The R-410A Condensing Unit Conundrum
EPA is revisiting its rule that components can be manufactured indefinitely for service purposes
There is some confusion in the HVAC industry over whether or not R-410A condensing units can continue to be manufactured after December 31, 2024, in order to service existing systems. As you might recall, the Environmental Protection Agency’s (EPA’s) final rule on Technology Transitions (TT) – published last October and revised in December to allow a longer sell-through period – states that components used to repair legacy refrigeration, air conditioning, and heat pump (RACHP) systems can be manufactured, imported, sold, distributed, or exported indefinitely.
Indeed, EPA emphasized that the final rule should not limit the continued use of any existing products or RACHP systems, adding that allowing existing systems to operate until the end of their useful life is important for ensuring a smooth transition in the phasedown of HFCs.
For the HVAC industry, this means that with existing split-system air conditioners and heat pumps, the EPA would allow the replacement of an outdoor R-410A condensing unit, followed by the indoor coil at a later date. It is important to note that this provision applies exclusively to service situations. Starting January 1, 2026, if both the indoor and outdoor components require replacement at the same time, it would be considered a new system, which must use a refrigerant with a GWP below 700.
The indefinite manufacture of R-410A condensing units raised concerns within the HVACR industry, which feared it would create a service loophole that would allow customers to replace their components forever. So in December 2023, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), the Alliance for Responsible Atmospheric Policy (Alliance), and Heating, Air-conditioning & Refrigeration Distributors International (HARDI) sent a letter to EPA, asking the Agency to reconsider exempting condensing units charged with R-410A from the final rule, stating that it would have adverse consequences for climate protection.
The letter went on to state that “consumers will traditionally replace a condensing unit as a ‘repair’ only when the condensing unit is nearing the end of its useful life (after 10+ years). But under the TT Final Rule, as promulgated, rather than being replaced at end-of-life with new equipment containing refrigerants below the applicable thresholds for GWP, an older unit system could have its condensing unit replaced with a new R-410A condensing unit and remain in operation virtually indefinitely. This frustrates the intent of the TT Final Rule to guide an orderly transition to next-generation refrigerant technologies by allowing the manufacture of R-410A condensing units to continue unchecked.”
In addition, the letter states that this issue, “creates a conflict with the U.S. Department of Energy’s (DOE’s) regulation of split air-conditioning and heat pump equipment, where an outdoor condensing unit and indoor unit are a system and must both meet the minimum energy performance standards.”
In June 2024, EPA responded to the letter, stating that it would reconsider “the rule’s allowance of continued manufacturing and import of single- and three-phase residential and light commercial air conditioning and heat pump condensing units less than 65,000 British thermal units using higher global warming potential refrigerants…and will evaluate whether there is a need to restrict the manufacturing and import of such condensing units.” The letter further stated that EPA “intends to develop a proposed action on this matter” but did not include a timeline for when we can expect to see that action.
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Ultimately, it may not matter, because the DOE has now taken an interest in this issue. As part of its proposed rule on the test procedure for central air conditioners and heat pumps, DOE clarifies that it will only certify R-410A split systems after January 1, 2025, through a procedure known as ‘outdoor unit with no match’ (OUWNM).
“This pathway to certification severely restricts the size of the indoor coil that is permitted to be rated with split-system air conditioners and heat pumps,” said Bud Link, lead senior technical service advisor at Nortek, in a recent article. “The practical outcome of this clarification is that it is extremely likely that most, if not all, manufacturers will cease the manufacturing of R-410A split-system condensing units by January 1, 2025.”
As we wait for EPA and/or DOE to issue their final rules, contractors should prepare accordingly, as the manufacture of R-410A condensing units may come to an end sooner than anticipated.
