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EPA Offers Temporary Relief on R-410A Installations
Agency says it will deprioritize enforcement of the installation ban in the Technology Transitions rule
ENFORCEMENT BAN: EPA is temporarily deprioritizing enforcement of the ban on installing some HVAC equipment manufactured before January 1, 2025.
The Environmental Protection Agency (EPA) offered some good news right before the holidays, announcing that it would temporarily deprioritize enforcement of the ban on installing equipment covered by the proposed Technology Transition (TT) rule reconsideration. This includes R-410A residential and light commercial air conditioners and heat pump systems that were manufactured prior to January 1, 2025, as well as commercial refrigeration remote condensing units and cold storage warehouses.
“While the rule itself remains in effect, the statement signals a shift in enforcement focus as EPA continues to consider changes to the regulation,” said Alex Ayers, vice president of government affairs at HARDI, in a blog post. “This is good news for distributors and contractors as they enter 2026, pending the agency’s final rule repealing the installation date.”
However, ACCA pointed out in its blog that EPA did not extend similar relief to R-410A VRF/VRV systems, which, under current regulations, may only be installed through January 1, 2027, provided they were manufactured or imported before January 1, 2026. The blog noted that “ACCA continues to advocate for extended compliance timelines for these systems.”
Earlier this year, EPA proposed revisions to the Technology Transitions (TT) rule under the AIM Act, including removing the installation cutoff for residential and light commercial AC/HP equipment manufactured or imported before 2025. The proposal would also temporarily allow higher GWP limits for cold storage and retail food refrigeration starting in 2026, with stricter limits taking effect in 2032.
In response to the proposed revisions, the HVACR industry submitted more than 2,300 comments to the EPA, with many urging the agency to provide some enforcement flexibility for equipment categories facing January 1, 2026, compliance dates that could change as part of the reconsideration. Commenters argued that because reviewing feedback, completing interagency review, and finalizing the rule would take time, clearer guidance was needed so that manufacturers and distributors would know how existing inventory and pending orders would be treated.
In response to those concerns, EPA noted that it “is aware of the circumstances and equities created by the Agency’s decision to reconsider the 2023 Technology Transitions Rule through the rulemaking process. While EPA intends to extend the compliance dates through this reconsideration, known as the ‘TT Rule Reconsideration,’ the current deadlines remain effective until modified through this rulemaking. Enforcement of the current deadlines subject to the TT Rule Reconsideration is a low enforcement priority for the Agency, and EPA intends to focus its resources on compliance with the new compliance dates that will be established by this rulemaking.”
HARDI has been one of the more vocal advocates addressing distributors’ remaining R-410A inventory, which, under the original TT rule, could not be installed after January 1, 2026. According to Ayers, members estimate potential losses of more than $500 million if the December 31, 2025, installation deadline is not repealed.
EPA expects to issue the final TT rule sometime in early 2026.
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