What is the AIM Act: The complete guide for refrigerant regulations in the USA

The U.S. government is ramping up its environmental policies, with the EPA announcing that the AIM Act will take full effect starting January 1, 2026. This marks a big shift for refrigerant management, especially for businesses relying on refrigeration and cooling systems. With so much at stake, it’s crucial to understand the new regulations and changes to stay compliant and steer clear of hefty fines.

What is the AIM Act?

The American Innovation and Manufacturing Act (AIM Act), is a law focused on reducing the use of HFCs (hydrofluorocarbons). These are powerful greenhouse gases commonly found in refrigerants used in air conditioning, refrigeration, and heat pumps. The goal is to phase down HFC production and import by 85% over the next 15 years, starting in 2022. 

Why take action now

The AIM Act carries strict penalties for businesses that fail to comply with its regulations. Enforcement is overseen by the EPA, which draws upon the robust mechanisms of the Clean Air Act. These include:

• Criminal Penalties: Imprisonment or criminal fines for severe violations.
• Civil Fines: Penalties of up to $102,638 per day for each violation.
• Separate Violations for Each Kilogram: Every kilogram of refrigerant distributed in violation of the AIM Act is considered a separate violation, amplifying the potential financial impact.
• Legal Actions: Administrative orders and court injunctions to halt non-compliant practices.

In a recent case, Clean Venture Inc, an environmental services company from Avenel, New Jersey, faced a civil penalty of $11,663 for violating AIM Act regulations. The company imported:

• 2,041.2 kg of R134a
• 22.7 kg of R407C
• 3.6 kg of R404A

Calculate your refrigerant leak rate

These penalties underscore the critical importance of adhering to the AIM Act’s provisions. Non-compliance not only exposes businesses to severe financial and legal consequences but can also harm their reputation. To avoid such outcomes, organizations should adopt advanced refrigerant management systems equipped with AI-driven telemetry, slow leak detection, sensor-based monitoring, automated repair workflows, and compliance tracking. These solutions ensure seamless adherence to regulations while enhancing operational efficiency.

What does the AIM Act cover?

The AIM Act is a comprehensive policy aimed at reducing the environmental impact of HFCs by addressing their production, consumption, and use across industries. Here’s a detailed breakdown of its core elements:

1. Production and Consumption Phasedown

At the heart of the AIM Act is the gradual reduction of hydrofluorocarbons (HFCs) in the U.S., following a stepwise schedule. The phasedown targets an 85% reduction in HFC production and import by 2036, aligning with international agreements like the Kigali Amendment to the Montreal Protocol. 

<Alt: AIM Act - HFC breakdown chart>

As the supply of HFCs decreases, the cost of these refrigerants is expected to rise, making leak detection strategies more critical than ever. With prices climbing, even small leaks could lead to significant financial losses for system owners. Investing in early leak detection systems not only helps minimize refrigerant waste but also reduces environmental impact, making it a win-win for both businesses and the planet.

2. Limitation of high GWP refrigerants

The AIM Act doesn’t just phase down the supply of HFCs—it also restricts their use in specific applications where safer, environmentally friendly alternatives are readily available. These restrictions target areas like:

• New commercial refrigeration systems: Encouraging businesses to adopt low-GWP refrigerants in their cooling setups.
• Residential and commercial air conditioning units: Phasing out high-GWP refrigerants in favor of sustainable options.
• Aerosols and foam products: Promoting the use of less harmful substitutes in manufacturing and packaging processes.

The goal is to shift the market toward cutting-edge technologies and sustainable refrigerants like hydrofluoroolefins (HFOs) and natural options such as ammonia, carbon dioxide, and propane. These alternatives not only align with climate goals but often offer improved energy efficiency and lower long-term costs.

3. Promotion of Sustainable Alternatives and Technologies

The EPA offers support through research initiatives, funding programs, and partnerships to develop and deploy advanced cooling technologies. Effective refrigerant management is a cornerstone of the AIM Act, aiming to reduce leaks, reclaim used gases, and enhance technician and consumer safety. While some regulations under this section are still being finalized, the key elements include:

Fire Suppression Systems: Standards for servicing and disposing of HFC-based fire suppression equipment are also expected.

Container Tracking and Recordkeeping: New rules will ensure better tracking and labeling of HFC containers to reduce illegal venting and ensure proper handling.

Reclamation and Recovery: The Act promotes the reuse of reclaimed HFCs, introducing stricter standards for their recovery, especially during the disposal of old equipment.

Stricter Leak Repair Standards: Regulations will set clearer guidelines for repairing leaks in appliances containing HFCs, ensuring timely action.

Mandatory Leak Detection Systems: Automatic Leak Detection (ALD) systems will become a requirement for new and existing equipment. These systems will help identify leaks early, minimizing environmental and financial impacts.

These measures aim to create a robust framework for reducing HFC emissions while improving safety and transparency in the industry.

Proposed Changes Under AIM Act Part III

The AIM Act’s upcoming updates (Part III) introduce more stringent requirements aimed at reducing HFC emissions, enhancing accountability, and promoting sustainable practices. These proposed changes build upon existing EPA Section 608 rules while introducing new measures to tackle leaks, promote reclamation, and enforce record-keeping. 

<Alt: AIM Act - Part III webinar with Keilly Witman>

Watch Webinar on Preparing for Part III of the AIM Act

Key highlights include:

1. Leak Management and Monitoring

• Mandatory Leak Inspections: Appliances with a full charge of 15+ lbs. of HFC refrigerant or substitutes with a GWP > 53 will be subject to regular leak inspections, excluding most residential and light commercial AC/heat pumps.
• Leak Repair Thresholds and Deadlines: Similar to Section 608, these thresholds ensure timely repairs, reducing emissions from chronically leaking systems.
• Chronically Leaking Appliance Rule: Systems that frequently leak will require annual reporting, creating accountability for persistent issues.
• Automatic Leak Detection Systems (ALDS): For new and existing systems with a charge of 1,500+ lbs., automatic leak detection systems will become mandatory, improving the speed and efficiency of leak identification.

2. Use of Reclaimed Refrigerant

Starting January 1, 2028, the AIM Act mandates the use of reclaimed refrigerant for servicing HFC systems. This encourages recycling and reduces the need for virgin HFCs, aligning with sustainability goals.

3. Management of Disposable Cylinders

From January 1, 2025, all disposable cylinders must be sent to a reclaimer for the removal of residual refrigerants (refrigerant heel). This ensures that no harmful gases are vented during disposal.

4. Enhanced Record-Keeping and Reporting

Accurate records will be crucial for compliance. Businesses must:

• Track Appliances: Ensure all systems with 15-49 lbs. of refrigerant are added to their tracking system.
• Maintain Leak History: Gather earlier leak records and monitor ongoing leak rates to avoid penalties under the chronically leaking appliance rule.
• Invoice Compliance: Service provider invoices should include compliance records for refrigerant adds. Unverified invoices should not be paid.
• Filing Leak Repair Extensions: Prepare policies for requesting and documenting repair extensions when delays occur due to part unavailability or other issues.

The Phase-Down Schedule

The AIM Act outlines a clear 15-year phasedown timeline (2022–2036) for the production and consumption of hydrofluorocarbons (HFCs) in the United States. This schedule is designed to gradually reduce HFC usage, ensuring industries have time to adapt while aligning with global climate commitments.

Timeline: Key Reduction Targets and Benchmarks

<Alt: AIM Act - phasedown schedule>

This stepwise approach allows businesses to plan ahead while minimizing disruptions in refrigeration and cooling sectors.

Who Should Pay Attention to the AIM Act?

The AIM Act has far-reaching implications, impacting a range of industries that use or rely on refrigerants. Whether you’re managing a grocery store, running a manufacturing plant, or servicing air conditioning systems, understanding and complying with these regulations is essential to avoid disruptions and penalties.

Industries Affected

1. HVAC-R (Heating, Ventilation, Air Conditioning, and Refrigeration)
   • Businesses involved in installing, servicing, or operating HVAC-R systems will need to ensure compliance with phasedown targets and leak management requirements.
   • Companies must adapt to low-GWP refrigerants and adopt mandatory leak detection systems where required.
2. Manufacturing (Aerosols, Foam Insulation, etc.)
   • Manufacturers of products like spray cans, foam insulation, and other applications using HFCs are subject to restrictions on high-GWP substances.
   • Transitioning to alternative, sustainable materials will be critical to staying compliant.
3. Food Retail and Storage
   • Supermarkets, food warehouses, and cold storage facilities rely heavily on refrigerants for cooling.
   • As HFC supply decreases and costs rise, these industries will need to invest in leak detection, reclaimed refrigerants, and energy-efficient systems to maintain operations.
4. Automotive Sector (Air Conditioning Systems)
   • Manufacturers and service providers in the automotive industry must adopt alternative refrigerants for vehicle air conditioning systems.
   • Compliance with AIM Act regulations is critical for avoiding production delays and ensuring sustainability in the automotive supply chain.

Steps to Ensure Compliance with the AIM Act

Staying compliant with the AIM Act requires a combination of understanding regulations, proactive planning, and leveraging technology. Here are actionable steps to ensure your business is prepared:

1. Understanding Regulations

• Stay updated on EPA guidelines, including the phasedown timeline and new compliance requirements.
• Familiarize yourself with upcoming regulations for HFC appliances and ensure readiness for mandatory leak inspections.

2. Inventory Management

• Survey stores and track appliances with 15–49 lbs. of refrigerant in your system.
• Accurately document charge sizes for all appliances.
• Establish a tracking system to monitor leak rates and avoid penalties under the chronically leaking appliance rule.

3. Training and Certification

• Train technicians on handling low-GWP refrigerants and best practices for leak detection and repairs.
• Ensure contractors are well-versed in AIM Act reporting and compliance standards.

4. Adopting Alternatives

• Transition to low-GWP refrigerants like HFOs and natural refrigerants (e.g., ammonia, CO₂).
• Evaluate the cost-effectiveness of switching to new refrigerants versus maintaining older systems.

5. Embracing Technology for Continuous Compliance

• Invest in continuous leak monitoring systems to detect issues early, avoiding costly refrigerant loss and non-compliance fines.
• Automate refrigerant tracking and compliance reporting with cloud-based solutions.
• Use sensor-based monitoring and assign investigative teams to appliances with recurring issues or leaks.

6. Streamlining Operations and Record-Keeping

• Require service providers to submit accurate leak records and list compliance numbers on invoices.
• Delay payments for incomplete or inaccurate records and set clear deadlines for corrections.
• Prepare for leak repair extension requests by maintaining detailed repair policies and logs.
• Audit all stores for enforcement readiness and ensure compliance reports are up to date.

7. Cost-Effective Compliance

• Analyze the cost of mandatory leak inspections versus investing in a continuous monitoring system.
• Implement leak tightness testing during installations and closely monitor new equipment prone to leaks.

Leveraging Technology to Embrace AIM Act Changes

As the AIM Act reshapes refrigerant management, technology offers powerful tools to streamline compliance and drive sustainability. Embracing innovation helps businesses navigate the changes and ensure they stay ahead of regulations while boosting operational efficiency.

Switch to a holistic refrigerant compliance management and leak detection solution! 

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Monitoring and Reporting Compliance

Cloud-based platforms allow real-time tracking of HFC usage and refrigerant inventory, making it easier for businesses to meet phase-down targets. These tools simplify monitoring and provide data needed to make timely adjustments to operations.

Automated reporting systems save time by generating compliance documentation for EPA submissions. Data visualization tools help businesses conduct audits, track performance, and compare against industry benchmarks for better decision-making.

Advancements in Refrigeration and HVAC Technology

Low-GWP refrigerants like CO₂, ammonia, and hydrocarbons are gaining popularity as sustainable alternatives to HFCs. These refrigerants are compatible with existing HVAC systems, making the transition smoother and more cost-effective.

IoT-enabled smart refrigeration systems are revolutionizing leak detection and refrigerant management. These systems monitor levels in real-time, detect leaks early, and optimize performance, helping businesses stay compliant while reducing waste and costs.

Data-Driven Decision-Making

AI and big data analytics provide businesses with predictive models to assess refrigerant compliance management costs and benefits. These insights help identify trends in refrigerant use and evaluate emerging alternatives, making long-term planning more strategic.

Life cycle assessment tools allow companies to evaluate the environmental and economic impacts of adopting new refrigerants and technologies. This data helps ensure that businesses make sustainable choices without sacrificing operational efficiency.

Facilio: Ensuring Continuous Compliance Amid Evolving Regulations

The AIM Act brings significant changes to refrigerant management, with the phasedown of high-GWP refrigerants and the transition to more sustainable alternatives. These regulations not only help reduce the environmental impact of refrigerants but also introduce challenges for businesses across industries that rely on refrigeration systems. Staying compliant with these evolving regulations is critical to avoid penalties and ensure operational efficiency.

To simplify  compliance and future-proof your business, adopting a comprehensive solution like Facilio is key. Facilio’s Refrigerant Compliance and Leak Detection solution offers an automated, cloud-based approach that integrates seamlessly with your existing systems, making it easier to track refrigerant usage, detect leaks early, and maintain compliance with the AIM Act.

<Alt: AIM Act - Facilio refrigerant compliance and leak detection solution>

Here’s what Facilio’s solution does best:

• Telemetry-based Slow Leak Detection: Real-time monitoring and alerts to quickly identify and address leaks, ensuring sustainability and reducing downtime.
• Automated Leak Detection and Workflow Management: Streamlines the management of leak events across multiple locations and contractors, ensuring consistent compliance and minimizing operational disruptions.
• Comprehensive Compliance Management: Automated strategies that assess refrigeration system health, forecast potential leaks, and simplify audit processes with standardized inventory tracking.

To stay ahead of AIM Act requirements and streamline your refrigerant management, schedule a demo of Facilio’s Refcomp solution today. Ensure your business is compliant, efficient, and ready for the future.