A regulatory fight that has received far less public attention than the A2L refrigerant transition or PFAS state reporting requirements, but that AHRI's own regulatory affairs team considers potentially more significant, is unfolding around a proposed change to the ASME Boiler and Pressure Vessel Code, Section VIII. The proposed change would eliminate three long-standing exemptions that currently apply to many HVACR components — exemptions that have been in place for decades, in some cases as long as forty years, without any documented safety incident motivating their removal.
AHRI and twenty-nine other industry organizations have formally appealed the proposed change after more than 250 negative public comments were submitted during the review process, with every single one rejected without explanation. The scale and unanimity of that rejection, combined with the lack of any stated rationale, is precisely what has elevated this from a routine code-update disagreement into a fight AHRI is treating as a genuine priority.
Why a Code Most Contractors Have Never Heard Of Could Matter to Your Business
The ASME Boiler and Pressure Vessel Code, Section VIII, governs the design, fabrication, and certification requirements for pressure vessels — equipment that, in the HVACR context, includes a range of components used across commercial refrigeration, chillers, and other pressurized HVAC equipment. The specific exemptions under threat have historically allowed certain HVACR components to be manufactured and certified without the full pressure vessel code compliance burden that applies to industrial pressure vessels in entirely different applications, on the basis that the relevant components have operated safely under the existing exemption framework for decades.
Eliminating those exemptions would mean manufacturers of the affected HVACR components would need to redesign, recertify, or substantially modify their manufacturing and quality assurance processes to comply with the full Section VIII pressure vessel requirements — a meaningful compliance cost increase that, absent a clear safety justification, AHRI's regulatory team characterizes as regulatory scope creep rather than a genuine safety improvement.
The Absence of a Stated Rationale Is the Real Story Here
What distinguishes this fight from a typical industry pushback against a new regulation is the specific process failure AHRI is highlighting: more than 250 negative comments submitted by industry stakeholders during the formal review period were rejected, every single one, without any explanation provided for why the concerns raised were not addressed. In a regulatory or standards-setting process that depends on stakeholder input actually shaping outcomes, a uniform rejection with no stated reasoning raises legitimate questions about whether the standard-setting body has genuinely engaged with the substance of industry concerns or is treating the public comment process as a formality.
This is precisely the kind of regulatory pattern that justifies AHRI mobilizing twenty-nine other organizations into a formal coordinated appeal rather than allowing individual member companies to absorb the compliance cost increase quietly. A coordinated, multi-organization appeal carries more institutional weight and is harder to dismiss than scattered individual objections, and it signals that the HVACR industry views this specific code change as a priority worth sustained advocacy resources.
