Can You Still Install R-410A? EPA 2026 Rule on Pre-2025 Units

What the 2026 rule changed, with dates

The rule is titled Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the AIM Act, published in the Federal Register at 91 FR 31284. For residential and light commercial air conditioners and heat pumps, the change that matters is this: it removed the deadline for installing systems whose components were made in or imported into the U.S. before January 1, 2025.

The amended regulation, 40 CFR 84.54(c)(1), now says a new system using refrigerant at or above 700 GWP may still be installed where all specified components of that system were manufactured or imported before January 1, 2025. Specified components are condensing units, condensers, compressors, evaporator units and evaporators. EPA's GWP reference table lists R-410A at 2,088, R-454B at 465 and HFC-32 (R-32) at 675.

What did not change:

• The 700 limit itself. EPA says installing new R-410A systems with equipment made or imported after January 1, 2025 remains prohibited.
• Equipment made in Canada or Mexico before 2025 but imported after January 1, 2025 doesn't qualify, per EPA's response to comments.
• The treatment of replacement condensing units. EPA left those rules as they were.
• Variable refrigerant flow systems, which have their own dates: equipment made or imported before January 1, 2026 may be installed until January 1, 2027, or until January 1, 2028 for projects with a building permit issued before October 5, 2023 (EPA).

One caution: some answers on EPA's Frequent Questions page (last updated September 14, 2026, when we read it on October 4, 2026) still describe the old January 1, 2026 cutoff for new split systems. The amended regulation text above is what changed; when the two disagree, go by the rule and ask EPA.

Job by job: repair or new system?

The whole question turns on whether the job is a repair of an existing system or the installation of a new one.

A new system may use R-410A only if every specified component is pre-2025 U.S. stock. Otherwise it needs refrigerant under 700 GWP.

For repairs, R-410A condensing units and coils can still be manufactured, imported and sold. Units made or imported after January 1, 2025 must carry a permanent label reading "For servicing existing equipment only" (40 CFR 84.58(b)). Pre-2025 inventory doesn't need relabeling, EPA says.

The capacity point is easy to miss on a replacement. If a tech wants to go up a size on the outdoor unit, the regulation treats the capacity increase as a new installation, so the new-system rules apply.

The New York exception

New York regulates HFCs under its own rule, 6 NYCRR Part 494, amended effective January 9, 2025. DEC's Part 494 fact sheet sets a 700 GWP limit for residential and light commercial AC and heat pumps (including residential dehumidifiers), with a New York prohibition date of January 1, 2026.

DEC's Part 494 FAQ, updated May 2026, says Part 494 adopts federal rules only as they stood on its effective date. Later federal changes, extensions, no-action assurances and other EPA decisions are not carried over automatically; you have to go to DEC, for example with a variance application under 494-1.8. So unless an exemption or variance applies, EPA's pre-2025 inventory allowance does not make a new R-410A system installable in New York after January 1, 2026.

Other points from the DEC FAQ:

• A building permit issued before January 9, 2025 that specifies the refrigerant extends the 2025 and 2026 prohibitions by one year to finish that project (494-1.5).
• Using and servicing a legally installed system isn't prohibited, but retrofits, capacity increases and component replacements can make equipment count as new.
• From 2030, DEC prohibits buying and selling bulk containers of virgin refrigerant with a GWP above 1,500, and lists R-410A as an example. The container rule doesn't apply to servicing equipment, though servicers may buy or sell virgin bulk refrigerant only as part of a service repair.

Other states can have their own HFC rules. Check with your state environmental agency before quoting a pre-2025 R-410A system outside the federal baseline.

What to ask your distributor

1. What are the manufacture dates, or U.S. import dates, of the condensing unit and the matching coil or air handler? Get them in writing, by serial number.
2. Was this equipment in U.S. inventory before January 1, 2025, or imported later from Canada or Mexico?
3. Does either component carry the label for servicing existing equipment only? If so, it is repair stock, not a new-system component.
4. How does the manufacturer handle warranty registration and coverage for pre-2025 units installed now?
5. What does R-410A refrigerant cost today, and what supply do you expect? The AIM Act caps total U.S. HFC production and consumption at 60% of baseline for 2024–2028, 30% for 2029–2033, 20% for 2034–2035 and 15% from 2036 on (42 U.S.C. 7675). Those caps cover all HFCs together, not R-410A alone.
6. What R-454B or R-32 equipment and refrigerant can you supply for the same job? EPA's preamble notes R-454B was hard to get in service cylinders in some regions in 2025.

EPA's FAQ says the company that installs, or directs the installation of, a system is generally the responsible party. That's you, so the paper trail belongs in your job file, not just the distributor's.

How to quote it

• Name the job type on the estimate. Repair: replacement condensing unit on existing R-410A system reads very differently from New system: R-410A, all components manufactured or imported before January 1, 2025, and each tells the customer and any inspector what rule you relied on.
• List the component dates or serials for any pre-2025 new system, and attach the distributor's confirmation.
• Offer the A2L system alongside whenever a whole system is going in, so the customer chooses with both prices in front of them.
• Keep the expiry short. EPA describes the qualifying stock as finite and decreasing, and the exact unit you quoted may be gone next week.
• Price it the same way as any job: labor hours at your shop's rate plus equipment and parts at your markup. The flat-rate price calculator and markup vs margin guide cover the math; price the refrigerant charge at today's replacement cost, not last year's invoice.
• Use a written estimate with scope and exclusions. Our estimate checklist applies to HVAC jobs as well.

This is general information, not legal advice. For a specific job, ask EPA through the Contact Us About Reducing HFCs form on its HFC pages, or in New York ask DEC at climate.regs@dec.ny.gov.

Bottom line

Under the federal rule, and outside New York, pre-2025 R-410A inventory can be installed as a new system with no end date, as long as every major component is pre-2025 U.S. stock and you can show it. Condensing-unit repairs on existing R-410A systems were never banned and still aren't. Everything else that counts as a new system, including a capacity increase, needs refrigerant under 700 GWP. Check your own state's rules, write down which case each job is, and price it from your own numbers.