EPA has issued a formal enforcement statement clarifying how it will approach the January 1 installation deadline for R-410A equipment in residential and light commercial applications.
While the agency plans to extend compliance deadlines through its ongoing “TT Rule Reconsideration” rulemaking, EPA emphasized that existing deadlines technically remain in effect until officially changed. Finalizing the rule will likely take several months, and legal challenges could delay it further. That said, EPA granted ACCA’s request by stating that enforcement of the current deadlines covered by the reconsideration is a low enforcement priority, and agency resources will instead focus on compliance with new deadlines once the rulemaking is finalized.
EPA also outlined internal guardrails on enforcement activity during this interim period. Any enforcement or compliance assurance action related to requirements under reconsideration must receive concurrence from senior enforcement leadership, consistent with EPA’s March 12, 2025, enforcement memo aligning agency actions with broader executive and agency priorities.
What this means
EPA’s shift in enforcement priorities provides relief for existing inventory of R-410A systems with components manufactured before January 1, 2025. This applies to residential and light commercial air conditioners and heat pump systems, along with other equipment specified in EPA’s proposed rule reconsideration.
It should be noted that the January 1, 2026, installation deadline remains in effect in New York State, where state regulation Part 494 provides a backstop to changes in the federal rules. ACCA supports both state efforts to repeal New York’s rule and federal preemption to prevent states from creating a patchwork of refrigerant regulations.
Boykin Air 