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EPA Rewrite Frees Pre-2025 R-410A Stock for New Installs and Bars Everything Newer

The rule took effect July 27. It drops the install deadline only where every specified component was made in or imported into the U.S. before Jan. 1, 2025. R-410A VRF stock still faces a Jan. 1, 2027, cutoff, and New York kept its own Jan. 1, 2026, date.

Staff Reporter  |  November 4, 2026
Key TakeawayResidential and light commercial R-410A systems can still be installed as new only if every specified component was made in or imported into the U.S. before Jan. 1, 2025. The 700 GWP limit is unchanged for anything newer, and condensing units sold under the service exemption still cannot go in as new systems.

A new R-410A split system now passes federal rules only if every specified component predates 2025. The Environmental Protection Agency's rewrite of its Technology Transitions rule, published May 26 and effective July 27, removed the installation deadline for residential and light commercial systems whose components were all made in the U.S. or imported before Jan. 1, 2025.

The 700 GWP limit itself did not move. "Installing new R-410A systems using equipment domestically manufactured or imported after January 1, 2025, remains prohibited," the agency wrote in the preamble.

The date stamp decides the install

Equipment built in Mexico or Canada before 2025 and brought into the U.S. after that date cannot be installed as part of a new system. Specified components for above-limit refrigerants made after that date must carry the label "For servicing existing equipment only," which EPA said gives a technician enough to judge whether a condensing unit qualifies. Swapping a failed condensing unit on an existing system remains allowed and does not count as a new installation.

EPA also said it cannot size what it freed. The agency acknowledged "a lack of concrete data on the number of R-410A units that remain in inventory," called the stock "finite and decreasing," and conceded "the potential challenges this poses to enforcing the restrictions against a few bad actors."

Two exceptions that catch installers

EPA treated VRF requests as out of scope, so R-410A VRF systems with components made or imported before Jan. 1, 2026, must be installed before Jan. 1, 2027, 58 days from now. Projects with a building permit approved before Oct. 5, 2023, have until Jan. 1, 2028.

New York's Part 494 keeps Jan. 1, 2026, for these systems, and a Department of Environmental Conservation FAQ updated in October says "changes to federal regulations are not automatically incorporated into Part 494." The Air Conditioning Contractors of America said New York contractors holding R-410A equipment "will likely take a loss selling it to contractors in other states."

New Retail Food and Cold Storage Limits
  • Supermarket systems: 1,400 GWP from Jan. 1, 2027, then 150 or 300 from Jan. 1, 2032
  • Retail food remote condensing units: 1,400 GWP from July 27, 2026, then 150 or 300 from Jan. 1, 2032
  • Cold storage warehouses: 700 GWP from July 27, 2026, then 150 or 300 from Jan. 1, 2032
  • The 150 limit applies at 200 pounds of charge or more. The 300 limit covers smaller charges and the high temperature side of a cascade system.
  • Existing supermarket systems can add up to 15 percent cooling capacity without being treated as new

EPA said the 1,400 ceiling keeps R-448A, R-449A and R-513A available for new supermarket installs. "This rule works against basic supply and demand," said Stephen Yurek, president and CEO of the Air-Conditioning, Heating, and Refrigeration Institute, in remarks reported by ACHR News.

R-454B cylinders and a soft HFC market

The rule's preamble gives EPA's account of last year's scramble. "While there was a sufficient supply of R-454B, there were challenges supplying the refrigerant in service cylinders to contractors and technicians," the agency wrote, which left scarcity in some regions. No current figure for R-454B cylinder lead times or prices could be verified from a primary document this fall, so none is printed here.

Hudson Technologies reported on Oct. 28 that third-quarter pricing fell 17 percent, and CEO Ken Gaglione told analysts that "ample channel inventory kept HFC market prices low." CFO Brian Bertaux said he expects 2027 pricing "to be about the same as 2026."

What ER&R requires, and of whom

The Emissions Reduction and Reclamation rule is a separate program, and the May action left it alone apart from a proposal to exempt road and intermodal transport refrigeration units from leak repair. No final version had appeared in the Federal Register as of Nov. 4.

Leak repair under 40 CFR 84.106 has applied since Jan. 1, 2026, to appliances with a full charge of 15 pounds or more of a regulated substance or of a substitute above 53 GWP. Appliances in the residential and light commercial air conditioning and heat pump subsector are excluded, which narrows what the 15-pound threshold reaches.

For covered equipment, the trigger is a leak rate above 20 percent for commercial refrigeration, 30 percent for industrial process refrigeration, and 10 percent for comfort cooling and other appliances. Owners or operators must identify and repair leaks within 30 days of adding refrigerant to an appliance over its limit, or 120 days if an industrial process shutdown is required. A certified technician must do the repair, and anyone adding or removing refrigerant must give the owner documentation.

Commercial refrigeration and industrial process systems holding 1,500 pounds or more that were installed from 2017 through 2025 need automatic leak detection by Jan. 1, 2027.

Why This Matters to Contractors

A rack installed on R-448A in 2027 under the new supermarket limit will meet a harder market within two years. On Jan. 1, 2029, servicing supermarket systems, refrigerated transport and automatic commercial ice makers must be done with reclaimed refrigerant, and the national HFC cap drops from 60 percent to 30 percent of baseline, taking consumption from the 181.5 million metric tons of exchange value equivalent EPA set for 2027 on Oct. 6 to about 90.8 million. New racks can keep going in on those blends until Jan. 1, 2032, three years after both changes.

Sources

  1. U.S. Environmental Protection Agency, "Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act," 91 FR 31284, May 26, 2026. federalregister.gov
  2. Code of Federal Regulations, 40 CFR 84.54, restrictions on the use of certain regulated substances, current text. ecfr.gov
  3. Code of Federal Regulations, 40 CFR 84.106, leak repair, current text. ecfr.gov
  4. Code of Federal Regulations, 40 CFR 84.108, automatic leak detection systems, current text. ecfr.gov
  5. Code of Federal Regulations, 40 CFR 84.112, reclamation, current text. ecfr.gov
  6. Code of Federal Regulations, 40 CFR 84.7, phasedown schedule, current text. ecfr.gov
  7. U.S. Environmental Protection Agency, "Excluding Road and Intermodal Container Transport Refrigeration Units From the Hydrofluorocarbon Leak Repair Requirements," 91 FR 30532, May 26, 2026. federalregister.gov
  8. U.S. Environmental Protection Agency, "Notice of 2027 Allowance Allocations," 91 FR 63548, Oct. 6, 2026. federalregister.gov
  9. New York State Department of Environmental Conservation, "Frequently Asked Questions, Part 494," updated October 2026. dec.ny.gov
  10. ACCA, "EPA lifts R-410A installation deadline, but refrigerant prices could rise," May 22, 2026. hvac-blog.acca.org
  11. ACHR News, "EPA Removes R-410A Installation Deadline," May 2026. achrnews.com
  12. Hudson Technologies, "Hudson Technologies Reports Third Quarter 2026 Results," Form 8-K exhibit, Oct. 28, 2026. sec.gov
  13. TradingKey, Hudson Technologies third-quarter 2026 earnings call transcript. tradingkey.com
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