The U.S. Environmental Protection Agency (EPA) has released an enforcement statement clarifying its position during the ongoing reconsideration of the 2023 Technology Transitions (TT) Rule. This announcement is intended to address regulatory uncertainty affecting manufacturers, distributors, and HVAC contractors nationwide.
The Technology Transitions Rule was issued under the American Innovation and Manufacturing (AIM) Act and establishes restrictions and compliance deadlines related to the use of certain hydrofluorocarbon (HFC) refrigerants. EPA has initiated a formal rulemaking process—referred to as the TT Rule Reconsideration—to review and potentially extend these compliance dates.
Current Deadlines and Enforcement Discretion
EPA has confirmed that, while it intends to extend the compliance deadlines through the reconsideration process, the existing deadlines remain legally effective until they are modified by final rulemaking.
However, EPA has also stated that enforcement of the current deadlines subject to the TT Rule Reconsideration is a low enforcement priority. During this interim period, the Agency intends to focus its compliance and enforcement resources on preparing for and implementing the new compliance dates that will be established once the reconsideration is finalized.
Protection of Health and Environment Remains a Priority
Despite the exercise of enforcement discretion, EPA emphasized that it retains full authority to take action when necessary to protect human health and the environment. The low enforcement priority does not eliminate regulatory responsibilities, particularly in situations involving safety, environmental risk, or improper handling of regulated substances.
Additional Oversight for Enforcement Actions
EPA also noted that, consistent with its internal enforcement guidance issued on March 12, 2025, any enforcement or compliance assurance action related to the TT Rule during the reconsideration period must receive concurrence from the Assistant Administrator for the Office of Enforcement and Compliance Assurance (OECA), or their designated representative.
This additional review requirement reinforces EPA’s intent to apply enforcement discretion carefully and consistently while the rule is under reconsideration.
What This Means for the HVAC Industry
For HVAC contractors, distributors, and manufacturers, this enforcement statement provides important near-term clarity while the regulatory process continues. Stakeholders are encouraged to:
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Stay informed on the progress of the TT Rule Reconsideration
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Continue planning for the refrigerant transition
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Prepare for updated compliance timelines once finalized
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Maintain best practices related to safety and environmental protection
Official EPA Resources
For the most up-to-date and authoritative information, EPA directs stakeholders to its official Technology Transitions regulatory page:
EPA – Regulatory Actions: Technology Transitions
https://www.epa.gov/climate-
This page includes official rule documents, fact sheets, timelines, and updates related to the Technology Transitions program under the AIM Act.
We will continue to monitor EPA actions closely and share relevant updates as they become available.
