EPA proposes eliminating HVAC install deadline

The EPA on Tuesday officially proposed eliminating the January 1, 2026, installation deadline for certain residential and light commercial air conditioning and heat pump systems, one month after Administrator Lee Zeldin suggested a change was coming. 

Catch up quick: The ‘Technology Transitions’ rule, published in October 2023 as part of the AIM Act, which kicked off today’s refrigerant transition, set a January 1, 2025, install deadline for residential and light commercial AC and heat pump systems using components manufactured or imported before this year.

• Just two months later, in December 2023, the deadline was extended by one year to January 1, 2026, in response to industry pushback over stranded inventory concerns. 

What’s happening: “The EPA no longer believes that limiting the ability to install new systems is warranted,” the agency writes in its proposed rule.  

• “Removing the installation compliance date allows [the] industry to sell through remaining inventory of R-410A equipment that has been previously manufactured or imported,” it adds.
• “This flexibility would… give consumers and contractors an additional option during the market transition to new substitutes.”

Of note: Tuesday’s announcement is just a proposal — nothing has actually changed at this point. 

The big picture: The EPA’s proposal points to A2L-related challenges from earlier this year, including cylinder shortages, which “affected the availability of R-454B… throughout the spring and most of the summer,” per the text, prompting OEMs to increase refrigerant charges in new equipment. 

• “Despite these actions to make R-454B more available,” it says, “the EPA understands that in some parts of the country, access to R-454B remains challenging.”
• The agency first considered a one-year extension to January 1, 2027; however, since it “does not have information about the extent of equipment that may remain in company inventories as of January 1, 2026, removing the installation compliance date altogether may be the more appropriate approach,” it adds. 

Zoom in: While the proposed rule calls for eliminating the install deadline, it leaves untouched a provision that currently allows condensing units using refrigerant with a GWP above 700, including R-410A, to be replaced as part of a repair. 

• “If restrictions were to be placed on replacing the condensing unit, the owner’s only recourse would be to replace the entire system,” it notes. 

The other side: Zeldin’s suggestion in late August that the agency may extend the deadline drew immediate pushback from industry associations, which argued that the move would cause disruptions — and is illegal. 

• “The AIM Act requires at least one year’s notice before changing compliance dates, meaning EPA cannot legally push back the 2026 deadline now without inviting lawsuits from the environmental community, creating uncertainty,” HARDI wrote at the time. 
• “Congress included this clause to prevent the very type of last-minute disruption EPA now appears to be considering,” it added.

The intrigue: The agency addresses the one-year notice period in Tuesday’s proposal; however, it argues for a caveat.

• “The EPA is proposing that the best reading of this statutory text is that the one-year requirement applies only to the creation of new restrictions and not to the relaxation or removal of existing restrictions,” it says. 

Representatives for ACCA, HARDI, and PHCC didn’t immediately return requests for comment, and a representative for the EPA referred Homepros to the proposal’s text. 

Looking ahead: The proposed rule will be open for a 45-day public comment period, after which the EPA will review those comments before issuing a ‘final rule.’

• Given the federal rulemaking process, HARDI CEO Talbot Gee on Tuesday noted that a final rule will be difficult to publish by year-end, and likely won’t be released until the first quarter of 2026.