On Jan. 1, 2023, the national minimum efficiency rating for heat pumps will decrease from 8.2 to 7.5. Yes, you read that right, the number will go down. But, don’t be mistaken. While the number may be decreasing, equipment performing at the minimum efficiency will actually be more efficient – much more efficient, in fact.  

Are you confused? Let me explain…

Testing Procedures 2.0

In the New Year, all commercial air conditioning and heat pump equipment from 65,000-760,000 Btuh will undergo a 15% efficiency increase from the existing ratings set in 2018. Combined with the efficiency requirements implemented in 2018, this will result in a 30% increase over the six-year period.

Minimum efficiencies for split system heat pumps will increase from 14 SEER to the equivalent of 15 SEER, and 8.2 HSPF to the equivalent of 8.8 HSPF. The key word in that sentence is “equivalent.” I say that because new testing procedures, conducted under the name Appendix M1, birthed new efficiency ratings: SEER2, EER2, and HSPF2.

Compared to today’s test procedures, the external static pressure used when testing will be increased, as much as fivefold, to better reflect field conditions. The cumulative impact is that these 2.0 metrics have lower numerical values: 8.8 HSPF is equal to 7.5 HSPF2 and 15 SEER is the same as 14.3 SEER2. While an HSPF2 rating of 7.5 is, obviously, numerically lower than today's rating of HSPF 8.2, minimally compliant HSPF2 products rated at 7.5 are expected to be 7% more efficient.

And, while 7% may not sound like a great amount, approximately 70% of current equipment does not meet these new minimum efficiency standards. Estimates reveal savings of about 300 million kWh over 30 years of sales, equivalent to the power used by 27 million households in one year, saving approximately $38 billion in utility bills.

Air Conditioning Systems

Through new regulations, the DOE is increasing the efficiency of commercial air conditioning systems in two phases. The first phase occurred in 2018 and consisted of a 13% increase in minimum efficiency, while the second phase will take place in 2023 and require an additional 15% increase in part-load (IEER) efficiency.

Regulations will be enforced nationally (not on a regional basis, like new residential standards), and DOE compliance is based on the ship date. After Dec. 31, the efficiency changes for all commercial air-cooled unitary products will fall into three different categories based on the capacity of the equipment, measured in million British thermal units per hour (MBH):

  • 0-66 MBH three-phase products: ASHRAE 90.1-2019 and any equivalent state or local code will require new SEER2 and HSPF2 minimum efficiency ratings.
  • 67-760 MBH: ASHRAE 90.1 and any equivalent state or local code will require new IEER minimum efficiencies. In addition, the DOE requires manufacturers to comply with these minimums on any unit shipped in the U.S. after Dec. 31, 2024.
  • 760 MBH and greater: ASHRAE 90.1 and any equivalent state or local code will require new IEER minimum efficiencies.


Refrigerants for many HVAC applications will be limited to a maximum global warming potential (GWP) of 750 in 2025.

The EPA regulates refrigerants through power cited by the Clean Air Act and now the AIM Act passed by Congress in December 2020. The AIM Act grants EPA authority, based on the supply of hydrofluorocarbons (HFCs), to develop product-specific regulations and facilitate refrigerant management practices.

In 2025, regulations are changing for residential and commercial air conditioners and heat pumps. Nationally, R-410A and R-407C will no longer be permitted for use in new equipment.

It is anticipated that regulations and codes requiring the transition in 2025 to refrigerants with zero ozone depletion potential (ODP) and a GWP of lower than 750 will soon be finalized. In 2024, the supply of HFCs is expected to be reduced by 40% in preparation of proposed 2025 refrigerant changes. Refrigerant recovery will become crucially important, considering the stepdown in supply.

EPA-approved replacements for R-410A include R-32 and R-454B. The energy efficiency performance of these gases is similar to R-410A, meaning air conditioners and heat pumps will not need to get significantly larger like they did when the industry transitioned from R-22 to R-410A. A significant redesign of products will likely occur to accommodate the ASHRAE classification of these replacements as lower flammability (A2L) refrigerants are used. Neither R-32 nor R-454B are considered drop-in replacements. Thus, for split systems, both the indoor and outdoor units must be replaced together.

Final Thoughts

Government regulations are beyond our control. There’s very little we, personally, can do to change them. However, that doesn't mean we have to like or agree with them.

My gripe comes in the naming of these “new” efficiency ratings. How much confusion will exist between the 1.0 and 2.0 versions of these ratings? Whose idea was it to simply slap the number 2 at the end of EER, SEER, and HSPF and call it a day? How many clerical errors will occur as a result? How many questions will arise regarding the differences in the OG ratings and the 2.0 versions? Couldn't we have just retained the original acronyms and rolled with the resulting ratings?

Additionally, greater efficiency numbers are great, but they're only one part of the equation. Other factors, such as: Is the equipment properly installed, is the equipment being adequately maintained, is the building's envelope sealed appropriately, etc., play a significant role in the equipment's performance.

So, what do you say? Are these efficiency regulations necessary, or are they another classic example of government overreach? Regardless how you feel about them, it's imperative your firm communicate these changes to clients. I'm interested to hear how you did just that. Send me your thoughts to the email address listed below, and I’ll do my best to share your process with our audience in a future issue.