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REGULATORY UPDATE
January 9, 2026
TECHNOLOGY TRANSITIONS RULE RECONSIDERATION
The EPA indicated in late December 2025 that they intend to extend compliance dates through the Technology Transitions Rule Reconsideration. However, the current January 1, 2026 deadlines remain effective until they are modified through the rulemaking process. Enforcement of the current deadlines is considered a "low priority" for the Agency and the EPA intends to focus its resources on compliance with the new compliance dates that will be established by this rulemaking. However, the EPA may take any action necessary to protect human health and environment.
It is important to note, that while the EPA has indicated that enforcement of the now effective A2L rules is a "low priority," this is not a No Action Assurance and leaves much discretion up to local compliance managers as to how or if the current requirements will be enforced.
The EPA has not indicated a timeline for publication of the final rule, or what provisions may be modified in that final rule. Once the final rule is published, it will take 30 days to become effective. Until the final rule becomes effective, the previous rule, including the January 1, 2026 compliance dates remain technically effective.
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