January 2026 – General Update on EPA Refrigerant Transition Rules and Reconsideration Rule

The majority of the HVAC industry, including HARDI and ACCA, is in support of EPA's TT rule reconsideration, removing the installation compliance date for left-over R-410A inventory of residential and light commercial equipment (see October 2025 post). However, as of January 2026, the EPA has not yet formalized or released the final reconsideration rule. In light of this, the EPA announced just before the holidays that it would deprioritize enforcement of the installation compliance dates covered by the TT rule reconsideration.

Though this recent update by the EPA provides some relief and signals positive direction in the release of the ruling, the current installation compliance date (now behind us), technically still applies. We are observing mixed reactions from the marketplace, with some continuing to install R-410A systems, while others are still choosing to abide by the rules. It is our opinion that installing left-over R-410A systems in 2026 is relatively low risk due to the EPA’s deprioritization. However, we want to be clear that the rules are technically still in place. We do expect the TT rule reconsideration to eventually be published in the coming months.

As of now, the EPA has not provided any further guidance and direction on the installation compliance date for R-410A VRV/VRF, which means that there are 11 months left to install such systems. Daikin and industry organizations such as HARDI and ACCA are still working with the EPA to remove the VRV/VRF installation compliance date. Meanwhile, almost all residential and light commercial SKUs are available from most manufacturers with A2L refrigerants, and the first R-32 VRV systems are landing on job sites in the U.S. this month (for Daikin).