The States Where Swapping the Condenser Is Not Servicing
Eleven state rules read. Three define a new outdoor unit on an old coil as new equipment; eight write one sentence that keeps their rule off a house.
Federal law is clear that replacing a failed outdoor unit on an existing system is servicing, not installing a new system. The EPA said so again in May 2026, declining two petitions that would have changed it, and that is the answer for most of the country. It is set out in full on the page about that question.
This page is about the states where it is not the answer, and about how they manage that — because it is not done in the ban. It is done in a definition.
There are only two drafts, and your state picked one
Nine state rules were opened for this page. Not one of them was written from scratch. Every one is a copy of one of two drafts, and the copies are close enough that whole definitions match word for word across states that share no border.
Draft one — air conditioning means chillers. Written from the federal SNAP prohibitions and adopted around 2020 and 2021. Six of the nine states use it, and six define the term in the same breath:
chillers, both centrifugal chillers and positive displacement chillers, intended for comfort cooling of occupied spaces
A chiller makes cold water for a building. The box on the pad outside a house is not one. These rules never reach a residential split system at all, so the federal service route is untouched in those states.
Draft two — air conditioning means what is on your house, and a new condenser makes it new. Written from California’s 2020 regulation order. It lists ducted central air conditioners and heat pumps by name, and then adds the sentence this whole page is about:
an existing system with a single condenser and single evaporator that has a new exterior condenser, condensing unit, or remote condensing unit
A house has one condenser outside and one evaporator coil in the plenum. So in a draft-two state the ordinary outdoor-unit-only replacement is not servicing. It is new equipment, and the refrigerant cap lands on it.
Nothing in either draft needed to mention condenser swaps or the service route. The definition does all of the work, which is why reading a state’s headline — “has an HFC rule” — tells you nothing.
The nine states, and which draft each took
| State | Rule | Draft | Reaches a house? |
|---|---|---|---|
| California | 17 CCR 95373 | two | yes |
| Washington | WAC 173-443-030 | two | yes |
| New York | 6 NYCRR 494-1.3 | two | yes |
| Colorado | 5 CCR 1001-26, Part B I.B.2 | one | no |
| Rhode Island | 250-RICR-120-05-53 | one | no |
| Maine | 38 M.R.S. §1613(1)(B) | one | no |
| Massachusetts | 310 CMR 7.76 | one | no |
| Virginia | 9VAC5-145-110 | one | no |
| Maryland | COMAR 26.11.33.02 | one | no |
| Delaware | 7 DE Admin. Code 1151 | one | no |
| Vermont | Air Pollution Control Ch. 38 | one | no |
Maine’s wording is the one variation worth noting, and it goes the same way: its rule says air conditioning equipment means “chillers used exclusively for the comfort cooling of occupied spaces”. Shorter sentence, same outcome.
Delaware and Vermont were opened on 6 September 2026 and both took draft one, word for word. Delaware’s is at 7 DE Admin. Code 1151 and Vermont’s in Chapter 38 of its air pollution control regulations; on each, the whole air conditioning end-use table is two rows — centrifugal chillers and positive displacement chillers — with R-410A prohibited in both from 1 January 2024, and nothing in either rule that a ducted house system answers to.
New Jersey is still unread, and it is unread for a specific reason worth stating: its rule is not built like the other ten. It is a statute rather than an agency regulation, and rather than writing its own end-use list it points at the federal SNAP appendices. Working out what it covers means reading the statute and then the appendices it adopts, and the statute’s own text was not reachable when this was written. It is one document behind a broken link, not a question anybody has answered here.
Do not read the eight-to-three split above as odds. The three that catch a house are three of the largest states in the country, and the next one you open could go either way.
What the three “yes” states cost you, in detail
| Where the definition sits | Prohibition | Date | |
|---|---|---|---|
| California | 17 CCR 95373 | 750 GWP or above, 17 CCR 95374(c) | 1 January 2025, on equipment manufactured after that date |
| Washington | WAC 173-443-030 | above 750 GWP, WAC 173-443-040 Table 3 | conditional — see below |
| New York | 6 NYCRR 494-1.3 | the federal limits at 40 CFR 84.54, adopted by reference | 1 January 2026 |
The exception these three left out
Every one of the nine states carries a normal-maintenance exception that lets a component of an existing system be replaced without the prohibition applying. Every one of them carries it in the refrigeration rules, for supermarket cases and cold storage. The three that reach a house do not carry it for air conditioning.
California’s is the clearest, because both sit in one section: 17 CCR 95375(b)(2)(C) exempts replacing a refrigeration component as normal maintenance, and the four exceptions for air conditioning at 95375(c)(2) are chillers, small refrigeration, very low temperature use and a building permit approved before the effective date. Washington’s Table 2 for refrigeration and Table 3 for air conditioning are printed one after the other with the same asymmetry.
An exception written once for one sector and never for the other, on facing pages, is hard to read as an oversight.
Washington’s date, honestly
Washington’s table gives 1 January 2026 for residential air conditioning if the state building code council adopted UL 60335-2-40 Edition 4 by 31 December 2023, and otherwise 24 months after adoption.
The 2021 mechanical code as printed for Washington in March 2024 still referenced the 2019 edition of that standard. The council then made A2L amendments by emergency rule in February 2025, extended in June 2025, with permanent rulemaking under way. Which of those events is “adoption of the updated code” decides whether the prohibition is already in force or lands in 2027, and this site has not established it.
So: the definition is settled, the date is not, and a Washington reader should ask the Department of Ecology or their contractor which date they are working to rather than take a number off any web page, this one included.
Who these rules are actually aimed at
Mostly at the trade. The verbs are commercial ones — manufacture, sell, lease, distribute, install, enter into commerce — and Washington’s air conditioning prohibition at WAC 173-443-075(1) reads exactly that way.
Two of the three go further, and it is worth knowing which.
- California’s list of prohibited acts at 17 CCR 95375(c)(1) includes use, alongside sell, lease, rent and install.
- New York’s is the most direct. Its first prohibition says no person may install a field-charged system using a prohibited substance, “nor have any such system be installed through their position as a designer, owner, or operator of that system.” A residential split system is charged on site. The owner is named in the sentence.
So do not read this page as the rule binds your contractor and not you. New York’s environmental department publishes a factsheet saying residential users are not regulated under Part 494; the rule text names the owner of a field-charged system. This site is not going to tell you which of those wins, and it does not have to — the practical answer is the same either way, because a job that cannot lawfully be done does not get done.
What is settled is the other direction: New York states plainly that nothing in the regulation requires anyone who acquired equipment before the prohibition date to stop using it. None of these rules is about the system you already own.
One more piece of New York timing worth having, because it separates two dates people merge: installing is barred from the prohibition date, and selling is barred a year later. So in the window between them the unit can still be bought in New York and cannot lawfully be put in.
What this does not tell you
- Eleven states, and nothing about the other thirty-nine. New Jersey has an HFC statute that was not opened for this page. Everywhere else, either there is no state rule and the federal answer stands, or there is one nobody here has looked for. The absence of your state from the table is not a “no”.
- Rules move. Every date here comes from a rule that can be amended, and two of the nine were amended in the last two years. The table says when each document was read; a rule read a year ago is a rule worth re-opening.
- It says nothing about your existing system. No rule on this page requires anyone to remove or replace working equipment. They are about what may be sold and installed.
- It is not the manufacturer’s answer. Even where the swap is lawful, the outdoor unit still has to be one the manufacturer approves against the coil you already own, and that is a different question answered on the brand rules page.
What to ask your installer
- Which state rule are you working to, and does it treat a condenser replacement as new equipment?
- What is the date of manufacture of the outdoor unit you are quoting? In California that is the number the prohibition turns on.
- If the R-410A route is closed here, what does the A2L system cost, and does it need the indoor coil replaced as well?
Questions people ask
Which states will not let me replace only the outdoor unit with R-410A?
California, Washington and New York, of the eleven state rules read for this site. All three define new air conditioning equipment to include an existing system with a single condenser and single evaporator that gets a new exterior condenser or condensing unit, so the ordinary swap is new equipment there rather than servicing. Eight others — Colorado, Rhode Island, Maine, Massachusetts, Virginia, Maryland, Delaware and Vermont — define air conditioning equipment as chillers, which is not a house. New Jersey has an HFC statute that has not been read here.
Do these rules bind me, or only my contractor?
Mostly the trade — the prohibited acts are manufacturing, selling, distributing and installing. But California's list also includes use, and New York's says no person may have a field-charged system installed through their position as designer, owner or operator, which names the owner. New York's own factsheet says residential users are not regulated; the rule text is less comfortable than that. Either way nothing here touches the system you already own: New York states expressly that nobody has to stop using equipment acquired before the prohibition date.
Why do these state rules copy each other word for word?
Because there are only two drafts in circulation and almost every state picked one. The older one, written from the federal SNAP prohibitions, defines air conditioning equipment as chillers and never reaches a house. The newer one, written from California's 2020 order, lists ducted central air conditioners and heat pumps and adds the single-condenser sentence. Eight of the eleven states read here use the first, three use the second, and which one your state adopted is the entire answer.
The rules this rests on
In force California counts a new outdoor unit alone as new equipment. California prohibits air-conditioning equipment using a refrigerant at or above 750 GWP, manufactured after its 1 January 2025 effective date, from being sold, installed or otherwise entered into commerce in the state, at 17 CCR 95374(c). R-410A is far above 750. What decides the question this site is about is the definition beside it: 17 CCR 95373 counts as "New Air-conditioning Equipment" an existing system with a single condenser and single evaporator that gets a new exterior condenser or condensing unit — which is exactly the outdoor-unit-only replacement the federal rule treats as servicing. The four exceptions in 17 CCR 95375(c)(2) are chillers, small refrigeration, very low temperature use and a building permit approved before the effective date; none of them is a maintenance or component-replacement exception for air conditioning. The prohibition bites on the date of manufacture, so R-410A equipment built before 1 January 2025 may still be installed.
In force Washington counts a new outdoor unit alone as new equipment too. Washington's rule is built the same way as California's and reaches the same place. WAC 173-443-030 counts as "new air conditioning equipment" a system in an existing facility with a single condenser and single evaporator that has a new exterior condenser or condensing unit, and WAC 173-443-075(1) forbids any person to sell or install new air conditioning equipment using a substance prohibited by Table 3 — refrigerants above 750 GWP. The exemptions for air conditioning at WAC 173-443-050 are two, a building permit predating the chapter and mission-critical military use; the refrigeration tables carry a normal-maintenance component-replacement exemption and the air conditioning table does not. The date is the open part: Table 3 sets 1 January 2026 for residential air conditioning if the state building code council adopted UL 60335-2-40 Edition 4 by 31 December 2023, and otherwise 24 months after adoption. This site has not established which branch applies, so a Washington reader should ask the Department of Ecology or their installer which date they are working to.
In force New York applies the federal limit through its own definition of "new". New York's amended Part 494 prohibits regulated substances in residential and light commercial air conditioning and heat pumps from 1 January 2026, and it does so by adopting the federal EPA requirements at 40 CFR 84.54. What differs is the word "new". At 6 NYCRR 494-1.3 the state's own definition counts as new any air conditioning equipment with a single condenser and single evaporator that has a new exterior condenser, condensing unit, or remote condensing unit installed after the prohibition date — the same sentence California and Washington use, and the one the federal rule does not have. New York's first prohibition also reaches further than the trade: no person may install a field-charged system using a prohibited substance, nor have one installed through their position as designer, owner or operator. Installing is barred from the prohibition date and selling a year after it. Nothing in the Part requires anyone who acquired equipment before that date to stop using it.
In force Eight states define air conditioning as chillers, and never reach a house. Colorado prohibits high-GWP refrigerants in air conditioning equipment under AQCC Regulation Number 22, and then defines air conditioning equipment, at 5 CCR 1001-26 Part B section I.B.2, as chillers — centrifugal and positive displacement — intended for comfort cooling of occupied spaces. A ducted residential split system is not a chiller, so the prohibition does not reach the outdoor unit on a house. Colorado is not alone in this and the wording is not a coincidence: Rhode Island, Massachusetts, Virginia, Maryland, Delaware and Vermont define the term in the same words, and Maine in a shorter version of them. Eight of the eleven state rules read for this site are this draft, which is why having an HFC rule and reaching a home system are two different questions. Delaware carries it at 7 DE Admin. Code 1151 and Vermont at Chapter 38 of its air pollution control regulations; on both, the air conditioning end-use table has exactly two rows, centrifugal chillers and positive displacement chillers, with R-410A prohibited in each from 1 January 2024.
Sources
- California Air Resources Board — California HFC Regulation, Final Regulation Order — Prohibitions on Use of Certain Hydrofluorocarbons (17 CCR 95371-95379) . Read 2026-09-04.
- Delaware Department of Natural Resources and Environmental Control — 7 DE Admin. Code 1151 — Prohibitions on Use of Certain Hydrofluorocarbons in Specific End-Uses . Read 2026-09-06.
- Vermont Agency of Natural Resources — Vermont Air Pollution Control Regulations Chapter 38 — Rules Regarding Phase-Down of the Use of Hydrofluorocarbons . Read 2026-09-06.
- Washington State Department of Ecology — Chapter 173-443 WAC — Hydrofluorocarbons (HFCs) and Other Fluorinated Greenhouse Gases . Read 2026-09-04.
- New York State Department of Environmental Conservation — 6 NYCRR Part 494 — Hydrofluorocarbon Standards and Reporting, Express Terms . Read 2026-09-04.
- Colorado Air Quality Control Commission — Colorado AQCC Regulation Number 22 — Greenhouse Gas Reporting and Hydrofluorocarbon Prohibitions (5 CCR 1001-26) . Read 2026-09-04.
- Rhode Island Department of State — 250-RICR-120-05-53 — Prohibition of Hydrofluorocarbons in Specific End-Uses . Read 2026-09-04.
- Maine Legislature — 38 M.R.S. §1613 — Hydrofluorocarbon use restrictions . Read 2026-09-04.
- Massachusetts Department of Environmental Protection — 310 CMR 7.76 — Prohibitions on Use of Certain Hydrofluorocarbons in Refrigeration, Chillers, Aerosol Propellants, and Foam End-uses . Read 2026-09-04.
- Virginia State Air Pollution Control Board — 9VAC5-145-110 — Definitions, Regulations for Control of Greenhouse Gases . Read 2026-09-04.
- Maryland Department of the Environment — COMAR 26.11.33.02 — Definitions, Prohibitions on Use of Certain Hydrofluorocarbons in Aerosol Propellants, Chillers, Foam, and Stationary Refrigeration End-Uses . Read 2026-09-04.
- US Environmental Protection Agency — Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020 . Read 2026-09-02.
This is a starting point, not an approval. Everything here is read from published manufacturer documents and dated, but only the licensed contractor who signs your installation can approve a specific system for your home and your local code. Take the citations on this page to them and ask.