2025 HVAC Regulations
Overview
In late 2023, the EPA released their final ruling for the Technology Transition Program spelled out in the AIM Act. This ruling will specify the new requirements for installing new HVAC equipment with an A2l Refrigerant, R-32 or R-454B, and servicing existing systems with R-410A or R-22 in the field. A breakdown of the final ruling and how it applies to different product categories is listed below.
Requirement | Packaged Units | Split Systems |
GWP | 700 | 700 |
RNC Date | 1/1/2025 Date of Manufacture or Import | 1/1/2025 Date of Manufacture or Import |
AOR New Systems Date | 1/1/2025 Date of Manufacture | 1/1/2025 Date of Manufacture or Import |
AOR Service Restrictions | Parts Only | Parts + Complete R410AOutdoor Unit |
R-410A Inventory Sell-Through | Three-Year | One-Year (New) Indefinite (Service) |
HVAC Systems | HVAC Products |
Definition | |
Any HVAC Equipment where its major components are sold by the manufacturer, assembled into a system, and charged in the field. Examples: Split Air Conditioners, Split Heat Pumps matched with Air Handlers, Evaporator Coils over Furnace, etc. | Any HVAC Equipment where all its components are installed, and the unit is charged by the manufacturer. These units only require power or water to be connected in the field during installation. Examples: SPP (Small Package Products) Units and Light Commercial Rooftop Units. |
Timing: Last Date of Install or Manufacture for R-410A | |
December 31, 2024, will be the last date of manufacture or import of new R-410A equipment.
| December 31, 2024, will be the last date of manufacture or import of new R-410A equipment.
|
Existing R-410A Service Methodology | |
Individual components of the system including the condenser, air handler, and evaporator coil, can be changed out with compatible components. The entire system (i.e., indoor unit and outdoor unit) cannot be changed out at the same time for service utilizing R-410A or R-22 products. | Individual components of a product may be changed out for like parts designed for R-410A. Entire products cannot be changed out for service with new R-410A products. |
Frequently Asked Questions
"What is considered an HVAC System in this final EPA Ruling?"
- An HVAC System consists of all parts necessary for a split air conditioner or heat pump system to operate. That means all condenser coils, compressors, expansion devices, and evaporator coils. Anything less than a total system is considered a specified component.
“Is my indoor unit or outdoor unit considered a system all by itself?”
- No, although a complete unit assembly is shipped from the manufacturer, these units need additional components to be installed on site to fully operate. Therefore, they are considered as components of a system.
“What is considered the date of install of a system?”
- The date of install will be considered as the day in which the system was assembled and charged for operation on site.
“When is the last date that I can install new systems containing R-410A equipment?”
- December 31, 2025 will be the last day that a new system containing R-410A can be installed.
“Can an R-410A system be serviced after December 31, 2024?”
- Yes, any component of an R-410A system including a complete indoor or a complete outdoor unit can be serviced at any time as long as the entire system is not replaced.
“Can all components of an R-410A system be replaced at one time?”
- No. If all the components of an R-410A system need to be replaced at one time, then the system is considered a new installation and must contain a low GWP refrigerant.
“Can the capacity of an R-410A system be increased via service after January 1, 2025?”
- Any service that would increase the capacity of the system greater than the original design would be considered changing the system to a new system and would require the use of low GWP refrigerants.
“Will R-410A indoor or outdoor units be available after January 1, 2025?”
- Yes, R-410A indoor and outdoor units will be available for the servicing of existing systems in the field. These systems will be marked “for service only” and they cannot be used on new installations.
“Who is responsible for ensuring that new systems will be installed using low GWP refrigerants after January 1, 2025?”
- The party or parties responsible for the installation and charging of the system will be responsible for ensuring the system is designed with equipment using low GWP refrigerants.
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