HVAC contractors and equipment manufacturers are navigating two simultaneous regulatory tracks in 2026 that are reshaping compliance requirements for both equipment installation and refrigerant chemistry: the state-by-state adoption of building and mechanical codes that permit — and in some cases mandate — the use of A2L mildly flammable refrigerants in residential and commercial HVAC systems, and an evolving PFAS regulatory framework that places new scrutiny on per- and polyfluoroalkyl substances, a category that encompasses some fluorinated refrigerants and refrigerant chemistry that the HVAC industry uses in production processes.
The two tracks are distinct in their regulatory agencies, compliance requirements, and timelines, but they intersect in the workload they place on manufacturers and contractors who must simultaneously manage the A2L installation code compliance transition and monitor PFAS regulatory developments that could affect refrigerant chemistry, product formulation, and liability exposure for companies that use or have historically used PFAS-containing compounds. The Chemours $450 million PFAS pollution settlement announced June 24 — the first comprehensive federal settlement resolving claims over pollution by a manufacturer of forever chemicals — underscores the legal and financial stakes now attached to PFAS compliance in chemical manufacturing, a category that includes refrigerant production.
The A2L Building Code Landscape
The A2L refrigerant transition that has driven equipment redesign since 2023 continues to progress through state and local building code adoption. The International Mechanical Code and International Fire Code have both been updated to include provisions for A2L refrigerants, but code adoption is a state and local decision in the United States, meaning the effective date of A2L-permitting code requirements varies significantly by jurisdiction. States in the early adopter category — including California, Colorado, Washington, and others that update building codes on accelerated timelines — have effective A2L provisions already in place in most jurisdictions. States that adopt codes on the standard three-year development cycle are at various stages of adopting the 2021 and 2024 IMC editions that contain A2L provisions.
For contractors, the practical compliance question in 2026 is not whether A2L equipment exists — it does, with AHRI reporting that over 90% of new residential and light commercial equipment now uses next-generation A2L refrigerants — but whether the local building code in the jurisdiction where they are installing that equipment has been updated to permit A2L installation. A handful of jurisdictions are still operating under older code editions that were written before A2L refrigerants were addressed, creating a situation where the nationally available equipment uses A2L refrigerants that a local code may not explicitly authorize. Contractors should verify the current edition of the mechanical and fire codes adopted in their service jurisdictions and, where older editions are in effect, work with the local authority having jurisdiction to determine the approved basis for A2L installation.
PFAS and Refrigerant Chemistry
The PFAS regulatory story is more complex and longer-term in its implications for HVAC refrigerants. Hydrofluorocarbons — the refrigerant category being phased down under the AIM Act — are fluorinated compounds, and some regulatory frameworks addressing PFAS have broad enough definitional language to include HFCs, though the most developed PFAS regulations have historically focused on PFAS compounds with longer carbon chains, like PFOA and PFOS, rather than the shorter-chain HFCs used in HVAC.
The Chemours settlement, while focused on manufacturing process PFAS discharges at Chemours facilities rather than on refrigerant product use, illustrates the scale of legal liability that PFAS-related environmental claims can generate. Chemours, whose Opteon refrigerant products are among the leading A2L and HFO alternatives promoted for the refrigerant transition, agreed to more than $450 million in fines and remedies to resolve PFAS-related claims at four manufacturing facilities. The settlement affects facilities that produce or use PFAS, not HVAC contractors who install refrigerant-containing equipment, but it reinforces the regulatory and legal scrutiny that fluorinated chemistry is attracting across the supply chain from production to application.
What Contractors Need to Monitor
For HVAC contractors, the practical monitoring priorities in 2026 are jurisdiction-specific A2L code adoption status, refrigerant handling certification requirements for A2L equipment service, and any PFAS-related product disclosure or reporting requirements emerging at the state level in markets like California, Colorado, Minnesota, and Massachusetts, which have each enacted independent PFAS regulatory frameworks that extend beyond federal EPA requirements. Contractors in those states should monitor state environmental agency guidance on PFAS in building products and mechanical systems for any provisions that address fluorinated refrigerants.
The dual track of A2L code compliance and PFAS regulatory monitoring adds complexity to a compliance environment that already includes AIM Act phasedown tracking, EPA Technology Transitions Rule compliance, Section 608 refrigerant handling requirements, and the state-level electrification and building performance standards that are emerging in several major markets. ACCA, HARDI, and PHCC have each published contractor guidance on refrigerant compliance in 2026 that addresses the primary regulatory requirements, and AHRI maintains updated technical resources on A2L equipment installation standards that are available to contractor members.
