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How does the EPA Technology Transition Rule impact the HVAC industry, and what are the key considerations for HVAC professionals?

The EPA Technology Transition Rule stands as a transformative force in the HVAC industry, primarily driven by environmental concerns and the imperative to reduce the ecological footprint of refrigeration and cooling systems.

Key considerations of this rule include: 

1. Product vs. System Differentiation: 

The rule makes a critical distinction between "products" manufactured in a plant and "systems" assembled in the field. The date of refrigerant charging in the field is deemed the "manufactured" date for a system. 

2. Specified Components: 

Encompassing condensing units, condensers, compressors, evaporator units, and evaporators, the rule regulates specified components. Notably, there is no specified end date for the use of these components. Understanding the compliance measures, such as labeling for specified components installed after the compliance dates, is crucial. An R410A specified component must be labeled with “For servicing existing equipment only” if it is installed after the compliance dates listed in the rule. 

3. Who Is Affected? 

The scope of the EPA Technology Transition Rule extends to anyone involved in assembling, contracting, owning, or operating HVAC systems. Notably, compliance responsibility for split systems lies with the entity in the field, emphasizing the importance of on-site adherence to regulatory standards. 

4. Global Warming Potential (GWP) Limits: 

A cornerstone of the rule is the enforcement of stringent GWP limits for various HVAC sectors. Compliance deadlines include: 

  • Beginning 1/1/2025: GWP must be less than 700 for residential and commercial air conditioners, heat pumps, and chillers.  Split systems must be manufactured by this date, while field refrigerant charge needs to be completed by 1/1/2026. 
  • Beginning 1/1/2026: GWP must be less than 700 for Variable Refrigerant Flow (VRF) systems.  VRF systems must be field charged by this date. 
  • Beginning 1/1/2027: GWP must be less than 700 for data centers. Split systems must be field charged by this date. 

5. Canadian Impact: 

The influence of the rule extends beyond U.S. borders, particularly affecting the Canadian HVAC market. Challenges include the potential allowance of commercial A2L products, the prohibition of building R410A equipment for export, and anticipated updates to Canadian building codes. 

Preparing for the Transition: 

In summary, the EPA Technology Transition Rule mandates a paradigm shift in the HVAC industry. Compliance with GWP limits is paramount, and understanding the differentiation between products and systems is crucial. Staying informed about the rule's provisions, including its impact on the Canadian market, will be instrumental in navigating this transition successfully. 

Access the full ruling here