This Month in DC Overview: June 2026

This Month in DC Overview

Alex Ayers gives us an overview of the most important things going on in DC this month. Highlights of this month's government affairs issues are:

This month brought significant developments across Washington, DC, state legislatures, and the courts, with major implications for the HVACR industry. Key issues included EPA refrigerant rules, tariff changes, furnace efficiency litigation, state-level NOx and HFC policies, counterfeit refrigerants, and federal labor legislation.

Industry Groups Challenge EPA Technology Transition Rule

HARDI, PHCC, and ACCA have jointly filed a petition for judicial review challenging EPA’s recent Technology Transition reconsideration rule. The legal action focuses on three specific subsectors: commercial refrigeration in supermarkets, remote condensing units, and cold storage.

The challenge centers on EPA’s decision-making process, particularly whether the agency adequately considered industry data showing that the transition could continue under prior requirements. The lawsuit also raises concerns about increased demand for HFCs beyond the available supply under the ongoing phasedown.

This case is important to the industry’s broader effort to prevent a second transition and encourage EPA to roll back changes that could create additional market disruption.

State Advocacy Continues in Key Markets

HARDI’s state advocacy team has been active across several states, including New York, California, and Colorado. A new update from Todd Titus, Madison Romero, and Zach Johnson highlights recent work during the second quarter, with attention to regulatory and legislative developments affecting HVACR distributors and contractors.

Section 232 Tariff Changes Affect HVACR

President Trump announced changes to Section 232 tariffs that affect HVACR products. One notable change was a special exemption for residential HVAC systems, which reduced the applicable tariff rate. Additional changes were also made regarding metal-content tariffs under Section 232.

These changes were welcomed by the industry, particularly given the cost pressures already facing HVACR supply chains.

Supreme Court Vacates 95% Furnace Decision

The Supreme Court vacated the DC Circuit Court’s decision involving the 95% residential furnace rule. This sends the case back to the lower court for further litigation and creates the possibility that the rule could eventually be overturned.

For now, the rule remains in place. However, the Department of Energy is separately working to delay implementation until 2030. HARDI previously filed an amicus brief in the case and supported the Supreme Court’s decision to send it back for further review.

Supreme Court Rejects Allocation Rule Appeal

HARDI also filed an amicus brief in a case involving EPA’s HFC allocation rule, which determines which companies participate in the HFC phasedown. The Supreme Court recently rejected a petition from RMS of Georgia challenging the rule.

HARDI welcomed that outcome because it helps preserve stability in the HFC refrigerant phasedown process.

Colorado Removes Ultra-Low NOx Requirement for Manufactured Homes

Colorado recently removed its ultra-low NOx requirement for furnaces manufactured for manufactured homes. This was an important change for the market, as members had reported difficulty finding compliant products for that specific application.

The removal of the requirement should help address product availability concerns in Colorado’s manufactured housing sector.

Ventura County Rejects Ultra-Low NOx Rule

In California, Ventura County rejected a proposed ultra-low NOx requirement for its air quality management district. The decision was driven in part by affordability concerns.

This reflects a broader trend: local governing boards are increasingly weighing affordability and product availability when considering new emissions requirements.

New York Shifts from GWP-20 to GWP-100

New York made significant changes to the Climate Leadership and Community Protection Act as part of its state budget. One of the most important changes was moving from a GWP-20 measurement standard to GWP-100.

This matters because New York had been an outlier in using GWP-20 for policy purposes, while most other jurisdictions use GWP-100. The GWP-20 approach made compliance with New York’s HFC regulations, including Part 494, more difficult.

The shift to GWP-100 could open the door for New York to revisit Part 494 and potentially remove some of the most aggressive requirements, including ultra-low GWP mandates. HARDI’s lawsuit in New York also continues, with the state expected to respond to HARDI’s appeal brief next month.

Counterfeit and Illegal Refrigerants Are a Growing Concern

HARDI is warning members to be cautious of refrigerant deals that appear too good to be true. Counterfeit refrigerants are becoming a greater concern, but the risks go beyond counterfeit products.

Because HFCs are regulated substances with tightly controlled imports, declining supply may create incentives for illegal imports. A recent case in another building-materials-related industry showed that distributors can face liability even if they are not the illegal importer, particularly if they should have known the product was suspiciously cheap or improperly sourced.

The warning is clear: companies should scrutinize unusually low-priced refrigerant offers and avoid participating, even indirectly, in illegal import activity.

Faster Labor Contracts Act Passes the House

The Faster Labor Contracts Act has also been a major focus. HARDI joined allies, including the National Association of Wholesale Distributors and the Coalition for a Democratic Workplace, in a coalition letter signed by approximately 375 organizations opposing the bill.

Despite that opposition, the legislation passed the House with some Republican support. HARDI opposes the bill because it would inject the government into labor contract negotiations, potentially harming both employers and employees. The focus now shifts to the Senate, where opponents hope to prevent the bill from advancing.

DOE Delay for Furnace and Commercial Water Heater Rules

The Department of Energy is considering delaying implementation of the residential furnace 95% rule until 2030. The delay would also apply to the commercial water heater rule.

Both rules are connected to the litigation now returning to the DC Circuit Court. HARDI joined a coalition comment letter urging DOE to delay the implementation dates to 2030.

Explore HARDI's Industry Issues and State Issues pages and stay up to date on the latest issues affecting the HVACR industry.

Read more on what's affecting our industry here: HARDI's Advocacy Blogs

Stay Informed with HARDI Advocacy

With federal rules advancing, tariffs shifting, and states introducing new complexities, staying informed is critical. HARDI continues to advocate for practical, member-focused solutions across all levels of government.