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?
| Rule | Federal Register | What it said for split systems |
|---|---|---|
| Technology Transitions final rule (Oct. 24, 2023) | 88 FR 73098 | Restricted 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 88825 | Extended 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 47999 | Proposed removing the January 1, 2026 installation deadline for that pre-2025 inventory. |
| Final reconsideration rule (May 26, 2026; effective July 27, 2026) | 91 FR 31284 | Removed the installation deadline for systems whose specified components were all manufactured or imported before January 1, 2025. |
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.
| Petitioner | D.C. Cir. case | Filed | Scope stated in the petition |
|---|---|---|---|
| HARDI, PHCC and ACCA | No. 26-1168 | June 24, 2026 | Only cold storage warehouses, retail food remote condensing units and supermarket systems |
| AHRI and the Alliance for Responsible Atmospheric Policy | No. 26-1174 | June 25, 2026 | Only remote condensing units, supermarket systems and the 60-day effective date for those changes |
| Natural Resources Defense Council | No. 26-1188 | July 20, 2026 | The final rule; the petition doesn't limit its scope |
| Massachusetts, 17 other states, the District of Columbia and New York City | Not listed by EPA | July 21, 2026 | The final rule; the petition doesn't limit its scope |
| ALTA Refrigeration and CUSER | No. 26-1202 | July 24, 2026 | Only the cold storage warehouse provision |
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
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
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
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
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
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.
Related
- R-454B PT Chart (Pressure-Temperature)R-454B pressure-temperature chart from −40°F to 150°F with bubble (liquid) and dew (vapor) psig, a quick lookup, °F/°C toggle and how to read glide.
- Superheat and Subcooling, Explained with Worked ExamplesSuperheat and subcooling explained with worked R-454B and R-32 examples: which PT column to use, the formulas, common mistakes and five check questions.
- HVAC Software That Answers the Phone, Books the Tech and Keeps the BooksHVAC software that answers every no-heat and no-cool call, books the tech, follows up on replacement quotes, chases invoices and keeps QuickBooks clean.
- HVAC Answering Service That Triages, Books and Pages Your On-Call TechAn AI answering service for HVAC that triages no-heat and no-cool calls, screens for gas smells and books the job instead of taking a message.
- AC Tonnage CalculatorRough AC tonnage calculator using the square-feet-per-ton rule of thumb, with a Manual J reality check. Ballpark only; size systems with ACCA Manual J.
- What Is a Mechanic's Lien?How a mechanic's lien works for contractors, with notice, filing and enforcement deadlines from six state statutes and a worked example.
- What Is a Lien Waiver?What a lien waiver is, conditional vs. unconditional and progress vs. final waivers, and which states require statutory forms, with sources.
- What Is a Contractor License?What a contractor license is, when you need one, and how six states set dollar thresholds, bonds and insurance, with links to each licensing board.
- What Is a Surety Bond?How contractor surety bonds work: license, bid, performance and payment bonds, state bond amounts, the federal Miller Act, and what a bond costs.
- What Is Workers' Compensation Insurance?When contractors must carry workers' compensation, how employee thresholds differ by state, and how premiums are calculated from payroll and class rates.
Sources
- Federal Register — 91 FR 31284, Technology Transitions reconsideration final rule (May 26, 2026), PDF (checked October 24, 2026)
- Federal Register — 2026-10387, Technology Transitions reconsideration final rule (checked October 24, 2026)
- Federal Register — 88 FR 88825, residential and light commercial AC/HP interim final rule (Dec. 26, 2023) (checked October 24, 2026)
- Federal Register — 90 FR 47999, proposed reconsideration rule (Oct. 3, 2025) (checked October 24, 2026)
- EPA — Regulatory actions, Technology Transitions (checked October 24, 2026)
- EPA — Fact sheet: Technology Transitions reconsideration final rule (May 2026) (checked October 24, 2026)
- EPA — Technology Transitions HFC restrictions by sector (checked October 24, 2026)
- EPA — Frequent questions on the phasedown of HFCs (checked October 24, 2026)
- EPA — Petitions for reconsideration and judicial review under the AIM Act (checked October 24, 2026)
- AHRI and Alliance petition for review, D.C. Cir. No. 26-1174 (checked October 24, 2026)
- HARDI, PHCC and ACCA petition for review, D.C. Cir. No. 26-1168 (checked October 24, 2026)
- NRDC petition for review, D.C. Cir. No. 26-1188 (checked October 24, 2026)
- Commonwealth of Massachusetts et al. petition for review (checked October 24, 2026)
- 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.