Public comments favor eliminating HVAC install deadline

The installation of residential and light commercial air conditioning and heat pump systems using components manufactured or imported before this year is prohibited beginning January 1, 2026. 

However, the EPA on September 30 proposed eliminating the deadline, allowing such systems to be installed indefinitely, and opened a public comment period to accept feedback before issuing a final rule. 

What’s happening: Friday marked the final day of that period, with the agency receiving 70 comments from stakeholders across the industry, including contractors, distributors, and manufacturers. 

What they’re saying: “As a licensed HVAC contractor, we urge EPA to approve the sell-through extension,” wrote John Anstett, sales manager at Wisconsin-based Wulf Brothers, adding that doing so “prevents job cancellations, alleviates homeowner and business owner concerns, and limits waste of existing materials while keeping emissions controlled.”

• “Our customers have open purchase orders and job-specific packages in transit or on hand,” said Pete Perret, sales leader at distributor G.A. Larson. “Allowing for extended sell-through lets those projects proceed while manufacturers complete listings, training, and code alignment for newer systems.”
• “Distributors and contractors nationwide currently hold large inventories of legally manufactured R-410A equipment purchased in good faith,” added Thermal Supply’s Dominic Morando. “A prohibition on installation after 2025 would instantly render this equipment unsellable… [and] likely result in improper or premature disposal of R-410A refrigerant as stranded systems are scrapped,” which would “directly contradict the AIM Act’s environmental intent.”

State of play: One commentator, writing on behalf of a group of U.S. HVAC manufacturers and importers, noted, “Across manufacturers, distributors, and contractors, the market value of unsold [R-410A] systems is estimated to exceed $100 million nationwide.”

• “Premature disposal would produce economic waste without any meaningful environmental benefit,” they added. “EPA’s proposal correctly allows for orderly market depletion and inventory management.”

Yes, but: Carl Reid, a Texas-based mechanical engineer, was one of few commentators to oppose the agency’s proposed rule change. “The AIM Act was intentionally designed not only to reduce climate impacts but also to accelerate technological innovation and strengthen U.S. manufacturing competitiveness,” he wrote.

• “The HVAC industry has already made substantial investments in next-generation systems,” he added. “The EPA’s [initial] rule provided long-term regulatory certainty that enabled these investments.”
• “Reconsidering or extending compliance deadlines for condensing units risks creating regulatory uncertainty, discouraging further private-sector investment, and disadvantaging U.S. manufacturers… The U.S. should not jeopardize its leadership position by signaling policy instability.”

Go deeper: An anonymous commentator added, “The EPA is prioritizing the wants of private companies over public and environmental health by prolonging avoidable emissions.”

What we’re watching: The EPA will now review the submitted comments before issuing a final rule, which, given the federal rulemaking process, will likely be released in the first quarter of 2026. 

Full list of comments