EPA Signals Intent for Relief on Some Install Dates

Update (12/28): Check out HARDI's latest update on the EPA's ruling in the article here.

The Environmental Protection Agency has signaled it plans to provide relief on the upcoming system installation ban of residential and light commercial air conditioning and heat pump and VRF/VRV systems using high-GWP refrigerants like R-410a. The EPA has signaled this intent in letters to HARDI, AHRI, and the Alliance for Responsible Atmospheric Policy and in the frequently asked questions section of the technology transitions page on the EPA website. From the EPA website:

Does EPA intend to make changes to the ban on installing new residential heat pump and air conditioning systems using refrigerants with GWPs higher than 700 as of January 1, 2025, and variable refrigerant flow (VRF) systems using refrigerants with GWPs higher than 700 as of January 1, 2026?

EPA understands that for new residential construction, including both single-family and multi-family dwellings, where builders order heating and cooling equipment well in advance of knowing the exact date of install, the imminent compliance date has raised concerns about system components that may already be in the distribution chain. EPA intends to act swiftly to address concerns regarding the January 1, 2025, installation compliance date for residential heat pump and air conditioning systems including by potentially amending the final regulation to allow for installation of previously manufactured components until January 1, 2026. Separately, EPA intends timely consideration of industry concerns related to VRF systems.

HARDI views the letter and the public FAQ as strong indications that the EPA will change the compliance deadline for the installation of residential and light commercial air conditioning and heat pump systems. This should dramatically reduce the concerns of stranded inventory caused by the January 1, 2025, installation date.

Distributors and contractors will still be able to use remaining in-stock equipment to repair existing systems after the compliance deadline as long as it meets DOE match system requirements. HARDI strongly encourages distributors to treat this potential change as an opportunity to reduce or eliminate any remaining inventory using high-GWP refrigerants after the 2024 cooling season. A delay in the system installation deadline is not an opportunity for a full year of high-GWP equipment sales. The allocation phase-down still applies, and the supply of R-410a and other high-GWP refrigerants will be reduced as the total amount of HFCs produced or imported in 2024 is equal to 60 percent of the baseline, and the baseline is based on the production and import of HFCs from 2011-2013, an already significantly lower amount that pre-phasedown years.

For any questions about the HFC phase-down and the technology transition rule, please contact Alex Ayers.

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