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The A2L Transition at 20 Months: Manufacturing Settled, Service Not

Two outdoor condensing units of different ages side by side against a house wall

Last reviewed: August 2026 · By the HVAC Brief Editorial Team · Our sourcing and editorial standards

Status report

Twenty months into the A2L transition, the manufacturing side is settled and the service side is not. New residential equipment moved to R-454B and similar blends on January 1, 2025. The installed base is still overwhelmingly R-410A, and will be for years. What that installed base costs to service depends on supply, and three federal actions in six weeks pushed the same way, which we tracked in refrigerant supply constraints. The certified product list now gives a count of the transition: our analysis of 285,055 ENERGY STAR heat pumps by refrigerant shows R-454B dominant in ducted systems and the three refrigerants close in mini splits.

What changed most recently is the installation rule: EPA removed the cutoff on pre-2025 inventory effective July 27, 2026, so both refrigerants are being installed simultaneously.

Where each piece stands

Element Status
New residential equipment manufacture Must be under 700 GWP since January 1, 2025
Installing pre-2025 R-410A inventory Permitted federally, no end date, since July 27, 2026
Servicing existing R-410A systems Legal, using produced or reclaimed refrigerant
EPA 608 certification Unchanged. No A2L-specific federal certification exists
Refrigerant supply Capped at 60% of baseline, dropping to 30% in 2029
Trade measures on imported refrigerant Antidumping orders on HFC blends and R-32 maintained in 2026

The gap nobody legislated

EPA Section 608 requirements did not change when the refrigerants did. A technician certified in 2015 holds a valid certification that says nothing about A2L handling, storage or tooling. The regulatory framework treats certification as current while the field material has changed underneath it.

That is not a compliance failure, it is a training gap, and it sits with employers rather than with the certification scheme. See what 608 actually covers and what A2L changes in practice.

Both refrigerants, same van

Because pre-2025 inventory remains installable with no federal end date, a contractor can be installing R-454B on Monday and R-410A on Tuesday. That means A2L-rated tooling and recovery equipment alongside the existing kit, not instead of it, for as long as the inventory lasts.

Frequently asked questions

Where does the A2L transition stand in 2026?

New residential equipment has been under the 700 GWP limit since January 1, 2025, so it ships with R-454B or similar. Pre-2025 R-410A inventory remains installable federally with no end date after an EPA rule effective July 27, 2026. The installed base is still overwhelmingly R-410A.

Do technicians need new certification for A2L?

No federal A2L-specific certification exists. EPA Section 608 requirements were unchanged by the transition, so an existing certification remains valid. The gap is training rather than certification, and it sits with employers.

Can contractors install both R-410A and R-454B equipment?

Yes. Pre-2025 R-410A inventory remains installable federally with no end date, while new equipment ships with A2L refrigerant. That means carrying A2L-rated tooling and recovery equipment alongside existing kit rather than replacing it.

Sources

  1. 40 CFR 84.54 and EPA final rule 91 FR 31284, effective July 27, 2026; 40 CFR 84.7 phasedown schedule.
  2. 40 CFR 82.161, technician certification.
  3. US Department of Commerce, 91 FR 48079 and 91 FR 51658, antidumping proceedings.

The HVAC Brief is an independent trade publication. We do not sell equipment, take manufacturer advertising, or accept payment for placement in our research. Corrections welcome.

Comments

2 responses to “The A2L Transition at 20 Months: Manufacturing Settled, Service Not”

  1. […] The same rules make R-290 look good on paper. Since January 1, 2025, new self-contained residential AC and heat pump products cannot use an HFC with a GWP of 700 or more, and the GWP table in 40 CFR 84.64 lists propane at 3.3. What limits R-290 is the SNAP listing scope and the charge caps, not a phase-out. For where the A2L switch stands, see our A2L transition status report. […]

  2. […] be installed under 84.54(c)(1), as our reading of the R-410A installation rule explains, and our A2L transition status report tracks the service side. We found no US rule in 40 CFR Parts 82 or 84 that bans R-32 in home […]

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