Advocacy
July 28, 2025 | 3 minute read
The transition to low-GWP refrigerants in the residential and light commercial HVAC market is already well underway. According to the latest industry shipment data, R-32 and R-454B units made up 76% of all ducted unitary equipment sales in June. This means the industry has moved quickly to adopt A2L refrigerants, despite service gas supply headwinds in many parts of the country. OEMs are quickly fulfilling orders for low-GWP equipment after meeting the January 1, 2025, production cutoff for R-410A systems under the EPA's Technology Transitions Rule.
But with strong adoption now underway, one critical deadline still looms: January 1, 2026, when it becomes illegal to install new R-410A systems (Note: EPA rules allow for component replacement to repair existing units including full replacement of outdoor or indoor units, but not both, additionally packaged systems can be sold until January 1, 2028). And despite industry rumors or wishful thinking, that date has not moved.
Back in March, the EPA announced it would “reconsider” elements of its Technology Transitions Rule under the AIM Act. Since then, there has been no proposed rule, no revised timeline, and no public signal that the installation deadline will be extended.
Why does that matter? Because regulatory delays require formal rulemakings. To write a new rule under the AIM Act is a time-consuming process with mandatory public comment periods and interagency review. With less than 6 months left until the 2026 split-system installation deadline, the window for the EPA to make changes is closing quickly. When a new proposal appears in the Federal Register, changes to the current HVAC transition remain unlikely.
Distributors and contractors should also understand that the idea of reverting to R-410A is not just unlikely—it’s logistically impossible. Factories retooled their assembly lines months ago to meet the January 1, 2025 manufacturing ban for R-410A. The supply chains for compressors, coils, sensors, and quality control systems were all redesigned for flammable A2L refrigerants. A reversal would mean months or even years of reengineering and re-certification, not to mention a staggeringly high additional cost to go backwards (temporarily, the reduction in high-GWP refrigerant will require a transition regardless of EPA deadlines).
The reality is, the transition has already occurred. OEMs made the switch. Equipment is selling. Contractors have been trained. While there are certainly market pressures and adjustment pains, the regulatory and manufacturing trains have left the station.
HARDI members should keep preparing for the 2026 install deadline. As the sales numbers show, most of the market already is. This is a time for clarity, not confusion. The worst course of action would be to delay purchases, training, or inventory decisions based on the false hope of a rule change that is nowhere in sight.
The bottom line: Low-GWP is here, now is the time for distributors to focus on selling out of remaining R-410A inventory to prevent stranded equipment.
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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