5 Top FAQs from Distributors on the HFC Phasedown Answered

As our industry adapts to the phasedown of hydrofluorocarbons (HFCs) under the AIM Act, the EPA has published some frequently asked questions explaining how the rules affect your business. While manufacturers and contractors are the primary focus, distributors also need to understand how these changes affect their operations.

Here are responses to some of the most relevant questions about the HFC phasedown, along with HARDI’s perspective on what the answers mean for your business.

1. Can I sell residential air conditioner components using R-410A after the January 1, 2026 installation deadline?

Answer: Yes. The Technology Transitions Program allows for the continued sale and distribution of condensing units, indoor coils, indoor air handling units, and other parts that use R-410A so long as they are used to service legacy R-410A systems. Components using R-410A cannot be used to install a new R-410A system beginning January 1, 2026. Specified components (i.e., condensing units, condensers, compressors, evaporator units, and evaporators) manufactured with R-410A after January 1, 2025, must be clearly labeled noting that the component may be used “for servicing existing equipment only.”

HARDI’s Take: There is no requirement to discard existing inventory of R-410A equipment. This protects your inventory investment. However, demand may shift as contractors transition to compliant systems. HARDI encourages proactive inventory planning and clear communication with customers about what can and cannot be installed after the cutoff.

2. How do I know whether the R-410A components I distribute are going to be installed into a new system (not allowed) or to service a legacy system (allowed)?

Answer: Original equipment manufacturers and distributors of components are typically not responsible for the installation of the equipment that they sell. Generally speaking, the responsible party would be the company that installs or directs the installation of the system. This may be different for complex and custom-designed refrigeration, air conditioning, and heat pump systems such as supermarkets and industrial process refrigeration if the distributor or original equipment manufacturer is involved in the design of the system.

HARDI’s Take: Contractors are responsible for ensuring systems are installed in compliance with phasedown deadlines. Distributors are generally not liable unless they direct the installation. Although distributors are protected from liability in most cases, HARDI advises caution in marketing and sales language; avoid anything that could be interpreted as installation guidance. Educating your contractor customers is a smart way to support compliance without assuming risk.

3. Do I need to maintain records or provide reports to EPA about the equipment I sell?

Answer: The recordkeeping and reporting requirements apply to manufacturers and importers of products and the following five components: condensing units, condensers, compressors, evaporator units, and evaporators. Distributors that are not importers do not need to keep records of sales or provide reports to EPA.

HARDI’s Take: The EPA does not require distributors to report HFC transactions. Reporting obligations apply to manufacturers, importers, and reclaimers. Even though reporting isn’t required for distributors, maintaining good records is still smart business. It helps with warranty claims, inventory management, and Department of Energy efficiency compliance. HARDI recommends implementing internal tracking systems to stay ahead of future regulatory shifts.

4. Do I need to label equipment that was manufactured before January 1, 2025, but held in our inventory?

Answer: No. The labeling requirements apply to original equipment manufacturers for components and products that are manufactured or imported after January 1, 2025.

HARDI’s Take: No action is required here, but it’s wise to verify that OEMs are labeling correctly to prevent confusion or returns from contractors who may be unsure about compliance status.

5. Do I need allowances to import products or components containing HFCs?

Answer: No. Allowances are required for the import of bulk HFCs, not products containing HFCs.

HARDI’s Take: This distinction is important for distributors who source finished goods or components internationally. You can continue importing products that contain HFCs without an allowance, as long as you're not importing bulk refrigerant itself. HARDI recommends confirming with suppliers that products are correctly classified and documentation clearly reflects that you're importing finished goods, not bulk HFCs.

Have questions about the HFC Phasedown? HARDI is here to help!

HVACR distributors can continue to navigate the HFC phasedown with confidence, provided they stay informed and proactive. HARDI will monitor regulatory developments and provide resources to help members navigate the transition.

Have more questions or need help interpreting how these rules apply to your business? Reach out to HARDI’s Government Affairs team.