The U.S. Environmental Protection Agency (EPA) has designated enforcement of the January 1, 2026, technology transition deadlines set by its 2023 Technology Transitions Rule as a "low enforcement priority." This applies to restrictions on high-global warming potential (GWP) refrigerants such as R-410A in residential and light-commercial HVACR systems, as well as cold-storage and remote condensing unit refrigeration systems. Enforcement resources will focus on compliance with new deadlines to be established through ongoing rule reconsideration. EPA stated that enforcement of these deadlines "is a low enforcement priority for the Agency and EPA intends to focus its resources on compliance with the new compliance dates", according to industry reports. EPA issued this enforcement guidance in December 2025. EPA released its enforcement statement on December 22, 2025 The revised enforcement approach covers cold-storage warehouses (GWP limits of 150/300), remote condensing units, and residential/light-commercial air conditioning and heat pump installations under reconsideration. The EPA memo clarifies that actions relating to requirements under reconsideration must be approved by senior agency enforcement leadership. EPA's internal guardrails require concurrence from senior enforcement leadership for any compliance action during the interim period
Background
The 2023 Technology Transitions Rule, implementing phasedown provisions under the AIM Act, set a January 1, 2026, compliance deadline for new installations using high-GWP hydrofluorocarbons (HFCs) in several HVACR subsectors, including residential and commercial applications. The rule also restricts the manufacture, sale, and import of such equipment from that date. EPA began reconsidering these deadlines in October 2025, proposing delays and higher interim GWP thresholds-for example, raising the GWP limit for cold-storage warehouses to 700 beginning January 1, 2026, with original lower limits reinstated in 2032. EPA's reconsideration proposes increasing cold-storage GWP thresholds to 700 starting January 1, 2026, reverting to 150/300 by January 1, 2032. EPA's enforcement shift provides temporary relief for industry participants during this regulatory transition.
Details
Industry groups, including HARDI (Heating, Air-Conditioning & Refrigeration Distributors International), requested enforcement flexibility until the reconsidered rule is finalized. HARDI CEO Talbot Gee said the shift was "welcome news for distributors and contractors" and noted HARDI had formally requested relief in advance of the final rule. Trade publications reported that EPA would also extend No Action Assurances (NAA) for refrigerated transport containers and standalone chillers under specific thresholds, reducing compliance burdens for essential supply chains. EPA extended NAA for refrigerated transport-intermodal containers and standalone chillers under 100 lbs used in semiconductor manufacturing.
Outlook
Stakeholders should continue planning according to the revised rulemaking timeline and remain prepared for the implementation of new compliance dates. Contractors and planners should notify clients of the enforcement reprieve but advise them to budget and schedule projects with possible stricter deadlines in mind. Equipment manufacturers and distributors should align inventory and training protocols to remain responsive as EPA finalizes new deadlines in 2026.
