New Year, New Deadlines: Does Your HVAC And Other Refrigerant-containing Equipment Comply With EPA's New January Requirements?

On January 1, 2026, owners, operators, installers, servicers, recyclers, reclaimers, and disposers of appliances containing hydrofluorocarbons ("HFCs") became subject to new requirements under two programs implementing the American Innovation and Manufacturing ("AIM") Act: the Emissions Reduction and Reclamation ("ER&R") Program and the Technology Transitions Program.

HFCs are chemicals widely used as substitutes for ozone-depleting substances in commercial and industrial refrigeration, air conditioning, heat pumps, aerosols, fire suppression systems, and foam blowing. Because HFCs are greenhouse gases with high global warming potential ("GWP"), the AIM Act authorizes the U.S. Environmental Protection Agency ("EPA") to regulate HFCs through a phasedown of production and consumption, enhanced management practices, and restrictions on use to facilitate the transition to next generation technologies.

While importers and manufacturers have been subject to other AIM Act requirements for some time, as of January 1, 2026, end-users are also subject to prohibitions and operating requirements under the ER&R Program and Technology Transitions Program. While EPA has proposed to extend some compliance deadlines for process refrigeration and semiconductor chillers, retail food and supermarket refrigeration, cold storage warehouses, and laboratory equipment, 90 Fed. Reg. 47999 (Oct. 3, 2025), other deadlines affecting commercial and industrial operations with common equipment like chillers and HVAC will remain in place. EPA's proposed extensions are not final; current deadlines remain in effect unless and until EPA finalizes changes.Requirements under the ER&R Program and Technology Transitions Program apply to the ongoing operation of certain existing equipment, as well as impose prohibitions on the installation of certain new equipment.

Emissions Reduction and Reclamation Program

On October 11, 2024, EPA adopted the ER&R Program for the management of HFCs, which imposes requirements related to leak detection and repair, use of reclaimed and recycled HFCs, HFC recovery, and tracking and recordkeeping. The ER&R Program affects manufacturing industries, electric generators, data centers and warehouses, and other sectors that use equipment that relies on HFCs or substitutes (e.g., substances used as a refrigerant or fire suppressant, which are not regulated HFCs or ozone-depleting substances).

The purpose of the program is to maximize reclamation of HFCs, minimize releases of HFCs from equipment, and ensure the safety of technicians and consumers.

Leak Repair

The ER&R Program implements leak repair and retrofit requirements for refrigerant-containing appliances containing 15 pounds or more of a refrigerant containing an HFC or substitute with a GWP above 53.

The Program provides exemptions for appliances containing solely ozone-depleting substances as refrigerants (e.g., CFCs, HCFCs, and halons) and appliances used for residential and light commercial air conditioning and heat pump subsectors. In the preamble text accompanying the final ER&R regulation, EPA indicated that light commercial and heat pump end-uses include: equipment that cools enclosed spaces in commercial premises (excluding chillers), such as window units, packaged terminal air conditioners and heat pumps, and portable air conditioners; central air conditioners (i.e., ducted); non-ducted systems (both mini and multi splits); packaged rooftop units; and water-source and ground-source heat pumps. 89 Fed. Reg. 82682, 82718 (Oct. 11, 2024). However, the regulatory text does not contain a definition for "residential and light commercial air conditioning and heat pump subsectors."

Operators subject to these requirements will be required to calculate the leak rate every time refrigerant is added to an appliance (with exemptions for retrofits, installations of new appliances, and seasonal variances). Operators also must repair leaks within 30 days (or 120 days if an industrial process shutdown is required) and confirm the repair using verification tests. Thereafter, repaired appliances would be subject to periodic leak inspections. Chronically leaking appliances found to be leaking 125 percent of their full charge within a calendar year would be subject to additional reporting requirements. For appliances where successful leak repair cannot be achieved and verified, the ER&R Program requires operators to prepare a retrofit and retirement plan.

Mandatory Use of Automatic Leak Detection Systems

The ER&R Program also implements automatic leak detection ("ALD") requirements for new and existing industrial process refrigeration and commercial refrigeration appliances containing 1,500 pounds or more of a refrigerant containing an HFC or substitute with a GWP above 53. Refrigerant-containing appliances installed on or after January 1, 2026 will be required to install an ALD system upon installation or within 30 days starting January 1, 2026, and existing appliances installed between January 1, 2017 and January 1, 2026 will have until January 1, 2027, to install an ALD.

Reporting Reclaimed Refrigerants

Effective January 1, 2026, refrigerant exceeding a limit of 15 percent by weight on the amount of virgin HFC refrigerants cannot be sold, identified, or reported as being reclaimed. Reclaimers were required to comply with this requirement and clearly label their compliance with this requirement starting January 1, 2026.

Requirements for Fire Suppression Equipment

The ER&R Program includes several provisions specific to fire suppression equipment that became applicable on January 1, 2026, including the following:

• Prevention of Releases: Any person installing, servicing, repairing, or disposing of fire suppression equipment, as well as owners and operators of fire suppression equipment, will be prohibited from releasing HFCs from this equipment, including as a result of maintenance failures. Releases will be permitted only in limited circumstances related to testing of fire suppression equipment, qualification and development testing, and emergency releases.
• Use of Recycled HFCs in Existing Equipment: Existing fire suppression equipment will be required to be serviced or repaired with recycled HFCs.
• Technician Training: The Program requires operators to provide training regarding HFC emissions reduction to any fire suppression technicians, starting January 1, 2026. For technicians hired on or before January 1, 2026, training must be conducted by June 1, 2026. For technicians hired after January 1, 2026, training shall be conducted within 30 days of hiring or by June 1, 2026, whichever is later.
• HFC Recovery Prior to Disposal: The Program requires operators to recover, recycle, or destroy HFCs from fire suppression equipment prior to the final step of the equipment disposal.

Additional reporting and usage requirements will continue to phase in during 2027, 2028, and 2030.

Summary of Key ER&R Deadlines

Technology Transitions Program

Those installing new equipment that use a regulated HFC should be aware of compliance requirements under the Technology Transitions Program that became effective January 1, 2026. The Technology Transitions Program prohibits new installation of equipment in certain sectors containing or using high GWP HFCs, including manufacturing industries, electric generators, and wholesalers. The installation prohibitions apply to new systems only; existing systems may continue operating.

In the final rule adopting the program, EPA indicated that the installation requirements apply to any person who assembles, contracts for, takes ownership of, or operates a system that is installed in certain sectors. See 88 Fed. Reg. 73098, 73120 (Oct. 24, 2023). The requirements do not apply to equipment that existed in the U.S. prior to December 27, 2020.

Upcoming Deadlines for Light Commercial AC/ Heat Pumps

Variable refrigerant flow systems used as light commercial AC or heat pumps, using aregulated substance with a GWP equal or greater than 700may be installed prior to January 1, 2027, where all specified components of thatsystem were manufactured or imported prior to January 1, 2026. When an approved building permit, which specifies the use of a restricted regulated substance, was issued prior to October 5, 2023, and all components of the variable refrigerant flow system were manufactured or imported prior to January 1, 2026, EPA extended the deadline for compliance with the prohibition until January 1, 2028.

Additional Deadlines and Proposed Extensions

There are additional upcoming deadlines prohibiting installation of certain systems, including for chillers industrial process refrigeration, cold storage warehouse systems, data centers, and supermarket systems, which are listed under 40 CFR § 84.54(c). Several of these deadlines may be impacted by EPA's proposed rule issued on October 3, 2025. The proposal seeks to adjust compliance requirements and extend deadlines affecting industrial process refrigeration and semiconductor chillers, retail food refrigeration, supermarket refrigeration systems, cold storage warehouses, and laboratory equipment. See 90 Fed. Reg. 47999 (Oct. 3, 2025).

As part of this proposed rule, EPA is considering removal of the installation deadline for systems in the residential and light commercial air conditioning and heat pump subsector with a GWP higher than 700, including unitary split systems (e.g., ducted and non-ducted mini-splits, multi-splits, and ducted air conditioners and heat pumps), where all specified components of such systems were manufactured or imported prior to January 1, 2025. See 90 Fed. Reg. at 48014. Currently, the compliance deadline is January 1, 2026, as the proposed rule has not yet been finalized.

EPA has stated that enforcement of the original deadlines for sectors undergoing reconsideration under the Technology Transitions rule is a "low enforcement priority" for the Agency until the modifications are finalized.

Conclusion

End-users that rely on HFC-containing equipment should closely examine the new compliance deadlines under the ER&R Program and Technology Transitions Program. These requirements could increase operational costs and introduce compliance risks. Existing end-users should review the requirements under the ER&R Program and evaluate their systems and develop comprehensive compliance strategies. Those installing new systems should review the compliance requirements under the Technology Transitions Program and stay informed about EPA's proposed rulemakings that may adjust certain deadlines under the Program. Taking proactive measures now will help mitigate risk and ensure operational continuity in a rapidly evolving regulatory landscape.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.