An Update on the EPA’s Technology Transitions Program

On Oct. 24, 2023, the U.S. Environmental Protection Agency (EPA) published a final rule restricting the use of high global warming potential (GWP) HFC refrigerants in air conditioning and heat pump products and equipment. These regulations, referred to as the Technology Transitions Program, support the HFC phasedown by forcing a transition to next-generation equipment that does not utilize high-GWP HFC refrigerants. The rule, as originally issued, placed restrictions on both the manufacture and installation of HVAC products and systems beginning on Jan. 1, 2025. 

See Related: What You Need to Know: EPA’s Emissions Reduction and Reclamation Program for HFC Refrigerants

In Dec. 2024, the EPA issued a subsequent final rule addressing technology transitions restrictions on the use of HFCs in the variable refrigerant flow (VRF) air conditioning subsector. The final rule allows VRF equipment with higher-GWP HFC refrigerants that was manufactured or imported prior to Jan. 1, 2026 to be installed until Jan. 1, 2027. This rule also allows VRF equipment that is intended for construction projects that were issued an approved building permit prior to Oct. 5, 2023, to be installed until Jan. 1, 2028.

As a result of this final rule, the new regulations for residential and light commercial air conditioning and heat pump systems have been updated as follows:

• Prohibit the manufacture and import of HVAC products (e.g., window units, portable room air conditioning) with GWPs > 700 on or after Jan. 1, 2025 
• Prohibit the sale, distribution, and export of HVAC products with GWPs > 700 on or after January 1, 2028
  
• Prohibit the manufacture of Residential and Light Commercial HVAC system components for use with a refrigerant having a GWP >700 “for use in a new HVAC system (e.g., mini-splits, unitary systems)” on or after Jan. 1, 2025 
• Prohibit the installation of new Residential and Light Commercial HVAC systems with GWPs >700 on or after Jan. 1, 2026 
• Prohibit the manufacture or import of new Variable Refrigerant Flow HVAC systems with GWPs >700 on or after Jan. 1, 2026
• Prohibit the installation of new Variable Refrigerant Flow HVAC systems with GWPs >700 on or after Jan. 1, 2027
  (Note: VRF equipment that is intended for construction projects that were issued an approved building permit prior to Oct. 5, 2023, may be installed until Jan. 1, 2028.)

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