The Environmental Protection Agency finalized revisions to the 2023 Technology Transitions Rule on May 21, removing the January 1, 2026 installation deadline for pre-2025 residential and light commercial air conditioning and heat pump equipment using refrigerants with a global warming potential above 700 — most significantly R-410A — while simultaneously extending HFC compliance deadlines for commercial refrigeration applications in supermarkets, retail food stores, and cold storage warehouses. The rule takes effect 60 days after publication in the Federal Register.
EPA Administrator Lee Zeldin framed the rule as fulfilling President Trump's commitment to lower costs and fix every problem the agency can address within its statutory authority, saying the changes allow businesses to choose refrigeration systems that work best for them, saving billions of dollars that will be felt directly by American families in lower grocery prices. The comment on grocery prices was directed at the commercial refrigeration provisions, which the EPA argued would lower the cost of store refrigeration compliance; AHRI and HARDI both disputed that characterization sharply.
The R-410A Win for Contractors
The removal of the R-410A installation deadline is the provision with the most direct and immediate impact for residential and light commercial HVAC contractors. Under the original Technology Transitions Rule, contractors and distributors would have been prohibited from installing R-410A equipment manufactured or imported before January 1, 2025, after January 1, 2026. That would have forced distributors to write off or remove from inventory pre-2025 R-410A equipment still in stock and contractors to stop installing R-410A units even when they had been purchased by customers or were already on the truck. Under the revised final rule, that deadline is removed. Contractors can continue installing pre-2025 R-410A inventory until supplies are depleted — effectively extending the useful commercial life of that equipment stock indefinitely. Over 90% of new residential and light commercial equipment already uses next-generation A2L refrigerants, according to AHRI, so the volume of R-410A inventory affected is concentrated in existing stock rather than new production.
The Commercial Refrigeration Compromise — and Why AHRI Opposes It
The provisions generating sharp industry criticism involve commercial refrigeration applications. The rule temporarily raises the allowable refrigerant GWP limit for supermarket and retail food refrigeration systems from 150 or 300 to 1,400 GWP beginning January 1, 2027, through January 1, 2032 — a five-year window in which new commercial refrigeration equipment can continue to use high-GWP HFCs rather than transitioning to lower-GWP alternatives. Cold storage warehouses receive a similar GWP relaxation beginning 60 days after Federal Register publication through January 1, 2032.
AHRI president and CEO Stephen Yurek said the commercial refrigeration revision works against basic supply and demand: by extending compliance deadlines, the EPA is maintaining and even increasing demand in the market for existing refrigerants while supply continues to fall under the AIM Act phasedown — meaning instead of falling, refrigerant prices are likely to rise. HARDI estimated the increased demand from the extended commercial refrigeration deadlines could add nearly $8 billion in refrigerant costs alone, with broader economic impacts potentially reaching $13 billion across the HVACR industry. HARDI CEO Talbot Gee called the outcome deeply disappointing.
The AHRI/Alliance Position on Manufacturers
John Hurst, executive director of the Alliance for Responsible Atmospheric Policy, added a dimension beyond cost: American manufacturers invested in new equipment, new refrigerants, new production lines, and American workers to meet the existing dates because Congress and the first Trump administration asked them to. The administration has now changed course in a way that weakens those investments. AHRI and the Alliance noted that next-generation refrigerants are widely available and approved for use in commercial refrigeration applications today, challenging the EPA's implicit premise that extended deadlines are needed because the market is not ready.
The interplay between the R-410A win and the commercial refrigeration loss is what prompted HARDI, ACCA, and PHCC to file a federal court challenge to the reconsideration rule on June 25 — a challenge specifically targeting the commercial refrigeration deadline extensions while supporting the R-410A installation deadline removal. The legal and regulatory landscape around refrigerant transitions will continue to evolve through that litigation and through the ongoing AIM Act phasedown schedule, which reduces HFC production and import allowances on a fixed statutory timeline regardless of what the EPA's Technology Transitions Rule says about when new equipment must transition.
