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SESK: Stuff Everyone Should Know · sesk.info/epa-vrf-gwp-700-2027

New VRF systems with GWP 700 or more, with all parts made before 2026, may be installed until when?

January 1, 2027, for systems whose parts were made before 2026.

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  1. January 1, 2025
  2. January 1, 2030
  3. January 1, 2027 ✔

Why: Under EPA's Technology Transitions rules, the GWP limit for new VRF systems is 700. Higher-GWP systems whose parts were all made or imported before January 1, 2026 may be installed until January 1, 2027.

Huh, didn't know that: A further extension to January 1, 2028 applies to buildings with a permit approved before October 5, 2023 that specified an HFC system.

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References

Answer: January 1, 2027. Under EPA's Technology Transitions rules, the GWP limit for new VRF systems is 700. Higher-GWP systems whose parts were all made or imported before January 1, 2026 may be installed until January 1, 2027.

  1. Technology Transitions HFC Restrictions by Sector (EPA) www.epa.gov/hfcs/technology-transitions-hfc-restrictions-sector
    New systems with a GWP above 700 can be installed until January 1, 2027
    Checked 2026-10-10.
  2. 40 CFR 84.54 Restrictions on the use of HFCs (Cornell LII) www.law.cornell.edu/cfr/text/40/84.54
    may be installed prior to January 1, 2027, where all specified components of that system are manufactured or imported prior to January 1, 2026
    Checked 2026-10-10.

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