By Yevhen Kovalchuk · Updated October 13, 2026 · 6 min read
Short answer
The AIM Act is a 2020 federal law that directs EPA to cut U.S. production and import of hydrofluorocarbon (HFC) refrigerants by 85% below a 2011–2013 baseline by 2036. It works through three programs: a phasedown of HFC allowances, management rules for leaks and reclaimed refrigerant, and sector limits on the global warming potential of new equipment. Existing systems can keep running; the pressure falls on new equipment, supply and price.
The American Innovation and Manufacturing (AIM) Act of 2020 is the federal law that is phasing down hydrofluorocarbons, the HFC refrigerants used in air conditioning, chillers and refrigeration. It directs EPA to reduce U.S. HFC production and consumption by 85% below a historic baseline by 2036. It does not ban running existing equipment. It limits how much HFC can be made and imported, sets rules for how HFCs are managed, and restricts which refrigerants can go into new equipment.
What does the AIM Act require?
The law gives EPA three jobs:
- Phase down HFC production and consumption through an allowance system.
- Manage HFCs and their substitutes, including leak repair, recordkeeping and reclaimed refrigerant.
- Restrict HFC use in new products and equipment, which EPA calls the Technology Transitions program. See our article on the Technology Transitions rule update.
The law is aligned with the Kigali Amendment to the Montreal Protocol, the international agreement to phase down HFCs.
How does the phasedown schedule work?
The baseline is the average of HFC production and consumption in 2011 through 2013, measured in carbon dioxide equivalent so that high-GWP refrigerants count for more than low-GWP ones. The statutory steps, as summarized by the Congressional Research Service, are:
| Period | Cap vs. baseline |
|---|---|
| 2022–2023 | 10% reduction |
| 2024–2028 | 40% reduction |
| 2029–2033 | 70% reduction |
| 2034–2035 | 80% reduction |
| 2036 and after | 85% reduction |
Some secondary sources print different years; rely on EPA and CRS figures. The law also lets EPA consider petitions to speed up the schedule after 2024.
What is an HFC allowance?
An allowance is a permit to produce or import a set amount of HFC, measured in CO2 equivalent. EPA allocates allowances to companies each year and the allowance total shrinks along the schedule. Because allowances are tradable, they carry a price, and that price flows into the cost of refrigerant. Refrigerants with high GWP, such as R-404A and R-410A, use up more allowances per pound, so they are the first to get scarce and expensive.
What does the AIM Act change for equipment owners?
- New equipment. The Technology Transitions rule sets GWP limits for new systems by sector, which pushes the market to A2L refrigerants such as R-32 and R-454B, to CO2, and in some applications to hydrocarbons. See A2L refrigerants explained.
- Existing equipment. You can keep operating and servicing it. The practical effect is supply and price: high-GWP refrigerant gets more expensive over time and reclaimed refrigerant becomes a larger share of supply.
- Leaks. EPA’s management rule for HFCs adds leak repair requirements for larger appliances that hold HFC or substitute refrigerant with a high GWP. The rule applies by charge size and refrigerant GWP, and it requires leak rate calculations and records. Check the current EPA page for exact thresholds and dates before setting a plan. A leak rate calculation is straightforward; see the leak and recordkeeping basics in our 2026 refrigerant overview.
- Reclaimed refrigerant. Reclaim and recycling requirements apply to recovered HFCs, including how reclaimed refrigerant is certified and labeled.
Which refrigerants are affected?
All HFCs are covered, including R-134a, R-404A, R-407C, R-410A and R-507A. The regulation counts them by GWP, so the highest-GWP products are the main target. HFOs and natural refrigerants such as CO2, ammonia and hydrocarbons are not part of the HFC phasedown, though they have their own safety codes and rules. If your plant uses ammonia, the phasedown is not the main regulation you follow; OSHA PSM and EPA RMP are.
What should facility teams do now?
- Inventory. List every system by refrigerant, charge size and age.
- Flag high-GWP systems. R-404A and R-410A units near the end of their life should be planned for replacement, not left to fail.
- Set a leak program. Track charge, top-ups and leak rate for larger systems; repair leaks promptly.
- Buy ahead for replacements. Specify equipment designed for lower-GWP refrigerants and check code requirements for A2L.
- Track the rules. EPA revised parts of the Technology Transitions rule in May 2026, and dates for some sectors changed. Confirm dates on the EPA pages, not on vendor summaries.
Texas adopted the 2024 editions of the international mechanical codes in 2026, partly because of A2L refrigerants. Local enforcement varies between cities, so check with the local authority for your project.
How does the phasedown reach equipment owners in practice?
The AIM Act regulates producers and importers, not individual building owners, but the effects travel downstream.
- Supply and price. As allowances shrink, high-GWP refrigerants become scarcer, which tends to affect the cost of servicing older equipment. Planning ahead is easier than reacting to a shortage.
- New equipment. Separate EPA rules restrict which refrigerants can be used in new products; see the Technology Transitions update.
- Reclaimed refrigerant. Reclaim becomes more valuable as supply tightens; refrigerant reclaim and recycling explains the basics.
- Leak management. Reducing leaks reduces both cost and regulatory exposure; see EPA 608 leak repair rules.
- Deadlines. Dates that matter for commercial refrigeration are summarized in HFC deadlines in January 2027.
Keep an inventory of refrigerants and charges so decisions are made calmly. Confirm current requirements at epa.gov.
Frequently asked questions
Is the AIM Act a ban on R-410A or R-404A?
No. It reduces how much can be produced and imported and restricts new equipment designs. Existing systems can continue to run and be serviced.
When does the phasedown end?
The schedule reaches an 85% reduction in 2036 and stays there.
Does the AIM Act apply to ammonia or CO2 systems?
No, those are not HFCs. They are covered by other rules and codes.
We follow these rules because SpecServis is planning to enter the Central Texas market. We are looking for technicians, partners and a company to buy. See our open positions or partnership options.
