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

> **Status as of 2026-10-24:** Since July 27, 2026, federal rules allow new residential and light commercial AC and heat pump systems using R-410A to be installed with no deadline if all specified components were manufactured in or imported into the U.S. before January 1, 2025; court challenges to the rule are pending, and no court has stayed it.

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](https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under). 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**

| 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](https://www.federalregister.gov/documents/2023/12/26/2023-28500/phasedown-of-hydrofluorocarbons-technology-transitions-program-residential-and-light-commercial-air) | 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](https://www.federalregister.gov/documents/2025/10/03/2025-19438/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under) | 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](https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under) | Removed 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**

| 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 |

_Source: petitions posted on EPA's [petitions and judicial review page](https://www.epa.gov/hfcs/petitions-reconsideration-and-judicial-review-under-aim-act), 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. **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](https://www.brix.so/reference/refrigerant-pt-chart/r-454b) on hand and make sure your crew can verify a charge with [superheat and subcooling](https://www.brix.so/academy/hvac/refrigeration/superheat-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.

> **Watch for outdated advice**
>
> Many articles from 2025 say installing R-410A systems is illegal after January 1, 2026. That was the rule until July 27, 2026, and it no longer applies to pre-2025 inventory. Some EPA pages updated before the 2026 rule may also still show the old date; the Federal Register text controls.

When homeowners call asking whether their R-410A system is "illegal" now, BRIX can answer the phone, book the visit and text the customer back, so you can give them the real answer in person.

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## 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)](https://www.brix.so/reference/refrigerant-pt-chart/r-454b)
- [Superheat and Subcooling, Explained with Worked Examples](https://www.brix.so/academy/hvac/refrigeration/superheat-subcooling)
- [HVAC Software That Answers the Phone, Books the Tech and Keeps the Books](https://www.brix.so/for/hvac)
- [HVAC Answering Service That Triages, Books and Pages Your On-Call Tech](https://www.brix.so/for/hvac/ai-receptionist)
- [AC Tonnage Calculator](https://www.brix.so/tools/hvac-tonnage-calculator)
- [What Is a Mechanic's Lien?](https://www.brix.so/learn/mechanics-lien)
- [What Is a Lien Waiver?](https://www.brix.so/learn/lien-waiver)
- [What Is a Contractor License?](https://www.brix.so/learn/contractor-license)
- [What Is a Surety Bond?](https://www.brix.so/learn/surety-bond)
- [What Is Workers' Compensation Insurance?](https://www.brix.so/learn/workers-compensation)

## Change log

- 2026-10-24: Published. Status verified against 91 FR 31284, EPA's Technology Transitions pages and the five petitions for review EPA posts.

## Sources

- [Federal Register — 91 FR 31284, Technology Transitions reconsideration final rule (May 26, 2026), PDF](https://www.govinfo.gov/content/pkg/FR-2026-05-26/pdf/2026-10387.pdf) (checked 2026-10-24)
- [Federal Register — 2026-10387, Technology Transitions reconsideration final rule](https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under) (checked 2026-10-24)
- [Federal Register — 88 FR 88825, residential and light commercial AC/HP interim final rule (Dec. 26, 2023)](https://www.federalregister.gov/documents/2023/12/26/2023-28500/phasedown-of-hydrofluorocarbons-technology-transitions-program-residential-and-light-commercial-air) (checked 2026-10-24)
- [Federal Register — 90 FR 47999, proposed reconsideration rule (Oct. 3, 2025)](https://www.federalregister.gov/documents/2025/10/03/2025-19438/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under) (checked 2026-10-24)
- [EPA — Regulatory actions, Technology Transitions](https://www.epa.gov/climate-hfcs-reduction/regulatory-actions-technology-transitions) (checked 2026-10-24)
- [EPA — Fact sheet: Technology Transitions reconsideration final rule (May 2026)](https://www.epa.gov/system/files/documents/2026-05/fact-sheet-san-12166-technology-transitions-frm.pdf) (checked 2026-10-24)
- [EPA — Technology Transitions HFC restrictions by sector](https://www.epa.gov/hfcs/technology-transitions-hfc-restrictions-sector) (checked 2026-10-24)
- [EPA — Frequent questions on the phasedown of HFCs](https://www.epa.gov/hfcs/frequent-questions-phasedown-hydrofluorocarbons) (checked 2026-10-24)
- [EPA — Petitions for reconsideration and judicial review under the AIM Act](https://www.epa.gov/hfcs/petitions-reconsideration-and-judicial-review-under-aim-act) (checked 2026-10-24)
- [AHRI and Alliance petition for review, D.C. Cir. No. 26-1174](https://www.epa.gov/system/files/documents/2026-08/alliance-ahri-petition-for-review.pdf) (checked 2026-10-24)
- [HARDI, PHCC and ACCA petition for review, D.C. Cir. No. 26-1168](https://www.epa.gov/system/files/documents/2026-08/hardi-acca-phcc-petition-for-review.pdf) (checked 2026-10-24)
- [NRDC petition for review, D.C. Cir. No. 26-1188](https://www.epa.gov/system/files/documents/2026-08/nrdc-petition-for-review.pdf) (checked 2026-10-24)
- [Commonwealth of Massachusetts et al. petition for review](https://www.epa.gov/system/files/documents/2026-08/commonwealth-of-massachusetts-et-al-petition-for-review.pdf) (checked 2026-10-24)
- [ALTA Refrigeration and CUSER petition for review, D.C. Cir. No. 26-1202](https://www.epa.gov/system/files/documents/2026-08/alta-cuser-petition-for-review.pdf) (checked 2026-10-24)

Talk to BRIX: call or text (518) 588-1122, email eeharris2004@gmail.com, or book a 15-minute call at https://cal.com/ethanharris/15min.

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Written by BRIX Editorial Team. Last updated 2026-10-24. General information, not tax, legal or financial advice.
Canonical: https://www.brix.so/news/epa-r-410a-installation-deadline-change