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A two-column checklist of contractor texts that are fine to send and texts that are not

“Can I still install R-410A systems?” As of October 2026 the answer is “sometimes,” and the rule behind it changed twice after it was first written. This is where the federal rules stand, what counts as a repair rather than a new installation, and what changes on the job when the new equipment uses an A2L refrigerant.

The limit: a global warming potential below 700

The rules come from EPA’s Technology Transitions program under the American Innovation and Manufacturing (AIM) Act of 2020, and they sit at 40 CFR 84.54. For residential and light commercial air conditioning and heat pump systems (EPA’s examples are mini-splits and unitary systems), the limit is a global warming potential (GWP) of 700. R-410A is far above it: EPA’s own SNAP rule of 2021 lists R-410A’s GWP as 2,087.5.

The restriction is on installation, and it reaches the installer. Section 84.54(c) says no person may install a covered system, “nor have any such system be installed through their position as a designer, owner, or operator of that system.”

How the R-410A date moved

  • October 24, 2023: EPA’s final rule restricted the installation of new residential and light commercial systems at or above the 700 limit from January 1, 2025.
  • December 26, 2023: an interim final rule extended that date by one year, to January 1, 2026, for equipment manufactured in or imported into the United States before January 1, 2025, because builders order equipment long before they know the install date.
  • May 26, 2026 (effective July 27, 2026): a reconsideration rule, published at 91 FR 31284, removed the installation deadline for that pre-2025 equipment altogether. EPA said it had heard about delayed construction projects, larger-than-expected stranded inventory, and contractors who had trouble getting R-454B in service cylinders to charge new units.

So today’s text of 84.54(c)(1) reads: new systems using a refrigerant at or above the limit “may continue to be installed where all specified components of that system are manufactured or imported prior to January 1, 2025.” A new R-410A system built from components made in 2025 or later may not be installed. Variable refrigerant flow systems run on their own dates, starting January 1, 2026, and self-contained products such as window units carry the same 700 limit on manufacture and import from January 1, 2025.

Which means the date of manufacture is now the question that decides a sale. EPA’s fact sheet on the 2023 rule says products and components that use an HFC must be labeled, with the refrigerant and, among other things, the date of manufacture. Before you install an R-410A system from stock, photograph the labels on every specified component and keep the photos in the job file. If anyone asks later whether that installation was allowed, those photos are your answer.

Repair is not installation

None of this stops you servicing the R-410A systems already in your customers’ homes. EPA’s frequent-questions page says the 2023 rule “does not limit the use of any existing product or system,” and that new components may continue to be made and imported “to allow existing systems to be maintained for the length of their useful life.” The fact sheet adds that new replacement components using higher-GWP HFCs must be labeled as for servicing existing equipment only.

Where the line falls is written into 84.54(e). Upon charging the system to full charge, three things count as installing a new system:

  1. Assembling a system for the first time from used or new components.
  2. Increasing the cooling capacity, in BTU per hour, of an existing system (supermarket systems get a 15% allowance; a home system does not).
  3. Replacing 75% or more of the evaporators (by number) and 100% of the compressor racks, condensers and connected evaporator loads of an existing system.

The common case, a failed outdoor unit on an otherwise working system, stays a repair. In the 2026 rule EPA left the treatment of condensing units unchanged, saying that “a homeowner can choose to replace their failed condensing unit rather than purchase a whole new system.” That swap works once: EPA added that after the condensing unit has been replaced, a later replacement of the indoor coil counts as installing a new system, which cannot use a refrigerant above the limit, and the same holds in the other order. Note in the job file which half of the system you replaced and when. Upsizing it is a different matter: added capacity counts as a new installation under the second item above. EPA also noted that when only the condensing unit or the indoor coil is replaced, the mismatched parts may work, but the system’s efficiency may not be as high. That is worth telling the homeowner, in writing, when you quote the repair.

R-410A will get scarcer and dearer

The supply is shrinking on a schedule. Under the AIM Act phasedown, EPA’s frequent-questions page shows HFC production and consumption allowed at 60% of the baseline for 2024 to 2028, 30% for 2029 to 2033, 20% for 2034 and 2035, and 15% from 2036. The same page warns that “the availability of HFCs and components may lessen over time,” and in the 2026 rule EPA said the price of legacy refrigerants “may rise as the phasedown continues.” Price refrigerant by the pound on its own line, from your current cost, and re-price it whenever your supplier does; Flat-Rate Pricing for Plumbing, HVAC and Electrical Service Calls covers building that line into a price book.

What changes with A2L refrigerants

The replacements in new residential equipment include A2L refrigerants such as R-454B and R-32 (HFC-32); in the 2026 rule EPA said installations using these substitutes rose significantly in 2025. EPA’s SNAP Rule 23 explains the class from ASHRAE Standard 34: “A” means no toxicity identified at or below 400 parts per million, and “2L” marks refrigerants that do propagate a flame but burn slowly, with a maximum burning velocity of 10 cm/s or less, among other limits. In plain words: lower flammability, not zero.

EPA lists these refrigerants as acceptable for new residential and light commercial air conditioners and heat pumps only subject to use conditions. In SNAP Rule 23 those conditions include:

  • New equipment only. They may be used only in new equipment “specifically designed and clearly identified” for the refrigerant; none may be used as a conversion or “retrofit” refrigerant in equipment designed for another. EPA added that the listing means a new system, including replacing the indoor unit of an existing R-410A system when its outdoor unit is replaced. An A2L condenser on an old R-410A coil is not allowed.
  • The safety standard. The equipment must meet UL 60335-2-40, 3rd edition, and the refrigerant charge must stay within that standard’s limits, which turn on factors such as the room area and the safety measures built in.
  • Warning markings. Permanent “Risk of Fire. Flammable Refrigerant Used” warnings on the equipment.

The same listing’s guidance for the field goes further: spark-proof tools, recovery equipment designed for flammable refrigerants, a class B dry powder fire extinguisher nearby, and service only by technicians “specifically trained in handling flammable refrigerants,” with training consistent with Annex HH of UL 60335-2-40. It also repeats that the Clean Air Act prohibits knowingly venting substitute refrigerants during service.

Those conditions are being revisited. EPA’s April 2026 fact sheet on proposed SNAP Rule 27 describes a proposal to move the condition for eight refrigerants in this end use, R-454B and HFC-32 among them, to the 4th edition of UL 60335-2-40 or to certification by a nationally recognized testing laboratory, for equipment made after any final rule. Watch EPA’s SNAP pages for the outcome.

Certification and training

EPA’s Section 608 page says technicians who maintain, service, repair or dispose of equipment that could release refrigerants into the atmosphere must be certified. There are four certifications: Type I for small appliances, Type II for high- and very high-pressure appliances (other than small appliances and motor vehicle air conditioning), Type III for low-pressure appliances, and Universal for all of them. The credentials do not expire.

A2L work adds handling skills, not just a card. AHRI’s Safe Refrigerant Transition Task Force, which includes contractors, the fire service, unions and training organizations, publishes a guide with chapters on A2L properties, tools, detectors and servicing A2L systems, along with “Technician Best Practices for A2L Installation and Servicing.” Budget the training hours and any new tools before your first A2L job, not after.

The building code has to allow it too

The International Code Council says approved changes in the 2024 International Building, Residential, Fire and Mechanical Codes allow residential and commercial use of A2L refrigerants, and it offers documents to apply those provisions to the 2021, 2018, 2015 and 2012 editions. Which edition applies, and with what amendments, is your state’s or city’s choice. AHRI keeps an interactive map of where state and local codes have been updated or legislation passed to allow A2L equipment. Check it, and your building department, before you quote your first A2L job.

A short checklist

  • For any new R-410A system: confirm every specified component was made or imported before January 1, 2025, and photograph the labels.
  • For a repair: make sure it stays a repair under 84.54(e), especially on capacity and on whether the other half of the system was already replaced.
  • For A2L equipment: new matched system only, the manufacturer’s instructions, trained techs, tools rated for it, and a local code that allows it.
  • Keep every tech’s Section 608 certification on file, and re-price refrigerant from current cost.

EPA changed the installation rule in 2023 and again in 2026, and it has proposed new conditions for A2L equipment, so check its HFC restrictions and SNAP pages before you rely on any date here. More for HVAC shops is on our HVAC page.

General information, not legal or tax advice. Rules change and vary by state; check with the agency named above or a professional for your situation.

Sources

  1. Technology Transitions: HFC Restrictions by Sector (last updated August 28, 2026), U.S. Environmental Protection Agency (accessed October 20, 2026)
  2. 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, Legal Information Institute, Cornell Law School (text of the Code of Federal Regulations) (accessed October 20, 2026)
  3. Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act of 2020, 91 FR 31284 (May 26, 2026), U.S. Environmental Protection Agency, Federal Register (accessed October 20, 2026)
  4. Frequent Questions on the Phasedown of Hydrofluorocarbons, U.S. Environmental Protection Agency (accessed October 20, 2026)
  5. Technology Transitions Program fact sheet (October 2023 final rule, updated December 2024), U.S. Environmental Protection Agency (accessed October 20, 2026)
  6. SNAP Rule 23: Listing of Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (signed April 2021, prepublication version), U.S. Environmental Protection Agency (accessed October 20, 2026)
  7. Fact Sheet: Proposed SNAP Rule 27 (April 2026), U.S. Environmental Protection Agency (accessed October 20, 2026)
  8. Section 608 Technician Certification Requirements, U.S. Environmental Protection Agency (accessed October 20, 2026)
  9. A2L Refrigerants Transition, International Code Council (accessed October 20, 2026)
  10. Safe Refrigerant Transition Task Force, Air-Conditioning, Heating, and Refrigeration Institute (AHRI) (accessed October 20, 2026)
  11. AHRI Unveils New Interactive A2L Refrigerant Building Code Map and Video Series (January 23, 2024), Air-Conditioning, Heating, and Refrigeration Institute (AHRI) (accessed October 20, 2026)

Where this comes from

Written by the team at Tailgate Office, LLC. Every figure comes from the sources listed above, as of the day each was accessed; prices and rules change without warning. Nothing here is legal, tax or financial advice.

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