The AIM Act refrigerant phasedown is the federal program, signed into law in December 2020, that requires an 85 percent cut in U.S. hydrofluorocarbon (HFC) production and consumption below historical baselines by 2036. The Environmental Protection Agency runs it through three levers: a shrinking cap on how much HFC refrigerant can be produced or imported each year, limits on which refrigerants can go into new equipment in specific industries, and tighter rules on recovering and reusing what’s already in circulation.1US EPA. Background on HFCs and the AIM Act HFCs don’t harm the ozone layer, but they trap hundreds to thousands of times more heat than carbon dioxide, which is why Congress targeted them.
The Phasedown Schedule
The EPA sets a national ceiling on HFC production and consumption each year, measured in exchange value equivalents that weight each chemical by its warming potential. Companies receive individual allowances, and no one can produce or import regulated substances without holding enough to cover the activity.2Office of the Law Revision Counsel. 42 Code 7675 – American Innovation and Manufacturing Allowances can be bought and traded, which pushes companies to switch to alternatives faster than the schedule strictly requires.
The cuts step down on this schedule:
- 2022–2023: 90 percent of baseline (10 percent cut)
- 2024–2028: 60 percent of baseline (40 percent cut)
- 2029–2033: 30 percent of baseline (70 percent cut)
- 2034–2035: 20 percent of baseline (80 percent cut)
- 2036 onward: 15 percent of baseline (final 85 percent reduction)
The 2024 drop from 90 to 60 percent was the steepest single step, and it tightened refrigerant supply across the market immediately.3Federal Register. Phasedown of Hydrofluorocarbons Allowance Allocation Methodology for 2024 and Later Years The next major squeeze comes in 2029.
Equipment Restrictions by Sector
Alongside the production cap, the EPA’s Technology Transitions program limits the global warming potential (GWP) of refrigerants that can be used in new equipment by industry. GWP measures heat-trapping ability against carbon dioxide over 100 years. R-410A, the residential air conditioning standard for two decades, has a GWP around 2,088, well above the new ceilings.
Most new commercial refrigeration equipment must use refrigerants with a GWP of 150 or lower. That covers supermarket systems, vending machines, stand-alone retail food units, and commercial ice machines. Smaller industrial process refrigeration units holding less than 200 pounds of refrigerant get a limit of 300.4US EPA. Technology Transitions HFC Restrictions by Sector
New residential and light-commercial air conditioners and heat pumps manufactured or imported after January 1, 2025, must use lower-GWP refrigerants. In practice, that means R-454B (GWP 466) or R-32 (GWP 675) instead of R-410A. Both are classified as A2L, meaning mildly flammable, which has changed equipment design and building codes.5US EPA. Frequent Questions on the Phasedown of Hydrofluorocarbons
The EPA originally set January 1, 2026, as the deadline for installing R-410A equipment that had been manufactured before the 2025 cutoff. In late 2025 the agency announced that enforcing the installation deadline is a low priority while it reconsiders the rule, and it may remove that restriction entirely. The manufacturing ban on new R-410A equipment remains fully in effect.
What This Means for Homeowners and Businesses
If you already own an R-410A air conditioner, you don’t have to replace it. The AIM Act targets new equipment, not existing installations, and your current system can be serviced and recharged with R-410A for as long as supply lasts. Supply is the catch. As the phasedown cuts deeper, R-410A will get scarcer and more expensive, following the pattern anyone remembers from the R-22 phaseout: prices creep, then jump.
When you do replace the system, the new unit will use an A2L refrigerant like R-454B. You can’t drop R-454B into an R-410A system. The two operate at different pressures and carry different flammability profiles, so R-454B needs equipment built for it. Budget for a full system replacement rather than a refrigerant swap.
Businesses running commercial refrigeration face a tighter runway. New equipment must meet the GWP limits above, and the 2029 step will cut available HFC supply to 30 percent of baseline. Building a transition timeline now lets you stagger equipment purchases instead of replacing a whole fleet under deadline pressure.
Recovery, Reclamation, and Leak Repair
Every pound of existing refrigerant gets more valuable as new production shrinks, and the AIM Act’s management provisions, run through the EPA’s Emissions Reduction and Reclamation (ER&R) program, are designed to keep that refrigerant in circulation instead of vented into the air.6Office of the Law Revision Counsel. 42 Code 7675 – American Innovation and Manufacturing – Section: Management of Regulated Substances
Technicians must recover refrigerant using certified equipment. Recovered HFCs have to be routed through an EPA-certified reclaimer before they can be resold or transferred to a new owner, and reclaimed product must meet the purity specifications in AHRI Standard 700.7Electronic Code of Federal Regulations. 40 CFR Appendix A to Subpart F of Part 82 – Specifications for Refrigerants
Leak repair rules vary by refrigerant. Under ER&R, equipment holding 15 or more pounds of an HFC or HFC substitute with a GWP above 53 triggers repair obligations once leak rates cross the specified thresholds.8US EPA. Leak Repair Requirements for Appliances Containing HFCs The older Section 608 program, which still governs ozone-depleting refrigerants like R-22, kicks in at 50 pounds and uses different trigger rates by equipment type. Under both programs, repairs generally must be completed within 30 days of discovery, or the owner has to develop a retrofit or retirement plan.9US EPA. Stationary Refrigeration Leak Repair Requirements
Starting January 1, 2028, disposable cylinders that held HFCs for equipment servicing must be sent to a certified reclaimer, a fire suppressant recycler, or another qualified processor to strip out the residual “heel” before disposal.5US EPA. Frequent Questions on the Phasedown of Hydrofluorocarbons
Technician Certification
Anyone who services, repairs, or disposes of equipment in a way that could release refrigerant must hold EPA Section 608 certification. The levels are:
- Type I: small appliances like window units and household refrigerators
- Type II: high-pressure and very-high-pressure systems, covering most residential and commercial air conditioning
- Type III: low-pressure systems, such as large centrifugal chillers
- Universal: all equipment types
Certification requires passing an EPA-approved exam through an approved testing organization, and Universal certification requires a proctored core exam. The credential does not expire. Apprentices working under direct supervision of a certified technician are exempt during training.10US EPA. Section 608 Technician Certification Requirements
The move to A2L refrigerants adds a practical complication. Section 608 training wasn’t built around flammable refrigerant handling, so industry organizations have developed separate A2L safety certifications covering installation in confined spaces, transportation, and general handling. The EPA hasn’t mandated a federal A2L credential, but many manufacturers and employers already require one, and local building codes increasingly expect it.
Penalties and Enforcement
The EPA enforces the AIM Act through the Clean Air Act’s penalty structure. Civil penalties can reach $124,426 per day per violation, adjusted periodically for inflation.11eCFR. 40 CFR 19.4 – Statutory Civil Monetary Penalties, as Adjusted for Inflation Knowing violations carry criminal exposure of up to five years in prison for a first offense, doubled for repeat convictions.12Office of the Law Revision Counsel. 42 Code 7413 – Federal Enforcement Falsifying reports or failing to keep required records carries up to two years, also doubled for repeat offenses.
Because shrinking supply and rising prices create obvious incentives to smuggle, the federal government stood up an Interagency Task Force on Illegal HFC Trade, co-chaired by the EPA and the Department of Homeland Security.13US EPA. U.S. Takes Aim at Violators of Greenhouse Gas Phasedown and Reporting Programs In March 2024, that effort produced the first criminal prosecution under the AIM Act, charging an individual with smuggling HFCs across the U.S.–Mexico border for resale.14US EPA. Operation Disrupt HFCs Companies that produce, import, export, or destroy regulated substances have to file detailed reports with the EPA, and container tracking and labeling requirements let the agency verify that refrigerant on the market was legally sourced.
How This Connects to the Kigali Amendment
The AIM Act is the U.S. domestic vehicle for meeting a parallel international obligation. The United States ratified the Kigali Amendment to the Montreal Protocol on October 31, 2022, which commits participating countries to a global HFC phasedown, and the EPA is responsible for keeping the country in compliance with that treaty.15US EPA. The Montreal Protocol Kigali and HFCs 2024 Transition Briefing Paper The domestic schedule aligns closely with Kigali targets, which keeps U.S. manufacturers and importers in step with international markets and avoids trade complications for companies that ship refrigerants or refrigerant-containing equipment abroad.