On May 21, the Environmental Protection Agency (EPA) issued a final rule on reconsideration of the 2023 Technology Transitions Rule under the AIM Act, which will shape our industry for years to come.
Lifting the installation deadline for residential and light commercial equipment
Most notably, the rule formally lifts the January 1, 2026, prohibition on the installation of residential and light commercial R-410A AC and heat pump equipment manufactured or imported prior to January 1, 2025.
That change was the central recommendation of ACCA’s comments, and the final rule echoes our arguments that the prior rule created unreasonable inventory-management burdens, forced contractors to forecast construction timing with unrealistic precision, and risked unnecessary equipment obsolescence.
EPA explicitly acknowledged that the original deadline created an issue regarding stranded inventory. They also recognized that the supply chain conditions brought about by the A2L transition worsened the problem beyond what was initially anticipated during their original 2023 rulemaking. Further, they note that the rapid market shift toward compliant A2L equipment resulted in larger inventories of legacy R-410A systems than expected.
Installation of such equipment is still technically prohibited until 60 days after publication in the Federal Register (Docket ID No. EPAHQ-OAR-2025-0005), but thanks to the enforcement discretion we won in December, the risk is now extremely low.
Concerns on VRF and commercial refrigeration rules
The most significant changes from October’s proposed rule relate to the commercial refrigeration subsector where EPA heeded concerns raised by supermarket operators, food retailers, and related trade associations in finalizing the following limits:
- a 1,400 GWP interim limit for supermarket systems until 2032,
- a 1,400 GWP interim limit for remote condensing units until 2032,
- and a 700 GWP interim limit for cold storage warehouses until 2032.
These changes represent a major retreat from the original 150/300 GWP framework established in the 2023 rule.
While these changes may be welcome news to some refrigeration contractors and their customers, ACCA is concerned that these changes will significantly increase the demand for the limited supply of HFC refrigerants available under the AIM Act’s phasedown schedule, which is not changed by this rule. That’s anticipated to significantly increase refrigerant prices for all contractors and HARDI estimates $13 billion in added costs for the refrigeration subsector alone. It could also increase pressure for an additional transition to highly-flammable A3 refrigerants.
ACCA also argued that VRF and VRV systems face the same stranded inventory and project-timing risks as other commercial systems, particularly because these projects are highly capital intensive and often tied to large construction timelines extending years into the future.
EPA characterizes the VRF requests as outside the scope of the current rulemaking and points to earlier relief already granted:
- installation deadlines delayed until January 1, 2027 generally,
- and until January 1, 2028 for certain projects with approved building permits before October 5, 2023.
EPA also argues that the number of VRF units affected is materially smaller than the number of conventional residential and light commercial systems.
No relief for New York. Will your state follow suit?
The January 1, 2026, installation deadline remains in effect in New York State, where state regulation Part 494 provides a backstop to changes in the federal rules. New York contractors who still have R-410A equipment will likely take a loss selling it to contractors in other states.
The lack of relief on R-410A equipment is just one of many costly and burdensome deadlines coming under New York’s Part 494. The regulation will drive up prices by banning virgin refrigerant and will prohibit equipment using even the new A2L refrigerants — in 2027 for heat pump water heaters, in 2030 for VRF/VRV systems and chillers, and in 2034 for residential and light commercial heat pumps and AC. Most alternatives run on highly flammable A3 refrigerants like propane and are nowhere near ready for mass adoption in a market as large as New York.
Today’s final rule may spur other states to follow suit. One of ACCA’s top legislative priorities is to minimize disruption from refrigerant transitions by working to preempt state refrigerant regulations. We continue to urge Congress and the Trump Administration to enact federal preemption under the American Innovation and Manufacturing (AIM) Act to fulfill the law’s original promise of an orderly refrigerant transition.
New Yorkers can also seek relief by participating in our ACTion Alert asking New York legislators to support A9596 and S9066 to roll back these rules.
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