As part of its reconsideration of the Technology Transitions Rule, EPA is proposing to eliminate the January 1, 2026, installation deadline for residential and light commercial R-410A systems. The proposal addresses concerns for these sectors but leaves variable refrigerant flow and volume (VRF/V) systems behind, which would still face a hard deadline of January 1, 2027. ACCA is urging EPA to extend the same policy to VRF/V equipment.
What EPA is proposing
The proposal would eliminate the installation deadline entirely for residential and light commercial systems. Any R-410A equipment manufactured or imported before January 1, 2025, could be installed at any time, removing the calendar-based restriction that threatened to strand functional equipment.
This change responds to supply chain disruptions experienced throughout 2025. Spring and summer months saw significant R-454B shortages, price spikes, and stockpiling. Removing the installation deadline gives the market breathing room without forcing contractors and consumers to discard functional equipment.
The VRF/V problem ─ and why it matters
VRF systems manufactured or imported before January 1, 2026, currently have until January 1, 2027, to be installed. Unlike residential equipment, this deadline would remain under EPA’s proposal.
Yet VRF equipment faces the same challenges: complex, multi-component systems with extended construction timelines and risk of stranded inventory.
Removing arbitrary installation deadlines across all equipment sectors offers important benefits:
- Prevents functioning systems from being discarded at fire-sale prices
- Lets contractors manage inventory based on actual supply and demand
- Maintains customer access to proven, affordable technology
- Reduces business uncertainty around equipment purchases
The refrigerant transition is happening — manufacturers have shifted to A2L refrigerants, and the industry continues moving toward lower-GWP alternatives. EPA’s proposal already recognizes that the current installation deadlines just create unnecessary disruption.
ACCA’s position and how you can help
ACCA supports removing the R-410A installation deadline for residential and light commercial equipment. We also believe the same policy should extend to VRF/V systems.
This proposal aligns with one of ACCA’s top legislative priorities: minimizing disruption from refrigerant transitions. Preventing stranded inventory and ensuring federal consistency are key steps toward that goal.
The public comment period ends November 21. Take action today through ACCA’s Action Alert to let EPA know you support removing the installation deadline and extending this policy to VRF/V equipment.
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