HARDI Applauds Quick EPA Action to Deprioritize Federal Enforcement of Installation Prohibitions in Technology Transition Rule

FOR IMMEDIATE RELEASE

Contact: Madison Romero, Public Affairs Associate
Email: mromero@hardinet.org
Direct: 614.345.4328

HARDI Applauds Quick EPA Action to Deprioritize Federal Enforcement of Installation Prohibitions in Technology Transition Rule

Columbus, OH — December 23, 2025 — Heating, Air-conditioning, & Refrigeration Distributors International (HARDI) applauds the U.S. Environmental Protection Agency (EPA) for releasing a new statement that deprioritizes federal enforcement of the January 1, 2026, installation prohibitions contained in the Technology Transition Rule Reconsideration. This action signals a significant shift in how the Agency will apply its limited enforcement resources as the law is expected to change.

“This is welcome news for distributors and contractors going into the new year,” said HARDI CEO Talbot Gee. “We heard from our members the need for certainty, and HARDI submitted an official request to the Agency earlier this month to provide relief to distributors and contractors before the final rule is released.”

The Technology Transition Rule, finalized under the American Innovation and Manufacturing (AIM) Act, includes an installation date prohibition that has been widely criticized by contractors, distributors, and manufacturers as unworkable and disconnected from how projects are planned, permitted, and built. Earlier this year, the EPA released a proposed rule to repeal the January 1, 2026, prohibition on installing residential and light-commercial air conditioners and heat pumps using R-410A refrigerant. HARDI submitted comments in support of this change and asked the EPA to expand the repeal of installation dates to include remote condensing units used in commercial refrigeration and equipment in cold storage warehouses, but the regulatory process is expected to take several months before a final rule is released.

“The EPA recognizes that repeal won’t help the industry until the rule is finalized,” said Alex Ayers, Vice President of Government Affairs for HARDI. “This new statement makes clear that federal enforcement of these installation prohibitions is not a priority while the Agency completes its reconsideration. This provides much-needed certainty for businesses planning projects and managing inventory during the transition.”

By deprioritizing enforcement of the Technology Transition Rule’s installation prohibitions for residential and light-commercial air conditioners and heat pumps, remote condensing units used in commercial refrigeration, and refrigeration systems used in cold storage warehouses, EPA acknowledges that aggressive federal enforcement in this area would create disruption without advancing long-term policy objectives, particularly given the likelihood of regulatory changes.

This action does not repeal or amend the Technology Transition Rule, and EPA’s enforcement discretion applies only to federal enforcement. States and local governments retain authority to enforce applicable requirements under state law, building codes, and permitting programs, and contractors must continue to comply with those obligations. However, the new statement significantly reduces the likelihood of EPA-initiated federal enforcement actions related to installation timing during this transition period.

“EPA’s decision confirms what industry stakeholders have long argued: the installation prohibition is flawed, impractical, and poorly suited for enforcement,” Ayers added. “While the rule remains on the books, EPA will now focus its enforcement efforts on higher-priority violations that present more significant concerns, like the illegal import of refrigerants and maintaining the R-410A manufacturing prohibition on non-repair components.”

HARDI will continue to urge Congress to provide a permanent legislative fix that eliminates all future installation dates set by any agency, providing clarity and certainty for contractors, distributors, and manufacturers.

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