The U.S. Environmental Protection Agency said it will deprioritize federal enforcement of certain installation restrictions scheduled to take effect Jan. 1, under its Technology Transition Rule, signaling a temporary easing of regulatory pressure on HVAC and refrigeration distributors and contractors while the rule is reconsidered.
The enforcement guidance applies to installation prohibitions affecting residential and light-commercial air conditioners and heat pumps using R-410A refrigerant, as well as remote condensing units used in commercial refrigeration and refrigeration systems in cold-storage warehouses. EPA said the decision reflects how it will allocate limited enforcement resources as regulatory changes remain under review.
The Technology Transition Rule was finalized under the American Innovation and Manufacturing Act and includes installation date prohibitions that industry groups have argued are disconnected from how projects are planned, permitted, and executed. Contractors and distributors have raised concerns that the rule could strand inventory and disrupt projects already underway.
“This is welcome news for distributors and contractors going into the new year,” said Talbot Gee, chief executive of Heating, Air-conditioning & Refrigeration Distributors International (HARDI). Gee said the group submitted a formal request earlier this month urging EPA to provide enforcement relief ahead of a final rule.
Earlier this year, EPA proposed repealing the Jan. 1, 2026, installation prohibition for residential and light-commercial air conditioners and heat pumps that use R-410A refrigerant. HARDI supported the proposal and asked the agency to expand the repeal to include commercial refrigeration equipment and cold storage applications. EPA has said the rulemaking process is expected to take several months before final action is taken.
“The EPA recognizes that repeal won’t help the industry until the rule is finalized,” said Alex Ayers, vice president of government affairs at HARDI. “This statement makes clear that federal enforcement of these installation prohibitions is not a priority while the agency completes its reconsideration.”
EPA said the guidance does not repeal or amend the Technology Transition Rule. The enforcement discretion applies only to federal actions. State and local governments retain authority to enforce applicable requirements through building codes, permitting programs, and state environmental regulations.
While the rule remains in effect, the guidance significantly reduces the likelihood of EPA-initiated federal enforcement actions related to installation timing during the transition period. EPA said it will instead focus enforcement efforts on higher-priority violations, including illegal refrigerant imports and compliance with manufacturing prohibitions on certain non-repair components.
HARDI said it will continue to advocate for a legislative solution that would eliminate future installation date mandates set by federal agencies, arguing that clearer statutory guidance is needed to provide long-term certainty for contractors, distributors, and manufacturers.
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