The extended R-410A equipment installation deadline is a step closer to being confirmed. The Environmental Protection Agency has formally moved to revise its Technology Transition Rule, submitting the proposed changes to the Office of Management and Budget on April 17 for interagency review. This is the final step before the rule can be finalized and new compliance deadlines officially take effect.
EPA announced in October 2025 that it was reconsidering its Technology Transitions Rule, which included the January 1, 2026, installation deadline for R-410A systems in residential and light commercial applications. The agency’s proposal acknowledged the deadline should be removed; until the rule is finalized, it technically stands.
What should HVAC contractors do in the meantime?
The OMB review process typically takes around 90 days, meaning the final rule could still be several months away. Until it becomes final, installation of R-410A heat pump and AC equipment in residential and light commercial applications is still technically prohibited under current regulations. Contractors may recall that EPA shifted its enforcement priorities in December 2025 when the agency announced that enforcement of the December 31, 2025 R-410A installation deadline was a low priority. EPA granted ACCA’s request to issue a formal statement saying that enforcement of the current deadlines covered by the reconsideration is a low enforcement priority, and that agency resources will instead focus on compliance with new deadlines once the rulemaking is finalized.
Contractors with substantial stockpiles of R-410A equipment will need to assess their own risk tolerance. It is highly unlikely that EPA will proactively take enforcement action at this point, but there is always a risk that courts could force them to do so. The safest course of action would be to hold that equipment until the rule is final.
New York R-410A deadline still in effect ─ and we need your voice
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 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.
ACCA supports federal preemption to prevent states from creating a patchwork of refrigerant regulations. 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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