The Refrigerant Changed. Has Your HVAC Tech?

The rules for new HVAC equipment changed on January 1, 2025. The person who services it did not get a matching update.

That’s the quiet risk in the refrigerant transition. Regulators set dates for what manufacturers build. Nobody sets a date for what a technician already knows. For a facilities team, the gap between the two lands on a service call.

What did the AIM Act actually change?

The American Innovation and Manufacturing Act of 2020 set a schedule to cut HFC production and consumption against a 2011-2013 baseline. According to the Congressional Research Service, the cut is 10% for 2020 to 2023, 40% for 2024 to 2028, 70% for 2029 to 2033, 80% for 2034 to 2035, and 85% from 2036 on. The U.S. is now in the 40% step.

Separately, EPA’s Technology Transitions rule limits which refrigerants can go into specific kinds of equipment. EPA’s sector table caps global warming potential (GWP) at 700 for residential and light commercial air conditioning and heat pumps, with a January 1, 2025 compliance date. It sets the same 700 limit for comfort cooling chillers, also from January 1, 2025. Variable refrigerant flow (VRF) systems carry the same limit with a later date.

To meet that limit, manufacturers moved to A2L refrigerants. ACHR News reports that R-32 and R-454B are both classified by ASHRAE as mildly flammable. Daikin, which includes Amana and Goodman, says all its products use R-32. Trane’s residential and listed commercial A2L products use R-454B. AHRI and its partners say more than 90% of new residential and light commercial equipment already uses next-generation refrigerants. That is an industry statement, not a count.

Did EPA delay any of it?

Partly, and the details matter. EPA’s regulatory actions page lists the sequence. An interim rule in December 2023 let pre-2025 residential and light commercial equipment be installed until January 1, 2026. A reconsideration proposal followed on October 3, 2025, and a final reconsideration rule was published on May 26, 2026.

On the main point, ACHR News reports that the final rule removed the January 1, 2026 installation deadline for residential and light commercial systems, so equipment made or imported before January 1, 2025 can be installed until that inventory is gone. EPA’s sector table agrees: it lists no installation compliance date for systems whose specified components were all made or imported before that date.

What did not change is the limit itself. The law firm Holland & Knight, in its summary of the final rule, notes it does not alter the ultimate GWP limits in the affected sectors. For a building, the practical result is a mixed fleet: existing and in-stock units on the older refrigerants, new units on lower-GWP ones, and one technician expected to service both.

One caution. The sector table describes its own categories, such as “mini-splits, unitary systems,” and notes it is informational and defers to 40 CFR Part 84. Whether a particular rooftop unit, chiller or VRF system falls in a given subsector is a question for your contractor and your engineer, not for a blog post.

Dates decide what ships. Skills decide who is safe opening the panel.

What does a technician need to service both?

The federal baseline hasn’t gone away. EPA states that anyone handling refrigerants, such as air-conditioning and refrigeration service technicians, must be Section 608 certified, and that the requirement is kept for substitutes like HFCs. The Bureau of Labor Statistics says the same in plain terms: EPA requires nearly all HVAC technicians to be certified in proper refrigerant handling.

A2L training is a layer on top. ACCA’s A2L safety course costs $49 for non-members and is free to members and their teams. It runs five modules, from an introduction through charge calculation, piping and charging documentation, and it is built on ASHRAE 15, 15.2 and 34 and UL 60335-2-40 and 60335-2-89. Learners need 80% on each quiz to pass. ACCA’s launch release says it is designed for technicians who already hold the 608 credential, and reported more than 2,000 contractors signed up since the start of 2024.

The practical details are what separate a trained tech from a certified one. According to ACHR News, R-454B equipment needs a deep vacuum held a little longer than older equipment, and commercial service calls for a nitrogen sweep step. Under UL 60335-2-40, ducted systems with more than 3.91 pounds of R-454B charge need refrigerant detection sensors, and maintenance technicians must keep them working.

Limits of the sources: the ones reviewed here describe 608 as the federal credential and A2L training as an additional layer. I did not find AHRI-branded technician coursework, and I did not find a federal A2L-specific license. Local codes and your manufacturer’s requirements may add more.

Is there actually a shortage of HVAC technicians?

The numbers say yes, with a caveat about who was asked. The 2026 AGC and NCCER survey drew 1,830 respondents, mostly construction firms, in July and August 2026. Among firms with openings, difficulty filling the role was reported by these shares.

The Bureau of Labor Statistics adds the demand side. It reports 440,900 HVAC mechanic and installer jobs in 2025, a median wage of $61,010 in May 2025, 11% projected growth from 2025 to 2035, and about 40,600 openings a year.

Read these together. The occupation is growing faster than average, most firms hiring for it say it is hard, and the people who are available must now be comfortable with A2L equipment as well as the older systems. The survey is of contractors, not a census of service companies, so it measures a pain point more than it sizes a national gap.

What should owners and facilities managers do now?

You can’t train the workforce yourself. You can decide who touches your equipment and what you ask them to prove.

1. Inventory your refrigerants. List each unit by refrigerant type and install year. Mark which are older high-GWP systems and which are A2L. Most buildings will find both.
2. Ask your contractor for proof of 608 certification. For every technician who will work on your equipment, not only the company.
3. Ask for A2L training records. Who completed it, when, and through which program. ACCA’s course is one option, and manufacturer training is another.
4. Ask about tools and procedure. Do they carry equipment rated for A2L work, and do they follow nitrogen sweep and vacuum steps? A bid that skips them is a bid that cut something.
5. Check detection systems. Where equipment carries refrigerant detection sensors, put them on the preventive maintenance schedule.
6. Confirm the subsector. Ask which EPA category each replacement falls under before a quote is accepted, since installation rules differ by category.
7. Plan for a mixed fleet. For several years you will need technicians who can service the old and the new. Write that into vendor scopes and into your own job descriptions.
8. Ask what happens when their senior tech leaves. Their bench is part of your risk.

If you employ in-house technicians, the same list applies to your own hires, plus a training budget that treats A2L as routine, not optional. A $49 course is small next to the cost of a refrigerant release in an occupied building, or a unit down in July. The harder cost is time: a technician in class is a technician not on a call, so schedule training the way you would schedule any other planned outage.

The same logic applies when you evaluate a new hire. A candidate with a 608 card and a few years on older equipment is a real asset, since most of your fleet is still that equipment. A candidate who has also finished A2L coursework and can explain a nitrogen sweep without notes is worth a closer look. Ask both questions in the interview, and note which answer comes with a story from the field.

Who is carrying the risk on your roof?

An EPA deadline moved this year, and it will move again. The skill gap doesn’t have a Federal Register notice. Next time a technician opens a panel on your building, do you know what they were trained to find inside?

If you’re hiring technicians for older equipment and new refrigerants alike, tell us what’s on your roof.