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Does the switch to new A2L refrigerants change your AC replacement quote?

It can, for a whole new system. EPA's rule says no person may install new residential air conditioning systems using a refrigerant with a global warming potential of 700 or greater, except where all specified components were manufactured or imported prior to January 1, 2025. EPA says components used to repair existing systems are not subject to these restrictions.

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.
Source: EPA, Technology Transitions HFC Restrictions by Sector (last updated August 28, 2026), read 22 October 2026.
Source: EPA, Technology Transitions Reconsideration Rule technical fact sheet (PDF, May 2026), read 22 October 2026.

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By InstaBids editorial team with AI research agents. Sources read: 22 October 2026 Updated 2026-10-22

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Key facts

What does the federal rule say about installing a new system?

No person may install a new residential or light commercial air conditioning or heat pump system using a regulated substance, or a blend containing one, with a global warming potential of 700 or greater, effective January 1, 2025, under 40 CFR 84.54(c)(1), which also carries an exception for older components. The paragraph is quoted below in its own words.

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

40 CFR 84.54(c), in the Electronic Code of Federal Regulations (eCFR), read 22 October 2026: "(c) No person may install any system, nor have any such system be installed through their position as a designer, owner, or operator of that system, in the following sectors or subsectors that uses a regulated substance as listed in this paragraph (c):"

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

Paragraph (c)(1): "(1) Effective January 1, 2025, residential or light commercial air-conditioning or heat pump systems using a regulated substance, or a blend containing a regulated substance, with a global warming potential of 700 or greater, except for variable refrigerant flow air-conditioning and heat pump systems. New residential and light commercial air-conditioning and heat pump systems using a regulated substance, or a blend containing a regulated substance, with a global warming potential of 700 or greater may continue to be installed where all specified components of that system are manufactured or imported prior to January 1, 2025."

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

The eCFR page shows its own status on the day it was read: "Displaying title 40, up to date as of 10/20/2026. Title 40 was last amended 10/19/2026." "It is not an official legal edition of the CFR."

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

Paragraph (e) says which work counts as installing a system. It begins: "(e) The following actions, upon charging the system to full charge, are considered an installation of a refrigeration, air conditioning, and heat pump system under paragraph (c) of this section:" "(1) Assembling a system for the first time from used or new components;"

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

In our reading, the limit is set by a number, the global warming potential, not by a refrigerant's safety class; the rule text quoted here does not name any safety class.

Can a new system with pre-2025 R-410A parts still go in?

Yes, under the current text, where all specified components were manufactured or imported prior to January 1, 2025. EPA's May 2026 fact sheet says the rule removes the January 1, 2026, installation compliance date for that equipment and allows pre-2025 inventory of air conditioning systems to be installed until supply runs out. Its words are quoted below.

Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.
Source: EPA, Technology Transitions Reconsideration Rule technical fact sheet (PDF, May 2026), read 22 October 2026.

EPA's technical fact sheet on the Technology Transitions reconsideration rule (May 2026), read 22 October 2026, in its row for residential and light commercial air conditioning and heat pump systems: "Removes the January 1, 2026, installation compliance date for equipment using refrigerants above the 700 limit that were domestically manufactured or imported into the United States before January 1, 2025" "Allows pre-2025 inventory of air conditioning systems to be installed until supply runs out"

Source: EPA, Technology Transitions Reconsideration Rule technical fact sheet (PDF, May 2026), read 22 October 2026.

EPA's table of HFC restrictions by sector, read 22 October 2026, says in a footnote to its row for residential and light commercial systems: "No installation compliance date for systems where all specified components were manufactured or imported prior to January 1, 2025. Refer to the Technology Transitions Reconsideration Rule for additional details."

Source: EPA, Technology Transitions HFC Restrictions by Sector (last updated August 28, 2026), read 22 October 2026.

The same page adds: "These tables are for informational purposes only and should not be relied on for compliance purposes. Please refer to 40 CFR Part 84, Subpart B for full details."

Source: EPA, Technology Transitions HFC Restrictions by Sector (last updated August 28, 2026), read 22 October 2026.

EPA's frequent questions page on the HFC phasedown, read 22 October 2026, still answers a homeowner question with this sentence: "After January 1, 2026, if a whole new system is installed it must use lower-GWP refrigerant."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

In our reading, that sentence does not match the regulation text quoted above, which no longer carries that date for home systems. When a quote leans on a date, ask the installer which text it relies on.

Does replacing only the outdoor unit count as a new system?

No, in EPA's frequent questions: a homeowner can replace a faulty component such as the condensing unit with a similar R-410A component, and a new system would be installed if both the condensing unit and indoor coil are replaced together. Those answers are quoted below.

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

EPA's frequent questions page, read 22 October 2026, on a broken R-410A condensing unit: "Homeowners can maintain and repair their systems throughout the useful life of the equipment. A homeowner can replace a faulty component (e.g., condensing unit, indoor coil, other smaller parts) with a similar R-410A component."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

On what a new system is: "For residential air conditioner split systems, a new system would be installed in a newly constructed home. A new system would also be installed if both the condensing unit and indoor coil are replaced together. The condensing unit contains the condenser coil and compressor, and the indoor coil is the evaporator."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

On keeping the existing refrigerant lines: "Yes. Refrigerant lines are generally not removed when replacing the other mechanical components of a system. Therefore, even if refrigerant lines are unchanged, replacing all the other components would result in a new system for purposes of the Technology Transitions Program."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

On replacing the condensing unit now and the indoor coil later: "Yes. Systems may be repaired over time. Factors for homeowners to consider when deciding to repair or transition to a new system using a lower-GWP refrigerant include availability of components, energy efficiency, and total maintenance costs."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

EPA's table of HFC restrictions by sector, read 22 October 2026, in its footnotes: "EPA is restricting the installation of new field-assembled systems. Components used to repair existing systems are not subject to these restrictions."

Source: EPA, Technology Transitions HFC Restrictions by Sector (last updated August 28, 2026), read 22 October 2026.

Where do A2L refrigerants such as R-454B fit in?

On EPA's list of substitutes for home air conditioning, A2L appears under the ASHRAE designation (safety classification), and R-454B is listed as A2L, acceptable with use conditions. EPA's frequent questions name HFC-32 and R-454B as examples of flammable or mildly flammable refrigerants. EPA's GWP reference table lists R-454B at 465 and R-410A at 2,088, against the rule's limit of 700.

Source: EPA SNAP Program, Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (last updated March 19, 2026), read 22 October 2026.
Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.
Source: EPA, Technology Transitions GWP Reference Table (last updated April 2, 2026), read 22 October 2026.
Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

EPA's SNAP page on substitutes in residential and light commercial air conditioning and heat pumps, read 22 October 2026, sorts its list by a column it labels this way: "Filter by ASHRAE Designation (Safety Classification):"

Source: EPA SNAP Program, Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (last updated March 19, 2026), read 22 October 2026.

Its table row for R-454B reads: "R-454B Opteon™ XL41 N 0 470 A2L May 6, 2021 (pdf) (583 KB) Acceptable with Use Conditions: See rule for detailed conditions."

Source: EPA SNAP Program, Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (last updated March 19, 2026), read 22 October 2026.

The same page says: "Many acceptable substitutes under SNAP may be restricted under the Technology Transitions Program."

Source: EPA SNAP Program, Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (last updated March 19, 2026), read 22 October 2026.

EPA's GWP reference table, read 22 October 2026, says of its figures: "These values are listed in 40 CFR 84.64 and are provided here as reference." Its row for R-410A reads "R-410A 2,088 Calculated", and its row for R-454B reads "R-454B 465 Calculated".

Source: EPA, Technology Transitions GWP Reference Table (last updated April 2, 2026), read 22 October 2026.

EPA's frequent questions page, on putting a lower-GWP refrigerant into an existing system: "EPA’s Significant New Alternatives Policy (SNAP) Program and industry standards prohibit the use of flammable or mildly flammable refrigerants such as HFC-32 or R-454B in systems that were not designed to use them."

Source: EPA, Frequent Questions on the Phasedown of Hydrofluorocarbons (last updated September 14, 2026), read 22 October 2026.

In our reading, the SNAP page and the GWP reference table print slightly different figures for R-454B (470 and 465). Both are below the 700 in the rule.

Source: EPA SNAP Program, Substitutes in Residential and Light Commercial Air Conditioning and Heat Pumps (last updated March 19, 2026), read 22 October 2026.
Source: EPA, Technology Transitions GWP Reference Table (last updated April 2, 2026), read 22 October 2026.
Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

What should you ask before you sign an AC replacement quote?

Ask each installer to write down which refrigerant the quoted system uses, which parts it replaces, and when those parts were made, so you can compare quotes for the same job. This is practical reasoning, not legal advice and not a finding from any agency.

  1. Ask for the refrigerant by its R-number on every quote, for example R-410A or R-454B.

    Source: EPA, Technology Transitions GWP Reference Table (last updated April 2, 2026), read 22 October 2026.

  2. Ask whether the quote replaces both the outdoor condensing unit and the indoor coil, or only one of them.
  3. If the quoted system uses R-410A, ask for the manufacture or import date of each major component in writing.

    Source: EPA, Technology Transitions GWP Reference Table (last updated April 2, 2026), read 22 October 2026.
    Source: Electronic Code of Federal Regulations, 40 CFR 84.54, Restrictions on the use of hydrofluorocarbons, read 22 October 2026.

  4. If only one part has failed, ask for a written repair option next to the replacement option, so you can weigh both.
  5. Ask whether your existing refrigerant lines will be reused or replaced, and what the quote includes for them.
  6. If a quote proposes a different refrigerant in your existing equipment, ask in writing whether that equipment was designed for it.
  7. Compare quotes only when they cover the same written scope: the same refrigerant and the same parts replaced.

Who sees your contact details when you post on InstaBids?

Contact details stay hidden until the homeowner picks a contractor and they confirm the connection.

Source: InstaBids process and privacy, live-page excerpts, read 22 October 2026.

Post your job on InstaBids, and contractors can bid in writing on one written scope.

Homeowners anywhere in the US can post a job; once you send it, InstaBids finds contractors to bid on it.

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