Original Article by Lennox

Below is a Lennox update on EPA/DOE progress and expectations regarding the A2L (Low GWP) refrigerant regulation slated for implementation in January of 2025. This article was written in a bullet point format in order to deliver the information in the most efficient way possible. Please contact the Lennox team for more details. 
 
  • Finalization of the actual refrigeration regulation, the conditions set around its use, and the phase out of R410A was required by 10/31/23.
  • *Previously open issue to yet be determined. The length of the sell through period for R410A products after Jan. 1, 2025.
    • Sell through period for R410A products manufactured before Jan. 1, 2025, will be three (3) years.  Determined week of 10/8/23. It is possible this could be adjusted.
    • Unexpected curve ball from the EPA
      • Components of a split system (Furnace, Air Handler or Coil, A/C or Heat Pump) have been defined as products (EPA).
      • When installed together in a new installation (New Construction Home, existing systems complete replacement, or new remodel), the combination has been defined as a system (EPA).
      • All new system installations completed after December 31, 2024, must be with new low GWP refrigerants.
      • Sell through period will not apply to new system installations.
      • R410A equipment (defined as products) may be manufactured after Dec 31, 2024, but only used for existing system component replacement.
    • Allowance to manufacturer R410A equipment after Dec. 31, 2024, was in recognition of consumer groups pressure.
      •  If a two-year old R410A system has an outdoor unit failure, and R410A not available, it could force an entire system replacement due to refrigerant sensor requirements on all indoor equipment for Low GWP usage.
    • Lennox anticipates this may move forward some builders' timelines for conversion to the new refrigerant to earlier in 2024 the previously expected.
    • Package Units are not defined as “systems”, so this new twist does not apply for the small percentage of work where new homes utilize package units.
    • Package units will convert to new refrigerant. They are just not subject to installation restriction of 12/31/24 for new homes.
  • Current state of R410 availability and cost.
    • There was a 10% reduction in the production of Virgin R410A in 2022.
    • There will be a further 40% reduction in the production of Virgin R410A in 2024.
    • A2L refrigerant use manufacturer mandate for all new HVAC product – Jan. 1, 2025.
    • There will be a further 70% reduction in the production of virgin R410A in 2029.
      • Unrelated, but  currently scheduled for 2029. Proposed gas furnace minimum efficiency set to 95%+ for installs after Dec. 31, 2028.
    • Expect R410A reduction schedule to drive cost of R401A product, across all manufacturers, in the near term.
    • Manufacturers already seeing quoted price of 2X 2023 price for R410A in 2024.
    • R410A costs in 2024 currently expected to be between 2X and 3X of 2023 price.
    • Expect R410A product availability to tighten in 2nd half of 2024.
    • Replacement of A2L with “natural refrigerant” in 2034.
  • Mechanical Code has been updated.

  • Progress of individual states adopting A2L Mechanical Code into their Building Codes.

  • Manufacturers A2L ratings availability on Air-Conditioning, Heating, and Refrigeration Institute (AHRI) ratings site.
    • Manufacturers are not allowed to have ratings posted to AHRI earlier than 30 days before product is commercially available.
    • Lennox expected to begin introducing A2L RNC products to the market in Q3 of 2024.
    • Each manufacturer will have their own commercialization schedule.
  • All GWP products, when introduced, will be rated In DOE 2023 Regional Standards compliant terms (SEER2/EER2/HSPF2) only.
    • No more dual ratings in SEER and SEER2 - Time to convert all calculations, plans, specs, etc.  All manufacturers will make this adjustment.
    • Anyone doing business in CA should communicate this to your design engineers and ask them to communicate, in turn, to the CEC.
      • We have attempted several times to inform the CEC without an acknowledgement.
      • They currently use a multiplier from SEER in their energy calculator.
      • The SEER designation will no longer be in place on low GWP equipment to drive this calculation.
  • See below to view cost driving changes through 2035. 


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