The U.S. Environmental Protection Agency (EPA) has announced that enforcement of the January 1, 2026 technology transition deadlines under the Technology Transitions Rule is a low priority while the agency finalizes revised compliance dates through ongoing reconsideration rulemaking. Until any formal change, the original deadlines remain in effect. The EPA's statement applies specifically to installation restrictions under Subpart B, covering residential and light-commercial air conditioning, heat pumps, remote condensing units, and cold storage systems. Enforcement discretion does not apply to leak repair requirements under Subpart C, which continue to be fully enforceable.
Background
The Technology Transitions Rule, adopted in October 2023 under the AIM Act, restricts high-global-warming-potential (high-GWP) HFC refrigerants in multiple sectors. The current enforcement delay concerns key installation deadlines set for January 1, 2026.
In December 2024 and 2025, the EPA extended some deadlines: installation deadlines for variable refrigerant flow (VRF) systems moved to January 1, 2027, with certain projects eligible through January 1, 2028. For cold storage warehouses, a higher GWP threshold of 700 applies, delaying stricter limits until January 1, 2032. These adjustments and the revised enforcement approach are part of the rule's reconsideration process.
Details
On December 22, 2025, the EPA clarified that, although statutory requirements remain unchanged, the agency will not actively seek federal-level enforcement of Subpart B installation restrictions during the rulemaking period. Industry groups such as HARDI welcomed this, citing clarity for distributors and contractors. Feedback from organizations including Rheem requested that the EPA provide no-action assurances bridging the interval between the original deadline and the final rule. According to ACHR News, Rheem's regulatory affairs director highlighted the necessity of enforcement guidance to prevent stranded inventory.
Contractor associations like ACCA noted that while enforcement discretion offers temporary relief, noncompliance still poses legal risks if misapplied. Experts also warned that compliance challenges may shift to state and local jurisdictions, where stricter rules could be implemented.
Outlook
EPA is expected to finalize the revised Technology Transitions Rule in the second quarter of 2026. New compliance dates and GWP thresholds will become enforceable following issuance. Contractors and manufacturers must ensure documentation demonstrates that equipment was legally manufactured or imported before the relevant deadlines. Enforcement discretion may be rescinded if violations become serious or intentional.
