Contractors have been racing to clear out R-410A inventory before the December 31, 2025, installation deadline, part of the industry's transition to lower global warming potential (GWP) refrigerants.
Tight timelines, rising costs, and supply delays have made it difficult for HVACR contractors to keep up with new regulations. In response, the EPA has proposed changes that could give contractors more time to install existing R-410A systems and adjust to the next generation of refrigerants.
The proposed rule would remove key federal deadlines and ease restrictions for certain commercial and industrial applications. It could relieve some of the pressure, but the final outcome depends on legal review and how individual states choose to enforce their own refrigerant policies.
What the EPA Is Proposing
The biggest change is eliminating the December 31, 2025 installation deadline for residential and light commercial R-410A equipment that was manufactured or imported before January 1, 2025.
The proposed rule also includes:
- Extended compliance deadlines for some commercial refrigeration and industrial process sectors
- Higher GWP thresholds for certain applications (like cold storage) starting in 2026
- Added flexibility to install already-manufactured systems
These changes are part of the broader AIM Act refrigerant phase-down signed into law in 2020. If finalized, the rule could ease some of the pressure contractors have felt during this transition, especially around stranded inventory.
Relief at the Federal Level, Confusion at the State Level
Even if the federal rollback moves forward, it may not matter in every state. Local rules in places like California and New York could still ban certain refrigerants or enforce their own installation deadlines, making it critical for contractors to track both state and federal policies.
Contractors operating across multiple states may find themselves navigating two sets of rules. This creates logistical and compliance challenges that complicate planning, inventory management, and technician training.
What This Means for Your Business
The proposed rule still needs to clear a public comment period and is likely to face legal challenges. In the meantime, the original December 31 deadline remains in place.
Here’s what to keep in mind:
- Don’t assume the rollback is guaranteed. Clearing out R-410A stock before the deadline is still the safer option.
- Watch the refrigeration sector closely. Cold storage and industrial process contractors should review the proposed GWP threshold changes and timeline shifts.
- State-level enforcement could override federal delays. Even if the EPA backs off, states with stricter rules may still enforce earlier deadlines, leaving you exposed without a compliance plan.
ACCA’s Push for Preemption
The big concern now is consistency. A patchwork of state refrigerant rules could undo any relief the EPA provides, especially for contractors with operations in multiple regions.
That’s why Air Conditioning Contractors of America (ACCA) is pushing hard for federal preemption through the AIM Act. Without it, contractors may be forced to follow different refrigerant rules depending on zip code.
ACCA has welcomed the EPA’s efforts to respond to real-world industry pressure, but the long-term goal is a single, clear national framework that eliminates confusion and compliance risks.
What to Do Next
- Talk with your distributors. They’re your best source for up-to-date availability and deadline clarity.
- Track refrigerant stock carefully. Plan now to avoid excess inventory if the rollback stalls.
- Keep technician training on track. Even with a delay, the move to A2Ls is still coming.
- Watch for updates in your state. Stay alert to rules from state environmental agencies or CARB-like bodies that may diverge from EPA timelines.
The EPA will announce a virtual hearing and open its public comment period soon. For now, continue moving forward on lower-GWP readiness but with one eye on the possibility of shifting federal timelines and state-by-state divergence.
