Study Guide
Lesson 7/52Free

AIM Act & HFC Phasedown

Understand the American Innovation and Manufacturing Act, HFC phasedown schedule, new leak repair rules, and the transition to low-GWP refrigerants.

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What is the AIM Act

The American Innovation and Manufacturing (AIM) Act was signed into law on December 27, 2020. It authorizes the EPA to phase down the production and consumption of hydrofluorocarbons (HFCs) by 85% by 2036. The AIM Act is separate from Section 608 of the Clean Air Act but works alongside it. It establishes three main programs: an HFC phasedown allocation program, technology transitions to promote lower-GWP alternatives, and an Emissions Reduction and Reclamation (ER&R) program.

The AIM Act (December 27, 2020) authorizes EPA to phase down HFC production and consumption by 85% by 2036 through three programs: phasedown, technology transitions, and ER&R.

HFC Phasedown Schedule

HFC phasedown 2022 target10% reduction from baseline
HFC phasedown 2024 target40% reduction from baseline
HFC phasedown 2029 target70% reduction from baseline
HFC phasedown 2036 target85% reduction from baseline (final)
HFC phasedown baselineHistorical HFC production/consumption levels
GWP reference pointCO2 = 1

Subsection (h) — Emissions Reduction & Reclamation

Subsection (h) of the AIM Act establishes the Emissions Reduction and Reclamation (ER&R) program. New HFC leak repair requirements took effect January 1, 2026. These rules apply to systems containing 15 or more pounds of HFC refrigerant — a significantly lower threshold than the 50-pound threshold for ODS under Section 608. Leak rate thresholds remain the same: 10% for comfort cooling, 20% for commercial refrigeration, and 30% for industrial process refrigeration. Residential and light commercial AC and heat pump systems are exempt from HFC leak repair requirements. Systems with 1,500 or more pounds of HFC charge require automatic leak detection systems.

HFC leak repair rules (effective January 1, 2026) apply to systems with 15+ lbs of HFC — lower than the 50-lb ODS threshold. Residential AC/heat pumps are exempt.

Technology Transitions

Under the AIM Act, EPA is restricting the use of high-GWP HFCs in new equipment across multiple sectors. The agency is promoting the transition to A2L mildly flammable alternatives such as R-32 and R-454B. These next-generation refrigerants require updated safety codes, equipment designs, and handling procedures. Mandatory use of reclaimed HFCs for certain sectors begins January 1, 2029. Technicians must stay current with evolving regulations and new refrigerant safety classifications.

EPA is restricting high-GWP HFCs in new equipment, promoting A2L alternatives (R-32, R-454B). Reclaimed HFC mandate starts January 1, 2029.

AIM Act Key Dates & Facts

AIM Act enactedDecember 27, 2020
HFC leak repair effectiveJanuary 1, 2026
HFC charge threshold15+ lbs (vs 50+ lbs for ODS)
Reclaimed HFC mandateJanuary 1, 2029
Residential AC exemptYes, from HFC leak repair requirements
Auto leak detection requiredSystems with 1,500+ lbs of HFC
Civil penalty (2025)Up to $59,973 per day per violation

AIM Act Summary

  • The AIM Act (December 27, 2020) authorizes EPA to phase down HFC production/consumption by 85% by 2036.
  • Phasedown schedule: 10% by 2022, 40% by 2024, 70% by 2029, 85% by 2036.
  • HFC leak repair rules (effective January 1, 2026) apply to systems with 15+ lbs of HFC — lower than the 50-lb ODS threshold.
  • Leak rate thresholds match ODS rules: 10% comfort cooling, 20% commercial, 30% industrial.
  • Residential and light commercial AC/heat pumps are exempt from HFC leak repair requirements.
  • Automatic leak detection required for systems with 1,500+ lbs of HFC.
  • Mandatory use of reclaimed HFCs for certain sectors begins January 1, 2029.
  • EPA is promoting transition to A2L mildly flammable alternatives (R-32, R-454B).
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