1.4 AIM Act and HFC Phasedown Schedule

1.4 AIM Act and HFC Phasedown Schedule

The American Innovation and Manufacturing (AIM) Act represents the most significant update to U.S. refrigerant regulations since the original CFC phaseout. As of 2026, these rules are actively reshaping the HVAC/R industry, and understanding them is essential for both the EPA 608 exam and real-world practice.

HFC Phasedown Schedule

The AIM Act mandates a gradual reduction — a phasedown, not a phaseout — of HFC production and consumption:

Baseline Levels

The phasedown is measured against baseline levels established from historical data:

• Production baseline: 382.6 Million Metric Tons of Exchange Value Equivalent (MMTEVe)
• Consumption baseline: 303.9 MMTEVe

Allowances are distributed based on the exchange values of individual HFCs, which correspond to their 100-year Global Warming Potentials (GWPs). Higher-GWP refrigerants consume more allowances per pound.

Technology Transitions (GWP Limits)

Under Subsection (i) of the AIM Act, EPA sets maximum GWP values for refrigerants in specific sectors. These rules restrict which refrigerants can be used in new equipment:

What This Means for Technicians in 2026

1. R-410A is being phased out of new equipment — its GWP of 2,088 exceeds the 700 GWP limit for new residential/commercial AC. New systems are transitioning to R-454B (GWP 466) and R-32 (GWP 675).
2. Existing R-410A systems are NOT affected — you can still service, repair, and recharge existing equipment that uses R-410A
3. R-22 is still in legacy equipment — but no new R-22 has been produced or imported since January 1, 2020. Only reclaimed or recycled R-22 is available
4. New refrigerants are mildly flammable (A2L) — R-454B and R-32 are classified as A2L, requiring updated safety protocols

2026 HFC Leak Repair and Management Rule

Beginning January 1, 2026, EPA's HFC Leak Repair and Management Rule places mandatory leak detection and repair requirements on owners or operators of HFC-containing appliances with a refrigerant charge of 15 pounds or greater:

• This significantly expands the scope compared to the old threshold of 50 pounds for ODS systems
• Automatic leak detection systems may be required for large commercial systems
• Owners must maintain records of refrigerant additions and leak repairs
• Appliances exceeding trigger leak rates must be repaired within specified timeframes

For the Exam: Know the phasedown schedule — especially that HFC consumption drops to 60% of baseline in 2024, 30% in 2029, and 15% by 2036. Also know that the AIM Act is a phasedown (gradual reduction), not a phaseout (complete elimination).