Heeding the urgent supply chain concerns raised by HVACR contractors and their customers over the past year, the Environmental Protection Agency on Tuesday proposed a new rule to delay or eliminate many future deadlines under the 2023 Technology Transitions Rule.
Most notably, the proposed rule would eliminate the December 31, 2025 deadline for installation of residential and light commercial R-410A equipment manufactured or imported prior to January 1, 2025. It also proposes delays and other changes to future deadlines impacting the industrial process and commercial refrigeration sectors.
If finalized, this proposal could provide welcome relief. It is sure to face months of regulatory review and legal challenges, however, so contractors should still make every effort to clear their inventory of residential and light commercial R-410A equipment by December 31.
Added urgency to preempt a patchwork of state rules
ACCA appreciates EPA Administrator Lee Zeldin’s urgency in seeking solutions to the shortages that America’s HVACR contractors and their customers have experienced this year. We remain concerned, however, that states will respond to these changes with a worsening patchwork of state refrigerant regulations.
Even without further regulatory action, contractors in New York, California, and elsewhere will now need to keep track of the many new ways in which their states’ regulations differ from the proposed federal rules.
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.
What’s changing?
This proposed rule is part of the broader effort to phase down high global warming potential (GWP) refrigerants under the AIM Act, which President Trump signed in December 2020.
The 2023 Technology Transitions Rule set sector-specific limits on HFC refrigerants and prohibited manufacturing, installing, or importing equipment that used certain higher-GWP refrigerants. It applied to systems like residential AC, heat pumps, and cold storage.
Now, EPA is proposing:
- More flexibility for installing equipment made or imported before January 1, 2025.
- Extended compliance deadlines for some sectors.
- Higher GWP limits for certain applications—like cold storage—starting in 2026.
EPA says these proposed changes are in response to appeals from industry associations seeking relief from cost pressures and supply chain challenges of a rapid transition. Other partners have raised concerns that prolonged use of higher GWP refrigerants could consume available allocations and force a more rapid transition to highly flammable A3 refrigerants.
Why it matters for contractors
With A2L refrigerant training included for all tiers, ACCA members are already ahead of the game in preparing for this transition.
Required comment periods and legal challenges are almost certain to keep this proposed rule in limbo well beyond the December 31 deadline, so contractors should think twice about gambling on a stockpile of R-410A equipment.
If this rollback goes through, however, here’s what it could mean:
- Reduced risk of stranded equipment: Even with a conscious effort to clear R-410A equipment, some stranded inventory is inevitable. This rule could save contractors from having to seek international buyers at fire sale prices.
- More time to adapt: Contractors that serve the commercial refrigeration and industrial process markets will want to carefully examine the proposed changes applicable to their sectors.
- Potential market shifts: Refrigerant availability, system design, and training timelines may change again.
Contractors who were planning for the original rule may have to re-adjust—again. That includes restocking parts, updating technician training, managing customer expectations, and watching for state rules that differ from EPA’s.
What’s next?
EPA will hold a public comment period and a virtual hearing. ACCA is reviewing the proposal closely and will keep members informed. ACCA’s priority will be to avert a patchwork of state regulations by advocating for federal preemption.
In the meantime, we recommend staying in touch with your distributors, watching refrigerant availability, and keeping your team informed. Whether or not the rollback is finalized, the industry will continue to move toward lower-GWP refrigerants and ACCA will be here to fight for your interests every step of the way.
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