Can you still repair R-22 and R-410A air conditioners in your rentals, or should you replace them?
You can keep running and repairing an R-22 system: production and import of R-22 ended on January 1, 2020, but EPA says existing systems may use it for as long as necessary, with recovered, reclaimed and older stock. R-410A systems can be repaired too; the federal limits apply to new equipment, and a May 2026 rule lets equipment made before 2025 still be installed. The real question is cost, which a simple per-year comparison answers.
Find out what each system uses
Start with an inventory. EPA notes that most air conditioners have a nameplate on the unit naming the refrigerant (EPA fact sheet on HCFC-22). Write down, for each unit: refrigerant, tonnage, manufacture date from the nameplate, and repair history. In an older building you may find R-22 condensers next to R-410A replacements from the 2010s and a few newer units on R-454B or R-32.
R-22: legal to run, costly to feed
R-22 (HCFC-22) is an ozone-depleting refrigerant. EPA's phaseout schedule ended U.S. production and import of HCFC-22 in 2020, and all HCFCs end in 2030. EPA's fact sheet is clear that no immediate change is required: "you may continue to use HCFC-22 in your existing system for as long as necessary." The supply now comes from refrigerant that was recovered and reclaimed or made before 2020.
Two cautions from the same fact sheet. A technician who retrofits a system to another refrigerant must recover the R-22 first and follow the manufacturer's guidance for the new one. And "R-22a" is not R-22: it is a flammable hydrocarbon blend that EPA says is not an acceptable alternative.
R-410A after the 2025 and 2026 rules
R-410A is an HFC with a global warming potential above 700. EPA's Technology Transitions rule, under the AIM Act, restricts the manufacture, import, sale and installation of new residential and light commercial air conditioning and heat pump systems that use refrigerants above that limit, starting with systems made from January 1, 2025 (EPA, Technology Transitions rules).
Installation of older stock was the open question. On May 21, 2026, EPA finalized a rule that removes the January 1, 2026 installation deadline for those systems made or imported before January 1, 2025, and allows that pre-2025 inventory to be installed "until supply runs out" (EPA fact sheet, May 2026). For an owner, that means a like-for-like R-410A replacement may still be possible if a supplier has pre-2025 equipment, while new equipment comes on lower-GWP refrigerants.
Whatever the refrigerant, the work belongs to certified people. EPA's Section 608 rules require technicians who service equipment that could release refrigerant to be certified, and it is illegal to knowingly vent refrigerant while servicing, repairing or disposing of equipment.
A repair or replace test you can run on any unit
Compare the cost per remaining year of each option. Use your technician's quotes and an honest guess of remaining life.
- Repair cost divided by the years the repaired unit is likely to last.
- Replacement cost divided by the expected life of new equipment.
- Add yearly refrigerant top-ups to the repair side if the system leaks.
- Add the yearly energy difference if you have it from utility bills or the equipment ratings.
- Pick the lower yearly number, unless downtime or tenant health risk outweighs it.
Example a made-up 12 unit building has R-22 condensers from 2007. The unit 4 compressor fails in July. Repair quote: $2,800, including reclaimed R-22. The technician expects 3 more years from the 19-year-old system, so repair costs $2,800 divided by 3, or about $933 a year, plus a leak that has needed $350 of refrigerant each summer: $1,283 a year. Replacement quote: $7,400 for a new matched system expected to last 15 years: $7,400 divided by 15, or about $493 a year. Replacement wins by about $790 a year, before any energy savings.
When several units of the same age are failing, price a block replacement. Doing four or five at once usually beats emergency replacements one July at a time, and it lets you plan the spending in your reserves.
Repair or improvement in the books
A compressor repair that keeps a system running is usually a repair. Replacing a whole heating and cooling system is usually an improvement that is capitalized and depreciated, though elections such as the de minimis safe harbor can change the treatment for smaller items. Keep the two apart in your books and let your tax preparer decide.
Running it in DoorKeeping
In DoorKeeping, each failure is a work order on the unit and goes to your HVAC vendor by link. The vendor's bill is read and coded into the property's books, and you can ask Claude or ChatGPT what you have spent on each unit's cooling over the last few years, which is the number the test above needs. Any payment still waits for your approval.
Sources
- EPA, Phaseout of Class II Ozone-Depleting Substances (HCFC schedule), read Oct 30, 2026
- EPA, Residential Air Conditioning and the Phaseout of HCFC-22: What You Need to Know (fact sheet), read Oct 30, 2026
- EPA, Section 608 Technician Certification, read Oct 30, 2026
- EPA, Regulatory Actions: Technology Transitions, read Oct 30, 2026
- EPA, Fact sheet: Technology Transitions reconsideration final rule (May 2026), read Oct 30, 2026
Questions
- Is it illegal to use R-22 in an apartment air conditioner?
- No. Production and import ended in 2020, but EPA says existing systems may keep using R-22 as long as necessary, supplied by recovered, reclaimed and pre-2020 refrigerant.
- Can I still install an R-410A air conditioner?
- New systems made from 2025 must use lower-GWP refrigerants. A May 2026 EPA rule lets R-410A equipment made or imported before January 1, 2025 still be installed until that supply runs out.
- Can R-22a be used to recharge an R-22 system?
- No. EPA says R-22a is a flammable hydrocarbon blend falsely marketed as an R-22 replacement and is not an acceptable alternative.