Technology Transitions Rule 2026: HVACR Contractors Face a Shifting Regulatory Landscape

As the HVACR industry continues its transition toward lower-GWP refrigerants, contractors are navigating a complex mix of federal enforcement discretion, evolving EPA timelines, and growing state-level regulatory pressure. While the Technology Transitions Rule remains a key driver of equipment and refrigerant change, uncertainty around enforcement and compliance has left many businesses wondering what comes next—and how to stay profitable through it. In conversations with ACCA and HARDI, two industry organizations offer practical guidance on the regulatory policy challenges, and why the industry may finally be approaching a “new normal” by mid-2026.

The EPA’s Technology Transitions Rule has been top of mind for HVACR contractors as the industry moves away from higher-GWP refrigerants like R-410A and into the next generation of equipment and compliance requirements. Although the original federal installation deadline was set for Jan. 1, the agency has signaled that enforcement will remain a low priority while the rule undergoes reconsideration—creating both relief and lingering uncertainty for the market.

According to Sean Robertson, vice president of membership, advocacy and events at ACCA, enforcement discretion was a critical step to give contractors breathing room during a complicated regulatory process.

“ACCA fought to secure that enforcement discretion because we know that federal rulemaking processes take time,” Robertson said. He noted that current expectations point toward a final EPA rule arriving sometime in the second quarter of 2026, still several months away.

Robertson added that EPA’s proposal to eliminate the installation deadline for residential and light commercial equipment appeared “surprisingly uncontroversial” during the comment period, making it likely that the change will be included in the final rule.

Alex Ayers, vice president of government affairs at HARDI, echoed that timeline, saying EPA will likely complete the final rule by late Q2 or early Q3.

“The bottom line is just regulations take time,” Ayers said. “This one unfortunately is crossing over past what the enforcement deadline is.”

Enforcement Discretion: Relief, Not a Free Pass

Both Robertson and Ayers emphasized that enforcement discretion does not mean contractors can ignore the law—it simply reflects EPA’s current enforcement priorities.

“The law is still in place,” Ayers cautioned. He compared the situation to informal “right to speed” laws, where enforcement may be relaxed for minor violations, but major oversteps still draw attention.

“The low enforcement priority is there, but if you start going 20 over the speed limit, that’s a much different scenario,” he explained.

Robertson also urged caution, noting that ACCA cannot provide legal advice, but contractors should understand the limits of protection.

“EPA has very limited enforcement resources,” he said, adding that contractors can read EPA’s statements and draw their own conclusions—but should remain careful.

“This is welcome relief, but nobody should be counting on it,” Robertson added.

Key Compliance Focus: Equipment Legally Manufactured Before Jan. 1

One of the clearest contractor risks right now is installing or importing equipment that was not legally manufactured or brought into the U.S. before the Jan. 1 cutoff.

“Contractors do need to make sure that any equipment they install was legally manufactured or imported prior to Jan. 1,” Robertson said.

He warned that attempting to import equipment manufactured after that date would be “a no-go,” and stressed the importance of maintaining accurate documentation.

Ayers reinforced that EPA has long made clear that installation—not distribution—is the primary legal trigger.

“Distributors were very clearly told…selling these components is not illegal. It is the installation,” he said.

That makes contractor recordkeeping and decision-making essential in the months ahead.

The Bigger Threat: State-by-State Refrigerant Rules

While federal enforcement may be temporarily flexible, both leaders warned that the greatest long-term challenge could come from states pursuing their own refrigerant policies.

Contractors, Robertson said, should be “extremely concerned” about diverging state regulations and the lack of federal preemption under the AIM Act.

New York is the clearest example.

“Contractors in New York State should know that this federal relief does not apply to them,” Robertson said. “Installation of R-410A equipment is explicitly banned.”

Ayers agreed, pointing out that New York’s rules go further than EPA’s framework, even covering supermarkets that received extra time under federal policy.

“When you have a state like New York…you absolutely have to follow those state laws,” Ayers said.

Both ACCA and HARDI emphasized the growing risk of a patchwork market, where contractors operating across state lines may face conflicting compliance requirements, inventory complications, and uneven competitive pressure.

“It’s going to be extremely problematic,” Robertson said, especially if competitors circumvent stricter rules by purchasing cheaper refrigerant or equipment across borders.

Supply and Pricing Update: The Refrigerant Shortage Is Over

Contractors also continue to recover from last summer’s widely reported R-454B shortage and price spikes. Ayers offered a clearer outlook heading into 2026.

“We’ve been saying now for several months the shortage is over,” he said.

He explained that while availability has largely stabilized since late summer, pricing remains the final piece of the equation—and even that has leveled off significantly.

“We went from nearly a 400% price spike down to 6% above what they were selling a year ago,” Ayers said. “That’s effectively the same price.”

His practical advice: don’t wait until the first hot day of the season to buy refrigerant.

“That’s kind of like trying to buy chicken wings on Super Bowl Sunday,” he said. “Plan ahead.”

Staying Profitable: Knowledge, Planning, and Normalcy Ahead

When asked what contractors should focus on most during this uncertain period, both leaders returned to the same theme: staying informed.

“Knowledge is power,” Robertson said. “Joining ACCA and your state and local allied contracting organizations is a great way to ensure access to that information.”

Ayers agreed that the industry is shifting away from constant transition and toward steady compliance.

“Change is slowing down. It’s now about compliance,” he said. “Make sure you know how to dot your i’s and cross your t’s.”

Looking forward, Ayers believes contractors may finally see stability return by mid-2026.

“We are moving into a year of more normalcy,” he said. “By getting through these first two quarters we will solidly be in the new normal.”

The Bottom Line for Contractors

While EPA enforcement discretion offers temporary relief, HVACR contractors should not treat the delay as an excuse to pause preparation. The refrigerant transition is still underway, state-level divergence is accelerating, and compliance discipline remains essential for protecting profitability and competitiveness.

From inventory management and documentation to training and advocacy, contractors who stay proactive—not reactive—will be best positioned to succeed as the industry enters its next phase of refrigerant regulation and market stability.