EPA to “reconsider” refrigerant technology rule – what do you think?
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The Environmental Protection Agency (EPA) has announced the largest deregulatory action in U.S. history, launching 31 initiatives aimed at reducing regulatory burdens and promoting energy independence.
The sweeping reforms, unveiled by EPA Administrator Lee Zeldin, include reconsideration of environmental regulations that impact energy production, vehicle emissions, manufacturing, and small businesses. On the list is “reconsideration” of the AIM Act’s Technology Transitions Rule which bans equipment using higher global warming potential (GWP) refrigerants like R-410A.
Washington, D.C. is often recognized as a “land of interpretation” due to its position as a hub for political discourse, policy debates, and the shaping of national narratives. ACCA is working diligently behind the scenes with our political and regulatory contracts to solidify an accurate interpretation of what this could mean for HVACR contractors.
Here’s what we know
No changes have been implemented yet. The recent announcement is news of what EPA plans to do in the future at this point in time.
Among the most relevant changes for HVACR contractors is the reconsideration of the Technology Transitions Rule, which is a component of the AIM Act, and the phasedown of HFC refrigerants. The rule mandates shifts to specific technologies and refrigerants with lower GWP in HVACR systems. Its ban on the manufacture and import of R-410A equipment for the residential and light commercial market took effect January 1, 2025.
It is debatable whether EPA is using “reconsideration” in the plain-English sense of reconsidering the rule altogether vs. the more technical sense of granting the “reconsideration” sought in a specific petition by AHRI, HARDI, and the Alliance for Responsible Atmospheric Policy. The EPA statement’s reference to “increased costs on food at grocery stores and semiconductor manufacturing” also suggests that it may address a pending lawsuit filed by grocery trade associations, but not a wholesale reconsideration of the overall rule.
The agency argues that these changes will lower costs for American families, stimulate job growth, and restore state authority over environmental policies.
Here’s how you can weigh in
ACCA’s Contractor Town Hall at ACCA 2025 and related online surveys will ask contractors to weigh the pros and cons of three possible options for the Technology Transitions Rule:
1. Anything goes: While deregulation often reduces compliance costs, there are concerns about the unintended consequences of rolling back this rule altogether. The phasedown of HFC supply, enacted in President Trump’s first term, is unlikely to change, so major manufacturers are unlikely to resume manufacturing R-410A equipment for the residential and light commercial market. The likely emergence of off-brand R-410A equipment could create market instability. Contractors committed to major brands may find unwelcome competition from lower-priced alternatives. Contractors who embrace those alternatives could find market opportunities, but customer relationships could suffer as the cost of HFCs to service relatively-new equipment skyrockets.
2. Adjusting future deadlines: Compliance deadlines for various subsectors of the commercial, industrial, and refrigeration markets are scheduled between 2026 and 2028. Changes to future deadlines are less likely to create market instability; ACCA is eager to hear from contractors who serve those markets about what specific changes would provide needed relief for their businesses.
3. Stay the course: While regulatory relief is appealing, it’s important to remember that the supply of HFCs is capped under the AIM Act. The continued availability of new HFC equipment in a few subsectors will exacerbate price and availability concerns impacting the HFCs needed to service existing equipment in all market segments, including residential. In the absence of federal preemption, further delays may also encourage some states to implement a patchwork of their own regulations. Federal preemption refers to federal law taking precedence over conflicting state or local laws. ACCA was a strong supporter of federal preemption in the original AIM Act, believing that a unified approach was necessary throughout the U.S. to ensure the introduction of A2L refrigerants was carried out safely. Federal preemption, however, was not included in the AIM Act despite ACCA’s input.
Join us at the Contractor Town Hall at ACCA 2025 on Thursday, March 27, from 7:15 – 9:15 AM to share your insights, discuss industry challenges, and help guide ACCA’s policy priorities.
Can’t make it? Click here to review our discussion draft, submit a video comment, or comment on the recent Contractor Forum posts about each HVACR priority. Or you can always send us your thoughts at govt@acca.org—your voice makes a difference.
ACCA’s commitment
The Air Conditioning Contractors of America (ACCA) is dedicated to supporting its members through these challenging times. We are closely monitoring the situation and will provide updates and resources to help contractors navigate the evolving political and regulatory landscape. Our mission is to equip HVACR contractors and their teams to meet pressing challenges and opportunities, and we will continue to advocate on behalf of contractors.
ACCA works hard to advocate behind the scenes on behalf of contractors; but we can’t do it alone. ACCA membership dues power our advocacy efforts and enable us to advance contractor interests so that contractors can keep their focus on doing what they do best: running successful, impactful businesses.
Thanks to our members for supporting this vital work.
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Posted In: A2Ls, Government, Refrigerants, Regulation Reform
