Equipment Transitions & Restrictions: The Technology Transition’s final rule restricts the manufacture and installation of certain refrigeration, air conditioning, and heat pump (RACHP) products. This rule allows for equipment with high GWP refrigerants, manufactured before January 1, 2025, to be installed until January 1, 2026. This ruling affects all regions. Along with these restrictions, certain HVAC products have been regrouped into three new classifications.
There are now three classifications of HVAC systems: Products, Systems & Components
Products: A product is functional upon leaving a factory. A product is a type of appliance with a sealed refrigerant loop that simply needs to be plugged in, mounted, or hooked to a water line to work. For example, window air conditioning units, residential dehumidifiers, packaged terminal air conditioners, commercial freezers, and vending machines are examples of products. If you need a heating, ventilation, and air conditioning technician to assemble and/or charge with refrigerant, it’s not a product. EPA is restricting the sale, distribution, and export of products containing higher-GWP HFCs three years after the manufacture/import restriction dates. Products will have a sell-through for three years until January 1, 2028.
Systems: A system is assembled from multiple components and charged on site. A system for purposes of the Technology Transitions Program is an assemblage of separate components constituting the refrigerant loop that typically are connected and charged with refrigerant in the field. If you need a heating, ventilation, and air conditioning technician to assemble and/or charge with refrigerant, it’s a system. Examples include supermarkets with centralized compressor rooms and mini-split air conditioners. Systems will have an installation deadline of January 1, 2026.
Components:
Components are described as pieces of equipment that must be assembled into a larger system to function. For purposes of the Technology Transitions Program, five components are specifically identified: compressors, condensing units or condensers, and evaporator units or evaporators. EPA does not restrict the manufacture, import, sale, distribution, or export of components that are used to repair existing RACHP systems.
New Products & Mitigation: Because of the low flammability of A2L refrigerants, equipment manufacturers will be re-designing their (RACHP) systems based around mitigation requirements. Mitigation is now required in the event of a refrigerant leak. To meet these new requirements, manufacturers will design their systems with added mitigation leak detection systems including leak sensors, control boards, and intrinsically safe electrical components.
How do these new systems work to mitigate refrigerant leaks? Although the new A2L refrigerants are difficult to ignite, mitigation is still needed. The new leak sensors and controls boards will work together to shut down the system in case of a refrigerant leak. If a leak is detected, the sensor will communicate with the controls board to shut down the system and turn on the blower to dissipate any refrigerant while the sensors notify the homeowner. The leak sensors will be in the indoor coil cabinet while the mitigation board will be installed in the furnace. Mitigation components will be factory installed on new A2L refrigerant equipment, but field installed mitigation equipment will be available.
Refrigerant Change & Your Equipment: With the new Technology Transition Rule, the EPA has designated that refrigerants must phase down the use of Hydrofluorocarbons (HFCs) to meet the new GWP (Global Warming Potential) level. To reduce HFCs, the EPA has designated that refrigerants must meet a new GWP (Global Warming Potential) of 700. The current refrigerant R-410A has a GWP of 2088 and does not meet the new GWP level.
What are HFCs or Hydrofluorocarbons? What is GWP or Global Warming Potential?
Hydrofluorocarbons (HFCs) are potent greenhouse gasses developed and manufactured as a replacement for ozone-depleting substances. The environmental impact of these hydrofluorocarbons is measured its Global Warming Potential (GWP).
In response to the new GWP requirements, two new refrigerants with lower than 700 GWP will take R-410A’s place for new manufactured HVAC equipment. The new refrigerant options are R-454B and R-32. See the table below for more information:
