Heating, Air-conditioning, & Refrigeration Distributors International (HARDI) said the U.S. Environmental Protection Agency (EPA) released a statement deprioritizing federal enforcement of the January 1, 2026, installation prohibitions in the Technology Transition Rule Reconsideration. HARDI said the statement signals a shift in how EPA will apply its limited enforcement resources as the law is expected to change.
The Technology Transition Rule, finalized under the American Innovation and Manufacturing (AIM) Act, includes an installation date prohibition that HARDI said has been widely criticized by contractors, distributors, and manufacturers as unworkable and disconnected from how projects are planned, permitted, and built. HARDI said EPA earlier released a proposed rule to repeal the January 1, 2026, prohibition on installing residential and light-commercial air conditioners and heat pumps using R-410A refrigerant, and that the regulatory process is expected to take several months before a final rule is released.
HARDI said EPA’s enforcement discretion applies to federal enforcement and does not repeal or amend the Technology Transition Rule. HARDI said states and local governments retain authority to enforce applicable requirements under state law, building codes, and permitting programs, and that contractors must continue to comply with those obligations; it added the statement reduces the likelihood of EPA-initiated federal enforcement actions related to installation timing during the transition period.
“The EPA recognizes that repeal won’t help the industry until the rule is finalized,” said Alex Ayers, Vice President of Government Affairs for HARDI. HARDI said EPA will focus enforcement on higher-priority violations, including the illegal import of refrigerants and maintaining the R-410A manufacturing prohibition on non-repair components, and that HARDI will continue to urge Congress to provide a permanent legislative fix eliminating all future installation dates set by any agency.
