Update as of 3/27/26

Court Temporarily Suspends Ban on R-404A & R-507A Refrigerant Sales in New York

The court has temporarily suspended the prohibition on bulk refrigerant sales of R-404A and R-507A, which was set to take effect on April 1st. 

Earlier this week, HARDI filed a request for a Temporary Restraining Order against the DEC on the enforcement of the bulk refrigerant sales prohibition for R-404A and R-507A set to take effect on April 1 (R-410A is not subject to the prohibition until 2030). The suspension remains in effect until the court rules on the accompanying preliminary injunction motion regarding the requirement, pending HARDI's appeal.

There is no set expiration date on the temporary suspension; the court will require both sides to submit briefs before hearing arguments. The briefing will end on April 20, and no hearing date has been scheduled yet.

This means you can continue to sell R-404A and R-507A in New York with no enforcement of the prohibition. We will keep you updated as the injunction process continues.

Update as of 1/7/26

EPA Signals Shift in R-410A Installation Enforcement

On December 23, 2025, the U.S. Environmental Protection Agency (EPA) announced a change in its federal enforcement priorities related to the January 1, 2026 installation prohibition for R-410A residential and light-commercial split-system air conditioners and heat pumps under the Technology Transition Rule.

While the rule itself has not been repealed, the EPA indicated it will not prioritize federal enforcement of the R-410A installation date as it works through a formal reconsideration of the regulation. This decision reflects widespread industry concern that the installation deadline is impractical, disruptive, and likely to be revised by Congress later in 2026. The manufacturing cutoff for R-410A equipment remains unchanged.

This announcement provides temporary federal-level relief for contractors, reducing the likelihood of EPA enforcement actions tied solely to the installation date during this interim period. However, the rule is still technically in place.

Important clarification:
EPA’s enforcement discretion applies only at the federal level. State and local authorities may still enforce existing requirements. In particular, New York State has issued a ruling that supersedes this EPA enforcement change, and contractors operating in New York must continue to comply with state-specific regulations and guidance.

Bottom line:
The EPA’s announcement does not eliminate the R-410A installation prohibition, but it signals reduced federal enforcement. Contractors must continue to follow all applicable state and local requirements, especially in states like New York, where stricter or overriding rules apply.

For NYS Contactors, please reference the NYSDEC Part 494 Fact Sheet 

After March 31, 2026 new (virgin) R-404a/R-507 will be prohibited in NYS. Only reclaimed product can be sold in NYS for service in refrigeration systems. It’s obvious that this will cause a shortage of availability. It may make sense to consider the owner of the system to pre-buy R-404a for future service applications.

VRF Systems: LG VRF systems will still be allowed for installation in NYS until January 1, 2027. This more closely aligns NYS with the EPA standards regarding VRF A2L systems. The main difference is that systems installed in NYS must use recycled R410 rather than virgin refrigerant for the trim charge. Additionally, the variance applies only to the four manufacturers listed on the DEC letter. The letter can be found below under NYS 494 VRF Variance. 

Full Letter NYSDEC Enforcement Discretion Part 494
HARDI: ODU New York A2L Transition Flow Chart HARDI: NYSDEC Summary Final Part 494
NYS 494 VRF Variance

Update as of 2/5/25

Meier Supply has been waiting for communication from NYS to provide us an update on the refrigerant prohibition they put into place January 9, 2025. We received an update and here are a few highlights.

• A prohibition will be reinstated beginning April 9, 2025 on any (virgin refrigerants) refrigerants with a GWP exceeding 2,200 (this includes R-422D & R-438A)

• 404a and 507 will be exempt from the prohibition until January 1, 2026. 

• Other refrigerants will be prohibited beginning 2030 depending upon their GWP (see chart below). The chart shows all of the most common refrigerants, there are others that apply based on their GWP.

• The state also allowed for a “Force Majeure” for 404a/507, which allows for a variance to the enforcement which allows end-users (supermarkets) to repair equipment until December 31, 2027. 

• All of this is layered on top of the EPA’s phasedown of high GWP refrigerants and the AIM act’s equipment transition to A2L’s this year.

Update as of 1/17/25

UPDATE ON REFRIGERANT SALES ENFORCEMENT

We want to provide you with an important update regarding refrigerant sales in New York State.
Based on the latest information from Heating, Air Conditioning, and Refrigeration Distributors International (HARDI), the New York State Department of Environmental Conservation (DEC) is currently not enforcing the prohibition on refrigerant sales as previously announced.

What This Means for You

As of today, you can purchase and use the following refrigerants in New York State without concern:

• R-404A
• R-438A
• R-507
• R-422B
• And other refrigerants previously included in the prohibition.

While this is a temporary pause in enforcement, we have not received official details on any permanent changes to the regulation. We will keep you informed as new information becomes available.

Update as of 1/6/25

IMPORTANT NOTICE

Final New York HFC Regulation Released, Prohibitions Begin January 9, 2025

The New York State Department of Environmental Conservation (DEC) has finalized rules to phase out the use of Hydrofluorocarbon (HFC) refrigerants and move to ultra-low GWP refrigerants in the future. The new regulations under Part 494 will dramatically impact HVACR products sold and installed in New York State. The final regulation impacts five main areas:

• Prohibitions on sales of bulk refrigerants (HFCs, HCFCs, and CFCs)
• Prohibitions on sales and installation of equipment using HFC refrigerants
• Labeling and disclosure requirements
• Recordkeeping and reporting requirements for manufacturers, producers, suppliers/distributors, and users of HFC refrigerants
• Leak repair requirements and an end-user refrigerant management program

With New York State phasing out the use of high-GWP refrigerants like R-404A in many applications to support environmental regulations. The best replacement alternative is R-449A, which offers lower GWP and similar performance. Contact your local Meier Supply branch to learn more about compliance and retrofit solutions!

Questions? Please contact us HERE

The equipment prohibitions apply to the manufacturing and sale of self-contained products and the the installation of field-charged systems. Learn More Below.

Equipment and Refrigerants

Labeling and disclosure requirements go into effect on January 9, 2025, despite some equipment subject to the requirements being manufactured before the requirements went into effect. Learn More Below.

Labeling and Disclosure Requirements

Recordkeeping requirements are classified as suppliers under this regulation. Refrigerant suppliers in or into New York State will be required to register with the state and provide annual reports on refrigerants sold and recovered for reclaim in the state. Learn More Below.

Recordkeeping and Reporting

Update as of 5/30/24

Urgent Action is Needed!

Contact your state legislators and oppose the NYSDEC Amendments to Part 494. If passed as proposed, these amendments will ban service gases in 2025 and force the transition to propane or CO2 systems in 2034. 

Taken Action and Oppose

New York HFC Phaseout and move to Dangerous Refrigerants

The New York Department of Environmental Conservation (NYSDEC) has proposed Amendments to Part 494 which would phase out the use of hydrofluorocarbons (HFCs) in the state and force the industry to switch to more dangerous refrigerants such as propane, isobutane, ammonia, and carbon dioxide.

Background
In 2019, the New York legislature passed the Climate Leadership and Community Protection Act, which included a provision to phase down the use of high global warming potential (GWP) pollutants, including HFCs. At the time of passage, the U.S. Congress had not yet passed the American Innovation and Manufacturing Act, which phases down HFC production and consumption by 85 percent. 

New York's Scoping Plan

In 2022, New York finalized its scoping plan for reducing climate pollutants statewide, a crucial step towards achieving its goal of net zero carbon emissions by 2050. As part of this comprehensive plan, the state was to “phase out” high-GWP HFCs in line with the EPA's efforts at the federal level and phase down its total use of HFCs, underscoring the state's commitment to environmental sustainability. Following the scoping plan, as written, New York would have matched the federal transition away from high-GWP refrigerants, serviced existing equipment, and achieved the climate goals included in the Climate Leadership and Community Protection Act. 

Amendments to Part 494

Unfortunately, the proposed Amendments to Part 494 released by the NYSDEC far exceeded the Scoping Plan approved in 2022. Under the proposed changes, New York would completely phase out the use of HFC refrigerants in new equipment installations, which are used in all current and next-generation air conditioning equipment and more than 90 percent of current and next-generation refrigeration equipment. By banning equipment using even low-GWP refrigerants, the department is forcing the switch to non-fluorinated refrigerants such as propane, isobutane, ammonia, and carbon dioxide, each of which poses more danger than current low-GWP alternatives. 

In addition to the phase-out of new equipment using HFC refrigerants, the department is also banning the sale of service refrigerants to keep current equipment operating. While NYSDEC says this is false, the department has started to realize its mistake in how the regulation was written, which forbids both virgin and reclaimed refrigerant. The intention was to allow reclaimed refrigerant (refrigerant recovered from equipment at end of life, re-purified and resold at the same quality as new refrigerant), however because all refrigerants are banned, the proposed regulation would force early replacement of working equipment.

Full Summary of NYS Proposed HFC Phaseout

Update as of 3/1/24

What you need to know and how it could impact your business without Action! 

New York Department of Environmental Conservation (NYDEC) has proposed substantial modifications to regulations that would significantly impact the use of refrigerants in the state of New York.

Amendments to Part 494, Hydrofluorocarbon Standards and Reporting: 

• The Department is proposing amendments to 6 NYCRR Part 494, “Hydrofluorocarbon Standards and Reporting.” The proposed regulation includes prohibitions, reporting, and other requirements regarding the sale, use, and supply of HFCs and new products and systems that contain HFCs. The goal of this proposed rule is to implement recommendations of the Climate Action Council Scoping Plan necessary to achieve the required statewide GHG emission limits and net zero goal outlined in the Climate Act. Comments and requests for further information can be sent to Suzanne Hagell at the address provided above. Include “Comments on Part 494 HFC” in the subject line of the email.

HOW YOU CAN MAKE A DIFFERENCE

To mitigate the significant impacts of this proposed regulation to the HVACR industry, we ask that you engage with policymakers, legislators, representatives, and regulators in New York. It is imperative these stakeholders understand the opposition to this proposal directly from their constituents.

Make Your Voice Heard

Supporting Information

WHY

NY DEC is proposing these amendments to support the emission reduction targets established by the Climate Leadership and Community Protection Act. We strongly oppose these measures in favor of federal regulations established by US EPA according to the American Innovation and Manufacturing (AIM) Act which will result in an 85% reduction of HFCs nationally by 2036.

The Impact

We strongly encourage review of the full regulatory proposal in order to understand the potential impacts to your business. Below are high level summaries of specific sections of the proposal.

Regulation and Prohibition based on 20-year GWP:
Proposed amendments would ultimately require the use of refrigerants with a GWP less than 10 according to the 20-year GWP scale. All other regulations (state, federal, international) rely on a 100-year GWP scale.
Not only would the regulations impact installation of new equipment, but it would also restrict distribution of bulk refrigerants above a specified GWP. This provision would have significant impacts on the ability to service existing equipment in the field and could result in stranded equipment.
• For example, NYDEC is proposing to restrict the distribution of bulk regulated substances with a 20-year GWP =4600 starting on January 1, 2025, which would prohibit refrigerants such as R-410A, R-404A, and R-507A.

 

Registration, Reporting and Recordkeeping Requirements
The proposed modifications to these regulations also include significant and burdensome registration, reporting, and recordkeeping requirements for any person who supplies, manufacturers, produces, or distributes bulk regulated substances or equipment or products containing regulated substances intended for sale or use in New York State.


Refrigerant Management and Replacement Program
Owners and operators of specified equipment would be subject to registration and labeling requirements. In addition, the specified equipment will be subject to stringent leak inspection, detection, and repair requirements. When leaks cannot be addressed and repaired according to the requirements of the regulations, the equipment must be replaced.


Food Chain Refrigerant Replacement Program
In the proposed modifications, NYDEC has included an unprecedented requirement that all retail food facilities meet one of the following conditions by January 1, 2035:
1. Equipment with charge size greater than 200 pounds must use a refrigerant with a 20-year GWP less than 10.
2. Achieve an annual leak rate of 1% or less.

If you would like to formally weigh in with the NYSDEC to share concerns with the proposed rule, you can do so by simply sending an email to climate.regs@dec.ny.gov