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What to Know About A2L Refrigerants, From Regulatory Expert Allison Skidd

March 19, 2024
What to Know About A2L Refrigerants, From Regulatory Expert Allison Skidd

The HVAC industry’s switch to A2L refrigerants on January 1, 2025, will be here before we know it.

Here Allison Skidd, Director of Global Regulatory Affairs, explains what to know about A2L refrigerants and the new refrigeration standards, as well as how contractors can prepare.

What is the new refrigerant regulation that goes into effect January 1, 2025? 

On October 24, 2023, the U.S. Environmental Protection Agency (EPA) published the final rule under the American Innovation and Manufacturing Act (AIM) that sets global warming potential (GWP) limits for air conditioning. It sets a GWP limit of 700 for new AC/HP equipment by January 1, 2025 (and January 1, 2026, for variable refrigerant flow HVAC systems).

Packaged equipment needs to comply based on the date the unit was manufactured, and split systems need to comply based on the date that systems are installed. The date of installation compliance was not something we were expecting for AC, and it effectively shortens the time we have to comply because it applies to existing inventory.

For that reason and others, the industry pushed back heavily on the surprise aspects of the final rule. This resulted in EPA amending the final regulation to allow for installation of higher-GWP HFC equipment manufactured or imported before January 1, 2025, to be installed until January 1, 2026.
How will the new regulation shift contractors’ day-to-day work in the field?

Now that we know what to plan for, it will be essential for installers to familiarize themselves with the specifics in order to be compliant. For example, there is a three-year sell through of existing inventory of R-410A packaged products made before 2025. R-410A components—such as an indoor coil, outdoor condensing unit, or air handler—can be manufactured and installed indefinitely as long as they are only used for the service of already-installed equipment.

What can contractors do now to ensure a smooth refrigerant transition?

Between now and the compliance date, installers should be:

    • Familiarizing themselves with the different compliance aspects of the GWP rule as they apply to systems, products, and components.
    • Considering any existing inventory of R-410A equipment and planning to make the switch to A2L to avoid stranded stock.
    • Seeking information and training on the safe handling of A2L refrigerants as offered by manufacturers and trade associations.

Although new certification isn’t required to handle A2L equipment, it is recommended to take advantage of available training and information for this important change.

Is this regulation the final refrigerant transition for the industry, or is there more to come?

Definitely more to come! The EPA, in a different rule, is proposing refrigerant cylinder tracking through its refrigerant management rule, published as a draft on October 6, 2023. The rule proposes that all used disposable cylinders must be sent to a certified reclaimer to recover the heel, starting January 1, 2025. Anyone who purchases, sells, or distributes HFCs must register with the EPA, and QR tracking will be mandatory for the distribution of all HFC cylinders starting January 1, 2027. 


Furthermore, in an attempt to spur recovery of spent refrigerant, the EPA is proposing to require the use of reclaimed refrigerant in all new equipment as well as for all service of equipment starting in 2028. Much more to come on this as the rule goes through further editing.

If that weren’t enough, we still have to keep an eye on states where there is independent activity on refrigerant regulation, despite there now being a national framework. AIM legislation did not preempt states from taking individual action. States such as California, Washington, and New York have finalized or draft rules underway, which differ from federal requirements in some respects. Awareness of the local rules will be critical for installers.
Rheem will continue to update contractors on the latest A2L refrigerant information as January 1, 2025, gets closer. You can also stay up to date on the latest industry changes at