Update on the EPA Technology Transitions Program Related to the HFC Refrigerant Phasedown

Changes are afoot that impact critical deadlines from The Environmental Protections Agency’s (EPA) Technology Transition Program (TTP). On Oct. 24, 2023, the EPA published a final rule restricting the use of high GWP (global warming potential) HFC refrigerants in air conditioning and heat pump products and equipment. These regulations, referred to as the Technology Transitions Program, support the HFC phasedown by forcing a transition to next-generation equipment that does not utilize HFC refrigerants.

The original program placed restrictions on both the manufacture and installation of HVAC products and systems. The EPA later issued an interim final rule, in December 2023, that amended one provision of the regulations that impacted the compliance date for the installation of HVAC systems.

Current EPA Regulations

In 2023, the EPA established new regulations for residential and light commercial air conditioning and heat pump systems that prohibited the manufacture of HVAC system components to be used in a new HVAC system on or after Jan. 1, 2025. It also prohibited the installation of new HVAC systems with GWPs >700 on or after Jan. 1, 2026. These regulations are now in effect across the U.S.

Impacts on the HVAC Industry

Manufacturers, distributors and dealers planned extensively to comply with the EPA manufacturing deadline; however, there have been some areas of the country where the supply chain has not been able to keep up with the demand for the new equipment and/or the refrigerant it uses. This, in turn, has impacted the ability to comply with the installation deadline of Jan. 1, 2026. As the deadline approached, HVAC projects scheduled for completion in the early months of 2026, that were designed around the new equipment regulations, were burdened with the prospect of long construction delays as a result of supply chain issues, or utilizing systems with GWPs above 700 and trying to beat the installation deadline. Many were left in a state of limbo trying to find a solution compliant with the EPA regulations.  

The EPA’s Proposed Solution

On Sept. 30, 2025, the EPA issued a proposed rule reconsidering some of the regulations enacted under the Technology Transitions Program. Of particular interest is the Jan. 1, 2026, effective date for the installation of residential and light commercial systems. For this market segment, the EPA has proposed removing the installation compliance date for HVAC systems that are made up of equipment that was manufactured before Jan. 1, 2025.

As such, under these proposed rules, HVAC systems that utilize refrigerants with GWPs above 700 would still be permitted, until a time when the current inventory of the pre-2025 equipment runs out.

Status of Regulatory Changes

At this time, this proposed rule has not yet been finalized. While the EPA intends to eliminate the Jan. 1, 2026, installation date requirement, technically the current deadlines remain in effect. The EPA has stated on its website, however, that enforcement is a low priority for the agency, and it intends to use its resources on compliance issues following the dates established by the proposed rulemaking.

Note, however, that the EPA may still take any action necessary, based on the original compliance dates, to protect human health and the environment. These actions are consistent with guidance from the EPA Office of Enforcement and Compliance Assurance included in a March 12, 2025 memo titled "Implementing National Enforcement and Compliance Initiatives Consistently with Executive Orders and Agency Priorities.”

Considerations for Contractors and Technicians

Due to the position the EPA has taken on enforcement, there is little risk at the federal level for contractors and technicians regarding the Jan. 1, 2026, installation date being enforced. However, there may be some other areas for concern:

• Some states may have local rules or regulations in place that may be enforced at the local level. Be sure to know all federal, state, and local regulations that may be applicable.
• The changes in the proposed rule only apply to new systems that are made up of equipment that was manufactured prior to Jan. 1, 2025. Be sure to confirm this date on the equipment rating plate – this could be a source of confusion because manufacturers can still manufacture equipment that is intended for replacement of components in existing systems.
• In no case can a new system be installed using equipment (i.e. condensing units) that was manufactured on or after Jan. 1, 2025.

Other Market Segments Impacted

The residential and light commercial HVAC market segment is one of several that are addressed in the 2025 proposed rulemaking. Other market segments include: 

• Retail food – supermarkets;
• Retail food – remote condensing units;
• Cold storage warehouses;
• Industrial process refrigeration and chillers used for semiconductor manufacturing; and 
• Industrial process refrigeration for centrifuges and laboratory shakers

If your business takes you into one or more of these other market segments, you should visit the websites referenced below for detailed information specific to those markets.