Refrigerants: Policy Issue

Overview

The U.S. Environmental Protection Agency (EPA) continues to phase down hydrofluorocarbons (HFCs) and facilitate a transition to next-generation A2L refrigerants, under the  American Innovation and Manufacturing (AIM) Act of 2020. In May 2026, the EPA finalized revisions to its Technology Transitions Rule that provide greater flexibility and revised compliance timelines in response to industry concerns. 

refrigerant

For housing providers, these regulations predominantly impact HVAC systems, which constitute the greatest areas of exposure, expense and operational responsibility. This transition aligns with federal and international efforts to phase down HFCs due to negative environmental impact with key dates being: 

  • January 1, 2025: Newly manufactured residential and light commercial HVAC equipment must use next-generation refrigerants, phasing out systems that rely on higher-Global Warming Potential (GWP) Hydrofluorocarbons (HFCs). 

  • Pre-2025 equipment: Under the revised rule, equipment manufactured or imported before January 1, 2025 may now be installed until inventory is exhausted, removing the prior January 1, 2026 installation deadline 

  • July 27, 2026 (effective date): EPA’s finalized rule revisions take effect, formally implementing this added flexibility. 

  • Long-term transition: The phasedown of HFCs and shift to A2L refrigerants remains in place, but with more adaptable timelines for compliance. 

Industry Position

The National Apartment Association (NAA) supports the EPA’s revised approach, which reflects years of industry advocacy to address cost pressures, supply constraints and implementation challenges. Without proper coordination and meaningful industry input, the transition threatened housing affordability and supply without proportional environmental benefit.

As an Owner or Operator, How Does this Affect My Business?

The revised rule reduces some near-term disruption but does not eliminate the broader transition. Housing providers should expect:

  • Improved flexibility: The ability to install pre-2025 equipment avoids stranded inventory and reduces the need for costly redesigns or rushed replacements. 

  • Lower immediate cost pressure: By easing rigid deadlines, the rule helps stabilize HVAC costs and project timelines. 

  • Continued long-term transition: Providers will still need to plan for a gradual shift to newer refrigerants and compatible systems. 

  • Ongoing operational complexity: Training, maintenance practices and equipment planning will continue to evolve as the market transitions. 

Additional Resource

NAA CAMT Refrigerant Bulletin

Contact Information

To learn more about this issue, please contact NAA's Public Policy team.