New York Delays R-404A & R-507A Restrictions — What It Means for Contractors

If you sell or service commercial refrigeration systems in New York, you've been watching the Part 494 situation closely. On March 27, 2026, an appellate court issued a temporary block on enforcement — giving the industry crucial breathing room. Here's the full breakdown.

What Is Part 494?

New York State Department of Environmental Conservation (NYSDEC) adopted Part 494, imposing stricter and faster HFC phasedown requirements than the federal EPA in many areas. The regulation targets high-GWP (Global Warming Potential) refrigerants and sets aggressive timelines for their elimination.

Key elements of Part 494 include:

• Earlier prohibitions on high-GWP refrigerants (e.g., above 2,200 GWP, or specific thresholds like GWP 150–700 depending on the sector and date)
• Restrictions on the sale, distribution, and use of virgin bulk refrigerants such as R-404A and R-507A — widely used in commercial refrigeration for supermarkets, cold storage, convenience stores, and restaurants
• Shorter sell-through periods for equipment compared to EPA (often 1 year vs. EPA's longer flexibilities)
• Sector-specific rules, including tighter GWP limits for new commercial refrigeration systems starting in 2025–2026

These rules were designed to accelerate the transition beyond federal timelines, but they created concerns about supply shortages, stranded inventory, and misalignment with available low-GWP alternatives and federal allowances.

The Court Delay — What Happened

In early 2026, HARDI (Heating, Air-conditioning & Refrigeration Distributors International) challenged aspects of Part 494 and requested enforcement discretion — essentially a temporary pause — to avoid immediate disruptions to the supply chain.

The NYSDEC had previously granted some short extensions in 2025, but rejected further extensions in March 2026. Enforcement of the bulk virgin refrigerant sales prohibition for certain high-GWP options (particularly R-404A and R-507A) was set to tighten or fully kick in after March 31, 2026.

Then, on March 27, 2026, the Appellate Division of the New York State Supreme Court (Third Department) issued a ruling in response to HARDI's legal challenge:

• It granted an Order to Show Cause and temporarily blocked the NYSDEC from enforcing the ban on R-404A and R-507A
• This extends the prior enforcement discretion beyond March 31, 2026, while the court considers a preliminary injunction
• The stay allows continued sale, distribution, and purchase of these refrigerants (at least for maintenance and servicing of existing systems) in the near term, preventing an immediate supply shock

What This Means for Your Business

Short-Term Relief

If you serve New York customers or sell into the state, you can continue handling and selling R-404A and R-507A for servicing existing equipment without the immediate prohibition that was looming. This buys critical time for supply chains and transition planning.

Ongoing Risk

The delay is not indefinite. Monitor for the court's next decision on the injunction. If the ban is ultimately enforced, virgin high-GWP refrigerant sales could face sharp restrictions, pushing demand toward reclaimed refrigerant, lower-GWP drop-ins, or full system retrofits.

Federal vs. State Tension

New York's rules remain more aggressive in some sectors, particularly commercial refrigeration GWP limits. EPA's proposed reconsiderations and flexibilities for 2026–2032 (in areas like retail food refrigeration) may influence state actions, but states retain the authority to go beyond federal minimums.

Opportunities for Contractors

The shifting regulatory landscape creates increased demand for:

• Compliant low-GWP refrigerants (R-454B, R-32, and others)
• Reclamation services and reclaimed refrigerant supply
• Leak repair tools and services (especially with the federal 15-lb threshold now active)
• A2L handling training and certification
• Customer guidance on New York-specific compliance requirements

Stock Up While You Can

At Twisted Refrigerant, we carry full inventory of R-404A, R-507A, and every major refrigerant — factory sealed, AHRI-700 certified, and EPA §608 compliant. Whether you're in New York or shipping nationwide, we've got you covered.

Need bulk pricing? Visit our wholesale portal or call us at (855) 307-COOL.

Stay Informed

For the most up-to-date information, we recommend checking the official NYSDEC Part 494 page and FAQ directly, along with updates from HARDI and ACCA. Court dockets and industry alerts will provide the next developments on whether the block becomes longer-term.

We'll keep posting updates here as the situation evolves. Subscribe to our newsletter below to stay in the loop.