EPA Removes the January 1, 2026 R-410A Installation Deadline: What Contractors Need to Know

By BRIX Editorial Team · Updated

Yes, you can still install new R-410A split systems, but only if every specified component was made in or imported into the U.S. before January 1, 2025. EPA's final rule published May 26, 2026 (91 FR 31284) removed the January 1, 2026 installation deadline for that inventory, effective July 27, 2026. Equipment made after 2024 is still prohibited.

Key takeaways

  • EPA's final rule (91 FR 31284, May 26, 2026) removed the January 1, 2026 installation deadline for pre-2025 R-410A residential and light commercial AC/heat pump equipment. It took effect July 27, 2026.
  • Equipment manufactured or imported on or after January 1, 2025 with a refrigerant GWP of 700 or more still can't be installed as a new system.
  • Repairing existing R-410A systems, including replacing a condensing unit or compressor, was never banned by this program.
  • Five petitions for review of the 2026 rule are pending in the D.C. Circuit. As of October 24, 2026, EPA lists them as active litigation and we found no order staying the rule.

What changed in 2026?

EPA removed the installation deadline for new residential and light commercial air conditioning and heat pump systems built from inventory made or imported before January 1, 2025. The final rule says such systems "may continue to be installed where all specified components of that system are manufactured or imported prior to January 1, 2025" (amended 40 CFR 84.54(c)(1)).

EPA finalized the rule on May 21, 2026, according to its fact sheet, and published it in the Federal Register on May 26, 2026 at 91 FR 31284. It took effect July 27, 2026. EPA's own summary: it "allows pre-2025 inventory of air conditioning systems to be installed until supply runs out."

EPA gave two reasons in the rule: builders and distributors still held R-410A inventory that would otherwise be stranded, and contractors had trouble getting R-454B in service cylinders in some regions in 2025 to charge new A2L systems.

What did the original 2023 rules say?

Residential and light commercial AC/heat pump rules, 2023 to 2026
RuleFederal RegisterWhat it said for split systems
Technology Transitions final rule (Oct. 24, 2023)88 FR 73098Restricted installation of new residential and light commercial AC/HP systems using refrigerants with a GWP of 700 or more beginning January 1, 2025.
Interim final rule (Dec. 26, 2023)88 FR 88825Extended the installation date by one year, to January 1, 2026, for systems whose components were all manufactured in or imported into the U.S. before January 1, 2025.
Proposed reconsideration (Oct. 3, 2025)90 FR 47999Proposed removing the January 1, 2026 installation deadline for that pre-2025 inventory.
Final reconsideration rule (May 26, 2026; effective July 27, 2026)91 FR 31284Removed the installation deadline for systems whose specified components were all manufactured or imported before January 1, 2025.
Source: the 2026 final rule's summary of the regulatory history (91 FR 31284–31300) and EPA's Technology Transitions regulatory actions page, checked 2026-10-24.

Self-contained products such as window units and portable room air conditioners are handled differently: EPA's sector table lists January 1, 2025 as the manufacture and import date for those products with a GWP of 700 or more, with sale and distribution prohibited three years after that date.

What didn't change?

  • Post-2024 R-410A equipment. The rule says that installing new R-410A systems using equipment manufactured or imported after January 1, 2025 "remains prohibited." EPA called requests to drop the 700 GWP limit out of scope.
  • The 700 GWP limit. New systems built from current production still need a refrigerant under the limit, such as R-454B or R-32.
  • Repairs. EPA's FAQ says you can keep repairing existing systems, including "replacing a major component like a condensing unit or compressor." The 2026 rule didn't change how replacement condensing units are treated.
  • VRF systems. Variable refrigerant flow systems are on a separate schedule. EPA's sector table says new VRF systems above 700 GWP can be installed until January 1, 2027 if all components were made or imported before January 1, 2026.

Is the rule being challenged in court?

Yes. EPA lists five petitions for review of the 2026 rule in the U.S. Court of Appeals for the D.C. Circuit, all marked "Active Litigation" on its petitions page (last updated August 13, 2026). We found no court order staying or vacating the rule as of October 24, 2026.

Petitions for review of the 2026 Technology Transitions reconsideration rule
PetitionerD.C. Cir. caseFiledScope stated in the petition
HARDI, PHCC and ACCANo. 26-1168June 24, 2026Only cold storage warehouses, retail food remote condensing units and supermarket systems
AHRI and the Alliance for Responsible Atmospheric PolicyNo. 26-1174June 25, 2026Only remote condensing units, supermarket systems and the 60-day effective date for those changes
Natural Resources Defense CouncilNo. 26-1188July 20, 2026The final rule; the petition doesn't limit its scope
Massachusetts, 17 other states, the District of Columbia and New York CityNot listed by EPAJuly 21, 2026The final rule; the petition doesn't limit its scope
ALTA Refrigeration and CUSERNo. 26-1202July 24, 2026Only the cold storage warehouse provision
Source: petitions posted on EPA's petitions and judicial review page, read 2026-10-24.

The three industry petitions are limited to commercial refrigeration provisions and don't target the residential R-410A change. The NRDC and state petitions ask the court to review the final rule without naming particular provisions, so the residential change could be argued in those cases. Until a court rules, the July 27, 2026 rule is in effect.

What should HVAC contractors do now?

  1. 1

    Check the manufacture or import date on every component.

    Before installing an R-410A system, confirm the condensing unit, coil and other specified components were made in or imported into the U.S. before January 1, 2025. Keep the date plates, invoices or distributor paperwork in the job file.

  2. 2

    Don't mix in post-2024 R-410A equipment.

    If any specified component was made or imported in 2025 or later, the system can't be installed as new with R-410A. Quote an A2L system instead.

  3. 3

    Check state and local rules.

    The federal rule is the floor. Your state, city or building department may have its own refrigerant or permitting requirements, so confirm before you quote.

  4. 4

    Get your techs ready for A2L installs.

    Equipment from current production has to use a refrigerant under the 700 GWP limit, such as R-454B or R-32. Keep a R-454B PT chart on hand and make sure your crew can verify a charge with superheat and subcooling.

  5. 5

    Tell homeowners what's true.

    Existing R-410A systems can keep running and be repaired. Pre-2025 R-410A units can still be installed while inventory lasts. The legal challenges are pending, so put the date in writing on quotes.

Frequently asked questions

Can you still install R-410A in 2026?

Yes, if every specified component of the system was manufactured in or imported into the U.S. before January 1, 2025. EPA's rule published May 26, 2026 (91 FR 31284) removed the January 1, 2026 deadline for that equipment, effective July 27, 2026.

Is R-410A banned?

No. R-410A itself isn't banned. New residential and light commercial AC and heat pump systems built from equipment made or imported in 2025 or later can't use it, but existing systems can keep running and be repaired, and pre-2025 inventory can still be installed.

Can I replace just the outdoor unit on an existing R-410A system?

EPA's FAQ says repairs to existing systems can include replacing a major component like a condensing unit or compressor. The 2026 rule didn't change how replacement condensing units are treated. Check the unit's paperwork and your state rules before you quote.

When did the R-410A rule change take effect?

July 27, 2026. EPA finalized the rule on May 21, 2026, and it was published in the Federal Register on May 26, 2026. Between January 1 and July 26, 2026, the January 1, 2026 deadline from the 2023 interim final rule was still in the regulations.

Who is suing EPA over the 2026 rule?

EPA lists five petitions in the D.C. Circuit: HARDI/PHCC/ACCA, AHRI and the Alliance, NRDC, Massachusetts with other states, and ALTA Refrigeration with CUSER. The industry petitions target commercial refrigeration provisions; the NRDC and state petitions challenge the rule without naming specific provisions.

Does this apply to VRF systems?

No. VRF systems are on their own schedule. EPA's sector table says new VRF systems above 700 GWP can be installed until January 1, 2027 if all components were manufactured or imported before January 1, 2026.

Sources

  1. Federal Register — 91 FR 31284, Technology Transitions reconsideration final rule (May 26, 2026), PDF (checked October 24, 2026)
  2. Federal Register — 2026-10387, Technology Transitions reconsideration final rule (checked October 24, 2026)
  3. Federal Register — 88 FR 88825, residential and light commercial AC/HP interim final rule (Dec. 26, 2023) (checked October 24, 2026)
  4. Federal Register — 90 FR 47999, proposed reconsideration rule (Oct. 3, 2025) (checked October 24, 2026)
  5. EPA — Regulatory actions, Technology Transitions (checked October 24, 2026)
  6. EPA — Fact sheet: Technology Transitions reconsideration final rule (May 2026) (checked October 24, 2026)
  7. EPA — Technology Transitions HFC restrictions by sector (checked October 24, 2026)
  8. EPA — Frequent questions on the phasedown of HFCs (checked October 24, 2026)
  9. EPA — Petitions for reconsideration and judicial review under the AIM Act (checked October 24, 2026)
  10. AHRI and Alliance petition for review, D.C. Cir. No. 26-1174 (checked October 24, 2026)
  11. HARDI, PHCC and ACCA petition for review, D.C. Cir. No. 26-1168 (checked October 24, 2026)
  12. NRDC petition for review, D.C. Cir. No. 26-1188 (checked October 24, 2026)
  13. Commonwealth of Massachusetts et al. petition for review (checked October 24, 2026)
  14. ALTA Refrigeration and CUSER petition for review, D.C. Cir. No. 26-1202 (checked October 24, 2026)

Change log

  • : Published. Status verified against 91 FR 31284, EPA's Technology Transitions pages and the five petitions for review EPA posts.

Written by BRIX Editorial Team. Published October 24, 2026. Last updated October 24, 2026.

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