Asset Inventory Checklist: How to Prepare for the AIM Act

As of January 1, 2026, the EPA’s new management provisions under the American Innovation and Manufacturing Act (AIM Act) are in effect, establishing mandatory requirements for leak repair, automatic leak detection, and refrigerant reclamation for certain HFC systems and substitutes.

Understanding these changes is crucial to avoid fines and ensure compliance. At Fexa Trakref, we’re here to help you navigate through the proces.

How to know if you’re affected

Here are the following conditions that determine if your organization is affected by these new regulations:

• Leak repair is now required: If you operate comfort cooling (HVAC), commercial, or industrial process refrigeration systems with a full charge of 15 lbs or more of a refrigerant containing an HFC or substitute with a GWP greater than 53, you must comply with mandatory leak repair provisions outlined in 40 CFR Part 84, Subpart C.
• Mandatory automatic leak detection systems: If your facility uses commercial or industrial process refrigeration systems with a capacity of 1,500 lbs or more, Automatic Leak Detection (ALD) systems are mandatory for both new and existing equipment containing HFC refrigerants or their substitutes with a GWP of 53 or greater.
• Reclaimed refrigerant use: Beginning January 1, 2029, certain systems (supermarket systems, refrigerated transport, and automatic commercial ice makers) must be serviced with reclaimed HFCs. This is a significant compliance obligation under 40 CFR 84.112.
• Exemption for Residential & Light Commercial AC: EPA’s final rule includes a narrow exemption for leak repair provisions for residential and light commercial air conditioning/heat pumps, where some HVAC systems may not be subject to the same leak repair requirements even if they hold ≥15 lbs of refrigerant.

Asset inventory checklist: What information is required for compliance?

Under the AIM Act rules, facilities are required to maintain detailed records (e.g., asset type, refrigerant type, charge size, etc.) for systems subject to leak repair or ALD requirements. This checklist can help you prepare and maintain those records to ensure compliance.

Checklist for Automatic Leak Detection systems (ALDs)

For automatic leak detection systems, these fields are critical for documenting compliance with the new ALD system installation and monitoring requirements (applicable only to systems ≥1,500 lbs):

What’s next?

As you prepare for the upcoming changes to the AIM Act, it’s essential to conduct thorough asset surveys and gather necessary information about your systems. For technicians, this means collecting detailed data about each asset onsite, regardless of its size. Nameplates usually provide a wealth of information, but technicians familiar with the equipment can often fill in any gaps.

If your large systems lack Automatic Leak Detection (ALD) setups, you must install compliant ALDs by the effective dates specified in the rule (January 1, 2026 for new systems; January 1, 2027 for certain existing systems). Collaborate with your technicians to ensure you have the right information and budget for implementing ALDs. This proactive approach will not only enhance compliance but also help avoid costly operational disruptions.

As of January 1, 2026, the record-keeping requirements are now in effect. If you haven’t already, this is the time to review your asset management practices and close any compliance gaps.