Advocacy
EPA Publishes Final Technology Transition Rule and Frequently Asked Questions
October 24, 2023 | 11 minute read
The Environmental Protection Agency (EPA) published its final technology transition rule in the Federal Register today. This makes the rule fully finalized. The EPA maintained the requirement that split-system air conditioners/heat pumps (AC/HP) have an install deadline of January 1, 2025, and commercial refrigeration utilizing a remote condensing unit have compliance deadlines based on the use of the system (see tables at the bottom of this post for specific compliance dates for both products and systems). To help clarify the rule, the EPA updated its Frequently Asked Questions page, including questions specific to distributors, homeowners, technicians, and manufacturers.
HARDI is hosting a webinar on the final rule on Friday, October 27 at 1pm ET. Register here.
The EPA FAQ page is extensive and a good resource for information; below are questions pulled from EPA’s FAQ page.
What is a “product” in the refrigeration, air conditioning, and heat pump sector?
Generally speaking, a product is a type of appliance with a sealed refrigerant loop that simply needs to be plugged in, mounted, or hooked to a water line, to work. For example, window air conditioning units, residential dehumidifiers, packaged terminal air conditioners, commercial freezers, and vending machines are examples of products. If you need a heating, ventilation, and air conditioning technician to assemble and/or charge with refrigerant, it’s not a product. This follows the same interpretation previously used under the Clean Air Act (e.g., Section 608) and has been used for decades.
What is a system?
A system for purposes of the Technology Transitions Program is an assemblage of separate components constituting the refrigerant loop that typically are connected and charged with refrigerant in the field. Generally speaking, if you need a heating, ventilation, and air conditioning technician to assemble and/or charge with refrigerant, it’s a system.
(Homeowner question): My R-410A unitary air conditioner condensing unit broke. Do I need to buy a whole new system with the lower GWP refrigerant or can I replace the faulty component?
Homeowners can maintain and repair their systems throughout the useful life of the equipment. A homeowner can replace a faulty component (e.g., condensing unit, indoor coil, other smaller parts) with a similar R-410A component. After January 1, 2025, if a whole new system is installed it must use lower GWP refrigerant.
What is a new system?
For residential air conditioner split systems, a new system would be installed in a newly constructed home. A new system would also be installed if both the condensing unit and indoor coil are replaced together. The condensing unit contains the condenser coil and compressor and the indoor coil is the evaporator.
If I leave the existing refrigerant lines but replace the condensing unit and indoor coil, is it a new system?
Yes. Refrigerant lines are generally not removed when replacing the other mechanical components of a system. Therefore, even if refrigerant lines are unchanged, replacing all the other components would result in a new system for purposes of the Technology Transitions Program.
Can I replace the condensing unit and replace the indoor coil at a later time?
Yes. Systems may be repaired over time. Factors for homeowners to consider when deciding to repair or transition to a new system using a lower-GWP refrigerant include availability of components, energy efficiency, and total maintenance costs.
(Distributor Question) Can I sell residential air conditioner units using R-410A after January 1, 2025?
The sale of condensing units, indoor coils, indoor air handling units, and other parts is allowed to service legacy systems.
(Distributor Question) How do I know whether the components I distribute are going to be installed into a new system (not allowed) or to service a legacy system (allowed)?
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.
(Distributor Question) Do I need to label equipment that was manufactured before January 1, 2025, but held in our inventory?
No. The labeling requirements apply to original equipment manufacturers for components and products that are manufactured or imported after January 1, 2025.
(Distributor Question) Do I need to maintain records or provide reports to EPA about the equipment I sell?
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.
(Distributor Question) Do I need allowances to import products or components containing HFCs?
No. Allowances are required for the import of bulk HFCs, not products containing HFCs.
(Distributor Question) Do I need prior authorization from EPA to import products or components containing HFCs?
No.
Compliance deadlines for products and systems
The below tables show the compliance deadline for products and systems. Self-contained equipment will use the products table, and field assembled, including split-system AC, will use the systems table. Note: Any equipment in existence before December 27, 2020, is exempt from these compliance deadlines.
Self-contained Refrigeration, Air Conditioning, and Heat Pumps – Restricted Products by Sector and Subsector Table*
(MVAC, ice cream makers, and Refrigerated Transport Subsectors available at EPA website)
Subsector | System | Global Warming Potential Limit or Prohibited Substances | Installation Compliance Date [5] |
Stationary residential and light commercial air conditioning and heat pumps | Residential and light commercial air conditioning and heat pump systems (e.g., mini-splits, unitary systems) | 700 | January 1, 2026 |
Stationary air conditioning and heat pumps | Variable refrigerant flow systems | 700 | January 1, 2026 |
Chillers | Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) | Not covered | Not covered |
Chillers | Industrial process refrigeration with exiting fluid from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Chillers | Industrial process refrigeration with exiting fluid above -30 °C (-22 °F) | 700 | January 1, 2026 |
Chillers | Comfort cooling | 700 | January 1, 2025 |
Ice rinks | Ice rinks | 700 | January 1, 2025 |
Data centers, computer room air conditioning, and information technology equipment cooling | Data centers, computer room air conditioning, and information technology equipment cooling | 700 | January 1, 2027 |
Industrial process refrigeration (not using chillers) | With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 150 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | High temperature side of cascade systems and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator below -50 °C (-58 °F) | Not covered | Not covered |
Cold storage warehouses | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Cold storage warehouses | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Cold storage warehouses | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - supermarkets | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2027 |
Retail food - supermarkets | With less than 200 lb refrigerant charge | 300 | January 1, 2027 |
Retail food - supermarkets | High temperature side of cascade systems | 300 | January 1, 2027 |
Retail food - remote condensing units | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Retail food - remote condensing units | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Retail food - remote condensing units | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - remote refrigerated food processing and dispensing equipment | Retail food - remote refrigerated food processing and dispensing equipment | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 | January 1, 2027 |
Remote automatic commercial ice machines | Remote automatic commercial ice machines | R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 | January 1, 2027 |
*These tables are for informational purposes only and should not be relied on for compliance purposes. Please refer to 40 CFR Part 82, Subpart B for full details.
[1] Sale, distribution, and export of these products is prohibited three years after the manufacture and import compliance date.
Refrigeration, Air Conditioning, and Heat Pumps – Restricted Systems by Sector and Subsector Table*
(Refrigerated Transport Subsectors available at EPA website)
Subsector | System | Global Warming Potential Limit or Prohibited Substances | Installation Compliance Date [5] |
Stationary residential and light commercial air conditioning and heat pumps | Residential and light commercial air conditioning and heat pump systems (e.g., mini-splits, unitary systems) | 700 | January 1, 2026 |
Stationary air conditioning and heat pumps | Variable refrigerant flow systems | 700 | January 1, 2026 |
Chillers | Industrial process refrigeration with exiting fluid below -50 °C (-58 °F) | Not covered | Not covered |
Chillers | Industrial process refrigeration with exiting fluid from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Chillers | Industrial process refrigeration with exiting fluid above -30 °C (-22 °F) | 700 | January 1, 2026 |
Chillers | Comfort cooling | 700 | January 1, 2025 |
Ice rinks | Ice rinks | 700 | January 1, 2025 |
Data centers, computer room air conditioning, and information technology equipment cooling | Data centers, computer room air conditioning, and information technology equipment cooling | 700 | January 1, 2027 |
Industrial process refrigeration (not using chillers) | With 200 or more lb refrigerant charge excluding high temperature side of cascade system and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 150 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | With less than 200 lb refrigerant charge and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | High temperature side of cascade systems and temperature of the refrigerant entering the evaporator above -30 °C (-22 °F) | 300 | January 1, 2026 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator from -50 °C (-58 °F) to -30 °C (-22 °F) | 700 | January 1, 2028 |
Industrial process refrigeration (not using chillers) | Temperature of the refrigerant entering the evaporator below -50 °C (-58 °F) | Not covered | Not covered |
Cold storage warehouses | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Cold storage warehouses | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Cold storage warehouses | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - supermarkets | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2027 |
Retail food - supermarkets | With less than 200 lb refrigerant charge | 300 | January 1, 2027 |
Retail food - supermarkets | High temperature side of cascade systems | 300 | January 1, 2027 |
Retail food - remote condensing units | With 200 or more lb refrigerant charge, excluding high temperature side of cascade system | 150 | January 1, 2026 |
Retail food - remote condensing units | With less than 200 lb refrigerant charge | 300 | January 1, 2026 |
Retail food - remote condensing units | High temperature side of cascade system | 300 | January 1, 2026 |
Retail food - remote refrigerated food processing and dispensing equipment | Retail food - remote refrigerated food processing and dispensing equipment | R-402A, R-402B, R-404A, R-407A, R-407B, R-407C, R-407F, R-407H, R-408A, R-410A, R-410B, R-411A, R-411B, R-417A, R-417C, R-420A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-426A, R-427A, R-428A, R-434A, R-437A, R-438A, R-507A, HFC-134a, HFC-227ea, R-125/290/134a/600a (55/1/42.5/1.5), RB-276, RS-24 (2002 formulation), RS-44 (2003 formulation), GHG-X5, Freeze 12 | January 1, 2027 |
Remote automatic commercial ice machines | Remote automatic commercial ice machines | R-402A, R-402B, R-404A, R-407B, R-408A, R-410B, R-417A, R-421A, R-421B, R-422A, R-422B, R-422C, R-422D, R-424A, R-428A, R-434A, R-438A, R-507A, R-125/290/134a/600a (55/1/42.5/1.5), RS-44 (2003 formulation), GHG-X5 | January 1, 2027 |
*These tables are for informational purposes only and should not be relied on for compliance purposes. Please refer to 40 CFR Part 82, Subpart B for full details.
[5] EPA is restricting the installation of new field-assembled systems. Components used to repair existing systems are not subject to these restrictions.
HARDI's Congressional Fly-In
May 21-22, 2024
HARDI Members - Join us in Washington, DC where we brief you on policies that matter, arrange meetings with representatives, and you get face-to-face with your representatives to affect policy change.
Alex Ayers
Alex Ayers is the Vice President of Government Affairs for Heating, Air-conditioning, & Refrigeration Distributors International. As a recovering political nerd and current policy wonk, Alex is HARDI’s primary lobbyist and regulatory expert. Growing up in Iowa, Alex was exposed early to local politics through the first in the nation Iowa Caucuses, participating as a county caucus delegate to develop the grassroots planks that go into creating the party platform. Since moving to Washington, DC, Alex has spent over a decade lobbying, publishing papers, and testifying in various policy areas, including taxes, energy, environment, agriculture, and economics. His research has been cited by organizations such as the Wall Street Journal, Forbes, and the Tax Foundation.
Expertise: HVACR Policy, Government Affairs, and Political Advocacy
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