HVAC Regulations 2025-2026: Opportunities for OEMs – Part 1

What are the key changes to the new HVAC regulation?

The Heating, Ventilation, and Air Conditioning (HVAC) industry is still going through its significant regulatory shift in decades, and for Original Equipment Manufacturers (OEMs), and contractors, it means keeping up with the changes. It means rethinking product lines, redesigning controls, and building supply chains that can match the shifting federal mandates.

As of January 1, 2026, per the Environmental Protection Agency (EPA) regulations under the American Innovation and Manufacturing  (AIM) Act, cooling systems using R-410A can no longer be installed. Any new system must be equipped with an approved low GWP alternative. This change affects every layer of the supply chain, from product design to installation.

But why is the R-410A being replaced? It all boils down to its high global warming potential or GWP[1].  We’re now shifting to low Global Warming Potential (GPW) refrigerants such as the new A2L refrigerants: R-32 and R-454B. These are the chosen alternatives that help reduce environmental impact. The A2L classification means low toxicity and mild flammability. Compared to older refrigerants, A2L refrigerants have additional safety. And because of this, manufacturers are expected to redesign control systems that include:

• Refrigerant leak detection sensors
• Safety shutdown mechanisms
• Monitoring and alarm systems

What does this new regulation mean for everyone involved? That’s a good question, because the more we understand, the more we learn to gain from that knowledge. Here’s what you need to know:

The New HVAC Regulations: What You Need to Know

The regulation driving these changes is the AIM Act of 2020. It authorized EPA to phase down the production and use of hydrofluorocarbons (HFCs), a class of refrigerants that are known for their outsized contribution to global warming. HFCs like R-410A are potent greenhouse gases. Under the AIM Act’s Technology Transitions Program, EPA set binding compliance dates that the entire HVAC industry is now required to meet.

This regulation impacts your business if your products serve single-family homes, multi-unit residential buildings, or large commercial facilities that use R-410A or other high-GWP refrigerants. In line with this, the following key dates are important to keep in mind for everyone involved in designing, manufacturing, and supplying HVAC equipment, from residential ERV/HRV and heat pump systems to commercial ventilation units and building automation controls:

• January 1, 2025 – manufacturing phase-out begins for new high GWP systems (Including R-410A and R-404A)
• January 1, 2026 – all new installations must comply with low-GWP refrigerant standards

For heat pumps, air conditioners, and condensing units, the impact is twofold. Equipment must transition to low-GWP refrigerants such as R-32 and R-454B. At the same time, they must meet updated Seasonal Energy Efficiency Ratio (SEER2) and Heating Seasonal Performance Factor (HSPF2) efficiency standards. Both need to be accomplished simultaneously, while also updating safety controls to handle A2L refrigerants. Because A2L refrigerants are mildly flammable, manufacturers must redesign control systems to incorporate refrigerant leak detection sensors, safety shutdown mechanisms, and monitoring and alarm systems. These requirements impact hardware architecture, firmware logic, certification pathways, and field commissioning procedures.

These compliance requirements are further reinforced by the following updated safety standards:

• CSA B52 Mechanical Refrigeration Code in Canada
• UL 60335-2-40 in the U.S.
• ASHRAE 15 Safety Standard for Refrigeration Systems across both countries

HVAC OEMs, equipment manufacturers, contractors, and distributors are all affected, whether it’s redesigning product lines around new refrigerants, managing inventory transitions, retraining service teams, or updating procurement processes to reflect the new compliance landscape.

With the new regulations in place, how can one turn these challenging adjustments to opportunities? Click here to learn more by reading the rest of the article in Part 2.