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How to Navigate Changing HVAC Management Regulations in 2026

3 minutes

For facilities maintenance teams, January 1, 2026, marked a significant milestone for HVAC management: all new commercial refrigeration equipment must utilize A2L or low-GWP refrigerants. Planning for this change is critical to avoid project delays, equipment availability issues, and compliance challenges. 

To help ease this transition, we have provided recommendations below, but you should consult with your service provider and/or equipment manufacturers to ensure that your unique facility is meeting regulatory and safety standards, optimizing capital planning, and realizing the full benefits of this transition.

A2L Refrigerants: What you need to know

The move to A2L refrigerants is driven by global efforts to reduce the environmental impact of hydrofluorocarbons (HFCs), which have a high Global Warming Potential (GWP). Regulations like the AIM Act in the U.S. and the F-Gas Regulation in the EU are phasing down the production and consumption of these traditional refrigerants and requiring lower-GWP alternatives.

So, what are A2Ls?

  • "Mildly flammable" classification: Unlike the A1 (non-flammable) refrigerants like R-410A, A2Ls are classified as "mildly flammable." This doesn't mean they're highly combustible like propane (A3 refrigerants), but they do require specific handling and safety protocols.
  • Lower GWP: A2L refrigerants, such as R-454B, R-455A, and R-1234ze(E) provide significantly lower GWPs. This means they contribute far less to climate change if released into the atmosphere.
  • Better heat transfer: A2L refrigerants have properties that allow for more effective heat exchange, improving the system's cooling/heating capability. Some manufacturers have reported efficiency gains of up to 10%.
  • New equipment standard: As of January 1, 2026, new HVAC-R equipment manufactured or imported into certain regions will predominantly use A2L refrigerants. A2Ls are designed for new systems built to accommodate their properties. Federal regulations and manufacturer guidelines do not permit retrofitting old systems to use A2L refrigerants.
  • System design considerations: Equipment designed for A2Ls incorporates enhanced safety features, including stricter charge limits, improved leak detection, and optimized ventilation to mitigate any flammability risks. In some settings, additional safety measures including setting up partial or full containment systems for charging stations may be required.

What your team needs to do

Preparation is key to ensuring a smooth, safe, and compliant transition. Here’s a checklist for your facilities maintenance team:

1. Invest in training & certification

  • A2L-specific safety: Technicians must undergo specialized training covering proper handling, storage, charging, recovery, and leak detection techniques.
  • Emergency procedures: Ensure your team understands emergency response protocols for A2L leaks, including ventilation, evacuation, and fire safety measures.
  • Certification updates: Verify that all relevant certifications are up-to-date and include A2L competencies.

2. Conduct a system inventory & future planning

  • Identify existing systems: Catalog all HVAC-R equipment currently using R-410A or other A1 refrigerants.
  • Plan for replacements: Understand that as older equipment reaches end-of-life, new installations must utilize A2L refrigerants. Start budgeting and capital planning for these replacements.

3. Upgrade tools & equipment

  • Spark-resistant tools: Many standard HVAC tools can create sparks. For A2L refrigerants, you'll need certified spark-resistant recovery machines, vacuum pumps, leak detectors, and manifold gauges.
  • Refrigerant identifiers: Ensure your identifiers can easily and accurately distinguish between A1 and A2L refrigerants.
  • Ventilation equipment: Portable ventilation systems can be crucial for working in enclosed spaces.
  • Proper storage: A2L refrigerants must be stored in designated, well-ventilated areas, often in flammable liquid storage cabinets or rooms, away from ignition sources.

4. Review and update safety protocols

  • Standard operating procedures (SOPs): Revise your existing SOPs to incorporate A2L-specific safety guidelines for installation, maintenance, leak detection, and repair.
  • Personal protective equipment (PPE): Confirm that your team has appropriate PPE, which might include additional considerations for A2L handling.
  • Emergency action plans: Update your facility's emergency response plans to specifically address A2L refrigerant incidents, coordinating with local fire departments if necessary.

With proactive preparation, thorough training, and the right tools, your facilities maintenance team can confidently address the changes and opportunities these new A2L refrigerant regulations present.