for consumers.
Removing the deadlines doesn’t expand the volume of R-410A equipment in circulation. It prevents functional systems from being stranded for no reason.
The state regulation problem
ACCA’s comments also raise concerns about the growing patchwork of state regulations. California, New York, and other states are moving ahead with their own refrigerant timelines, some of which would effectively mandate A3 refrigerants ahead of what the market can handle.
The AIM Act was supposed to provide a coordinated national phasedown. Instead, contractors now face incompatible rules across state lines. ACCA continues to advocate for federal preemption to prevent states from undermining the orderly transition Congress intended.
Public comments support deadline removal
EPA is reviewing public comments now. Many of the 70 submissions from contractors, distributors, and manufacturers support removing the installation deadline to minimize the impact of stranded inventory and supply chain disruptions.
The agency is expected to issue a final rule in early 2026. ACCA will continue tracking the rulemaking process and keeping members informed as the agency moves toward a final decision.
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