🔧 HVAC Article of the Month: Repeal of 2026 Installation Deadline for Pre-2025 Residential and Light Commercial AC/Heat Pumps
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Background: Original Requirements
Under the original Technology Transition Rule, the HVAC industry faced two distinct compliance mechanisms:
Products: These included packaged systems, which were granted a three-year sell-through period following their manufacturing cutoff. Sellers—not installers—were responsible for compliance. For example, R-410A packaged AC units had a January 1, 2025, manufacturing cutoff and could be legally sold through January 1, 2028.
Systems: Split systems, on the other hand, were governed by installation deadlines. Installers—not sellers—were liable if they installed systems after the cutoff date. Originally, R-410A split system ACs and heat pumps had both a manufacturing and installation cutoff of January 1, 2025.
Through advocacy by HARDI (Heating, Air-Conditioning & Refrigeration Distributors International) and other industry stakeholders, the EPA previously extended the installation deadline for these systems by one year—to January 1, 2026.
What’s Changed
With the latest update, the January 1, 2026, installation deadline has been repealed entirely for eligible residential and light commercial split systems. This means:
Both indoor and outdoor components of systems manufactured before January 1, 2025, may now be installed without a federal installation deadline.
“For servicing only” units cannot be used for new system installations—they remain restricted to the repair of existing equipment.
There is no relief for orphaned components (i.e., unmatched indoor or outdoor units), though these can still be used for service and repair applications.
Importantly, this repeal does not affect other categories of equipment such as VRF systems, packaged units, or chillers, which continue under their existing compliance schedules.
Environmental Impact: Minimal Change
From an environmental standpoint, the HFC impact of repealing the installation deadline is considered de minimis. The majority of R-410A refrigerant in new system installations is contained in pre-charged equipment already in distributor inventories. Therefore, the removal of the 2026 installation cutoff does not significantly alter refrigerant emissions projections or the pace of the transition to lower-GWP alternatives.
Industry Implications
By removing the installation deadline, the EPA has aligned system compliance more closely with product sell-through mechanisms, reducing confusion and easing logistical burdens for contractors, distributors, and manufacturers alike. The decision provides the HVAC industry with greater flexibility to manage existing R-410A inventories responsibly while continuing to prepare for the transition to next-generation refrigerants.
