Important Update: Court Temporarily Suspends New York State Restrictions on R-404A and R-507A
We are writing to provide an update to share publicly available developments regarding the New York State Department of Environmental Conservation (“NYSDEC”) regulations (6 NYCRR Part 494) as they relate to the purchase and sale of bulk R-404A and R-507A. On March 27, 2026, the Supreme Court of the State of New York, Appellate Division, issued an Order to Show Cause which provides that, pending further proceedings (1) NYSDEC’s existing enforcement discretion relating to certain provisions of 6 NYCRR Part 494 as applied to R-404A and R-507A is extended, and (2) NYSDEC is enjoined and restrained from enforcing the 6 NYCRR 494-1.4(f)(1) prohibition on the sale or purchase of bulk refrigerants as it applies to R-404A and R-507A. At the time of this update, NYSDEC has not issued additional guidance following the court’s order.
For reference, publicly available materials addressing these developments include the following:
Third-Party Coverage (for reference only):
NYSDEC Resources:
NYSDEC Climate Regulations – https://on.ny.gov/climateregs
Enforcement Discretion Letter (July 21, 2025) –https://dec.ny.gov/sites/default/files/2025-07/part494edletter.pdf
Part 494 FAQ – https://dec.ny.gov/sites/default/files/2025-02/part494faq.pdf
Part 494 Fact Sheet – https://dec.ny.gov/sites/default/files/2025-05/part494factsheet.pdf
Daikin Northeast Operational Note: As of the date of this communication, and pending further judicial orders and official guidance from NYSDEC, Daikin Northeast continues to conduct business consistent with applicable laws, regulations and currently effective court orders. This statement is not intended to interpret regulatory requirements or address any customer‑specific compliance obligations. As with all regulatory matters, our practices may evolve as additional official guidance or court decisions become available.
* This update is an abbreviated summary, and is provided solely to share publicly available information and is not intended to provide regulatory or legal advice or to interpret how the regulations or court order may apply to any particular transaction or circumstance.