2025 Low GWP
Compliant
Refrigerants

The EPA’s recommended transition rules were recently reviewed by the Department of Energy (DOE). The DOE concluded there needed to be further clarification in place to ensure an outdoor unit replaced still meets the federal minimum requirements. They added the requirement of “outdoor units with no match” to the Technology Transition Rules, which originally came from the dry charge ruling when the industry transitioned from R-22 to R-410A.

A “component” is one unit of a system that is installed for repair for an HVAC system. For example, a component would be the indoor unit (coil or air handler) OR the outdoor unit (air conditioner or heat pump.) This is different from a “product” which has a fully assembled and charged refrigerant loop at the factory. For example, a ResPak that contains all components in one package.

The term “outdoor unit with no match” refers to an outdoor unit, such as an air conditioner or heat pump, that does not have a compatible or recommended indoor unit paired with it to meet system performance, efficiency requirements and compliance regulations like AHRI certification or SEER/HSPF ratings.

Lennox will have repair parts for R-410A equipment to support warranty claims.

There are no direct implications for repair parts on R-410A components. Parts will be available as an option so a dealer can provide a repair vs. an entire system replacement.

Yes, Lennox will produce versatile coils and air handlers in 2025 and beyond to support repair and replacements for R-410A systems. The indoor unit can still be changed out and is not subject to the “outdoor unit with no match” rules. New catalog numbers will be assigned to versatile coils and air handlers as we go into 2025. This will ensure that you know if the coil or air handler was built before or after 2025.

Yes, mini-splits are part of the R-410A “system” rule. If you are replacing both the indoor and outdoor unit, that would be a “system” change. It’s part of the “component” rule if replacing just the outdoor or just the indoor unit.

The EPA Tehcnology Transition Rules are finalized, but as other government agencies review these rules, additional requirements or stipulations may be introduced.

The EPA Technology Transition Rule only applies to the United States however, the decision to manufacture R-410A for Canada only is still being decided. We anticipate having more information on this shortly.

No, per the “system” replacement ruling, BOTH parts of the refrigerant split system must be manufactured prior to 2025. The versatile coils and air handler built in 2025 and beyond can only be used for component replacement purposes.

For whole-home systems, Lennox has chosen 2025 Compliant Refrigerant R-454B due to its excellent performance for ducted systems and zero ozone depletion potential. For mini-splits, we selected R-32, designed to optimize efficiency and reliability in ductless systems. Our engineers worked to maximize equipment performance with these refrigerants, while minimizing changes to installation requirements.

The last refrigerant transition phased out refrigerants with high ozone depletion potential (ODP), such as R-22. The current HVAC industry refrigerant, R-410A, does not contribute to ozone layer depletion but it does have significant Global Warming Potential (GWP) as high as 2088. The Environmental Protection Agency (EPA) mandated that manufacturers switch to a refrigerant with a GWP of 700 or less by January 1, 2025.

The Environmental Protection Agency (EPA) recently proposed regulations aimed at banning the use of many hydrofluorocarbons (HFCs) in HVAC systems. Beginning in 2024, the phase down of HFCs are required to be at 40% below baseline, a significant decrease in the number of available production and consumption allowances compared to previous years.

The HFCs and HFC-blend refrigerants being phased out are as follows:
R-404A
R-134A
R-410A
R-407C used to replace R-22.

In response to the new regulations, low-GWP refrigerants have been created to have similar but better efficiencies and capacities than the refrigerants they are intended to replace. These include R-32 and R-454B.

The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) created a subgroup of refrigerants called A2L. "A" refers to non-toxic, "2" refers to the flammability level, and "L" refers to the low burning velocity. You can see this new subgroup compared to other refrigerant classifications in the referenced chart.

The newly established joint venture, Samsung Lennox HVAC North America, is set to bring advancements to our mini-split and VRF product lineup. Stay tuned for more details as we prepare to unveil this new, low GWP product lineup in Q4 2024 and continue to innovate the future of home comfort solutions. Lennox will continue to sell the current R-410A product line through this year and until supply is depleted in 2025. Lennox will continue to support the product line through the warranty period and service life.

Yes, the Lennox PureAir S and Healthy Climate PureAir are both certified for use with systems using low GWP refrigerants, R-454B and R-32.

Yes, when a UVC light is installed in the plenum, it can safely be used with systems using low GWP refrigerants, R-454B and R-32. The new RDS Sensor located in all Lennox units has been tested to perform in the UVC environment.

All other Healthy Climate IAQ equipment is safe to install with low GWP refrigerant systems, including:

• Healthy Climate filters
• Filter cabinets
• Humidifiers
• Dehumidifiers
• Heat Recovery Ventilators (HRVs)
• Energy Recovery Ventilators (ERVs)
• Induct Air Purifiers

Healthy Climate dehumidifiers now use R-32 refrigerant, which is classified as Low GWP (Global Warming Potential). These units remain EnergyStar certified, and there are no changes to the warranty, controls, interface, or compatibility. The only update is the transition of the refrigerant from R-410A to R-32.

There is no new impact to your residential and commercial HVAC business based on the EPA announcement to reconsider the Technology Transition Rule. 

• The AIM Act remains in effect. It is a bipartisan law passed by both houses of Congress and signed into law by President Trump in 2020, empowering the EPA to regulate and phase down higher-GWP refrigerants like R-410A. 
• Lennox, along with other manufacturers, has converted their entire residential and commercial product lines to lower GWP refrigerants that comply with the AIM Act.  

• Lennox will continue to manufacture, sell, and ship R-454B and R-32 products for residential and commercial HVAC applications. 
• The AIM Act remains in place and the industry has no plans to revert to R-410A. Lennox believes a transition back to higher GWP refrigerants would create substantial disruption and costs for our customers. 
• We will monitor developments in laws and regulations and keep you informed of potential impacts on your business. 

The American Innovation and Manufacturing Act (The AIM Act) is a law that gave EPA narrow authority to regulate and phase down HFC refrigerants with a high global warming potential (GWP). The AIM Act was a bipartisan law passed by both houses of Congress and signed into law by President Trump in 2020.   

Lennox believes it is unlikely that the AIM Act will be repealed.

Once a law is passed, the law is sent to the “agency of jurisdiction” to write the rules (regulations) to implement the law. The agency is required to promulgate by putting into effect rules to implement the law based on “congressional intent.”

The AIM Act was signed into law by President Trump in 2020 and the law was sent to the Environmental Protection Agency (EPA) to write the rules to implement the law. The EPA wrote or “promulgated” three rules to implement the AIM Act, which are:  

1. The Allocation Rule – this rule allocates HFC refrigerant amounts annually to producers, importers, and reclaimers.  
2. The Technology Transition Rule – this rule set dates and other parameters by which users of higher GWP refrigerants must transition to lower GWP refrigerants.  
3. The Refrigerant Management Rule – this rule mandates the use of reclaimed refrigerants and specifies various reporting requirements and compliance dates.  

The EPA announced that the “Technology Transition Rule” will be “reconsidered”. When a federal rule is reconsidered, the agency or body that initially issued the rule can choose to modify, revoke, or maintain the rule based on new evidence, changed circumstances, or a re-evaluation of the original reasoning.  

There are 3 ways to revoke or change a published final rule (regulation).  

1. Amend the rule.  
2. File suit in federal court challenging some aspect of the rule.  
3. Review the rule under the Congressional Review Act.  

Lennox believes this is unlikely. The EPA announcement focuses on “grocery and data centers.” The likely outcome, should a rule be amended, is that the dates for the future commercial refrigeration transition could be pushed back further.  

The residential and commercial HVAC transition away from R-410A has already occurred, and the industry is very unlikely to transition back to higher GWP refrigerants.  

In the unlikely event that an individual manufacturer decided to transition back to higher GWP refrigerants, Lennox believes that individual states would pass state-level laws and regulations requiring lower GWP refrigerants, creating a patchwork of regulations the AIM Act was meant to avoid. This scenario would be problematic for manufacturers, distributors, and contractors alike and would likely drive costs for consumers higher.