Shifts in environmental policy are driving significant changes in the heating, ventilation, and air conditioning (HVAC) world, particularly when it comes to refrigerants. High-Global Warming Potential (GWP) refrigerants like R-410A are being phased out to reduce greenhouse gas emissions, a move that greatly affects building owners, facility managers, and even homeowners. This transition is happening quickly, with the initial phase-out of refrigerant production having already started in 2024 and the complete phase-out of new high-GWP equipment beginning in 2025. As a result, many professionals and property managers are scrambling to figure out their next steps. 

At times like these, it’s crucial to have the right guidance. That’s why we’ve put together the key information and dates to keep in mind to be prepared for these changes. 

Overview of Refrigerants and Their Environmental Impact 

Refrigerants are chemical compounds used in refrigeration and air conditioning. Traditionally, many systems have relied on high-GWP refrigerants, such as R-410A. Global Warming Potential (GWP) is a metric that compares the heat-trapping capability of various gases to carbon dioxide over a specific time period (typically 100 years). For example, R-410A has a GWP of about 2,088, meaning it’s over 2,000 times more potent than CO₂ in terms of global warming effect. 

Why Phasing Out Matters 

The reason behind phasing out these high-GWP refrigerants is simple: they are major contributors to greenhouse gas emissions. Hydrofluorocarbons (HFCs) like R-410A have been increasing in usage worldwide since they were first introduced as replacements for ozone-depleting substances in the late 1980s and early 1990s. While they helped address ozone depletion, their high GWP has made them a significant concern in the context of climate change. 

Transitioning to lower-GWP options aligns with broader national and international sustainability commitments. For example, the U.S. ratified the Kigali Amendment of the Montreal Protocol in 2022, which aligns over 100 countries in phasing out HFCs by 80% by 2047. Furthermore, many states and local jurisdictions are also adopting stricter building energy codes to reduce overall carbon footprints.  

In other words, refrigerant phaseouts are just one piece of the puzzle: building owners are increasingly expected to modernize across multiple fronts, from energy-efficient lighting and insulation to advanced HVAC solutions. 

The AIM Act and Key Deadlines 

One of the primary drivers of the refrigerant transition in the United States is the American Innovation and Manufacturing (AIM) Act. This legislation sets clear targets for reducing HFC production and consumption, aiming to cut them by 85% by 2036. 

Most notably, the Act introduces a GWP limit of 700 for new refrigerants starting January 1, 2025. Because R-410A’s GWP far exceeds this threshold, new equipment relying on R-410A will no longer meet federal requirements. Certain commercial equipment manufacturers have until 2026, but the clock is ticking for the majority of refrigeration and HVAC systems. 

Timeline Highlights 

• 2024: Production and import of refrigerants above 700 GWP are reduced by 30%.  

• January 1, 2025: In most categories, new equipment using refrigerants above 700 GWP can’t be produced or installed under federal law. 

• 2026-2028: The remaining categories of new equipment not already phased out in 2025 are phased out during this period. 

• By 2036: High-GWP refrigerant production aims to be cut by 85%, making it increasingly costly for those still relying on it. 

These milestones can vary by location. Some states implement these rules earlier, while others align with the federal schedule. It’s vital to check local codes or consult experts to avoid costly compliance pitfalls. 

Impact on Building Systems 

Nearly any system that uses refrigerants can be impacted. This includes: 

• Split Systems and Heat Pumps: Common in both residential and commercial buildings. 

• Packaged Rooftop Units (RTUs): Often found on larger commercial properties. 

• Variable Refrigerant Flow (VRF) Systems: Popular for their efficiency in multi-zone structures. 

• Chillers: Essential in some industrial and large-scale commercial environments. 

Since many of these systems still use high GWP refrigerants, the new regulations will affect both small-scale property managers and large facility owners. 

Maintenance and Cost Implications 

Existing systems using high GWP refrigerants aren’t outlawed overnight; they can remain in operation. However, the cost to maintain them will likely increase as the supply of these refrigerants decreases under the phasedown schedule. As high-GWP refrigerants become scarcer, their prices can spike, translating into higher repair bills and potential downtime.  

This means that even if you can still legally purchase these refrigerants in your area, future service availability is uncertain. Equipment installed today could face premature retirement if refrigerant costs become prohibitive. 

Another consideration is that some states are adding additional, stricter regulations. For example, California is entirely banning the sale of R-410 refrigerant in 2030, making it impossible to maintain equipment past that point. It’s important to know your local regulations to ensure you aren’t left with an unmaintainable system for your building. 

Replacement Options and the Role of Facility Assessments 

One of the most talked-about solutions is switching to lower-GWP “A2L” refrigerants, such as R-32 or R-454B. These alternatives have a much lower environmental impact due to their GWP, which is 90% less than existing high-GWP refrigerants. 

However, they’re also mildly flammable, so installation and handling standards must be updated. As a result, contractors will need to follow revised safety guidelines, yet most HVAC professionals don’t expect drastic changes in daily procedures.  

Why a Facility Assessment Helps 

While it might seem like the best course of action is to update your HVAC systems immediately, this likely isn’t the case. You want to get the most out of your existing systems and upgrade when it makes financial sense. Determining this ideal time is complicated. 

A professional facility assessment or energy audit can provide critical data to guide these decisions. Through systematic analysis of your building’s energy usage, equipment age, and operational costs, you can: 

• Pinpoint the Most Urgent Replacements: Not all systems will fail simultaneously. An assessment helps identify which equipment is at the highest risk or least efficient. 

• Project Return on Investment (ROI): A thorough audit can estimate how much you’ll save on energy and maintenance with newer, more efficient systems. 

• Plan Around Local Code Timelines: With shifting deadlines, up-to-date information on regional requirements is essential. 

Using this information, you can determine the appropriate time to upgrade and incorporate upgrades into a facility-wide capital improvement or sustainable facility maintenance plan. 

Emerald Built Environments: Your Partner in Navigating the Refrigerant Phase-Out 

Acting now to address the high-GWP phaseout can help you avoid costly compliance issues and skyrocketing maintenance fees. Lower-GWP refrigerants not only support environmental goals but also deliver enhanced efficiency over time. Additionally, you can keep your operations on track by monitoring local codes and federal deadlines. 

Emerald Built Environments, A Crete United Company, can guide your organization through every step of this transition to ensure compliance. Furthermore, we can help you determine when and how to make cost-effective and energy-efficient HVAC upgrades with a comprehensive facility assessment or energy audit. By aligning your building’s equipment with future standards, you’ll protect both your bottom line and the environment for years to come.