The 2026 final rule provides a conditional inventory route; it is not permission to install any new high-GWP system. It requires the relevant specified components to meet the pre-2025 manufacture/import condition. Controlling rule
For a contractor's workflow, create an exception record rather than a blanket “allowed” flag. Recommended fields are component identity, manufacture/import evidence, system configuration, proposed installation, rule version, reviewer and decision. These are proposed evidence-management fields, not a claim that the rule prescribes this exact software schema.
If only part of the evidence is available, classify the selection as unresolved. Ask the distributor for documentation and the technical reviewer to confirm the applicable route. Do not use a vendor's sales description or an old pricebook entry as proof.
Why is an apparently current EPA PDF not enough?
One EPA fact sheet stored under a May 2026 URL explicitly warns that it has not been updated to reflect the new final rule and directs readers to current restrictions. Its URL date must not be mistaken for a fresh substantive summary. EPA historical fact sheet and warning
Add a source-status field to regulatory research: current guidance, final rule, proposed rule, historical guidance or superseded content. An automation that retrieves the nearest matching sentence without the warning can reproduce an obsolete deadline with a convincing citation.
Sources cited on this page
- Controlling rulefederalregister.gov
- EPA historical fact sheet and warningepa.gov