Companies across the nation are preparing for the upcoming roll out of the EPA’s AIM Act, which represents a major shift in refrigerant management requirements. Although new regulations will not take effect until January 1, 2026, facilities managers must start crucial preparations in 2025 to ensure that they can remain fully compliant with all of the new rules. 

Our checklist will help you get ready for these upcoming changes! Here is everything you need to know to prepare. 

What is the AIM Act?

The EPA has been regulating how businesses handle hydrofluorocarbons (HFCs) in their refrigeration and air conditioning systems since the early 1990s. This is important because HFCs play a major role in global warming. In fact, the impact of HFCs on climate change is thousands of  times greater than carbon dioxide. 

The AIM Act is the latest adjustment to the EPA’s HFC rules. Under the new Emissions Reduction and Reclamation (ER&R) Program, the AIM Act implements multiple strategies for minimizing harmful emissions and maximizing refrigerant reclamation. 

Check out our free Fexa Trakref guide to learn more: “AIM Act: What You Need to Know and Do To Comply.” 

Key changes include:

• Lowering the threshold for regulated systems from 50 pounds to 15 pounds of refrigerant
• Requiring automatic leak detection systems for larger installations
• Promoting the use of reclaimed HFCs
• Implementing stricter record-keeping requirements

How do you know if your organization is affected by upcoming changes? 

Every single business with an HVAC or refrigerant system needs to understand their place in this regulatory landscape. Even small businesses that didn’t previously need to worry about compliance issues need to confirm their compliance. 

For example, organizations like these may no longer be exempt from compliance reporting: 

• Small restaurants with walk-in refrigerators/coolers 
• Small commercial buildings with comfort cooling systems 
• Retail stores with commercial refrigeration units 
• Small grocery stores 
• Convenience stores with refrigeration systems 

Organizations that have traditionally been required to comply will need to examine if any of the changes to the rules affect their tracking and reporting. These include: 

• Large grocery chains and supermarkets
• Industrial refrigeration facilities
• Large commercial buildings
• Distribution centers
• Manufacturing facilities with process cooling

Essentially, your organization is likely affected if you operate equipment that: 

• Uses chillers
• Cools medium-to-large commercial spaces
• Has cooling capacity above 25 tons
• Operates as a combined system for refrigeration and air conditioning

It is your responsibility to investigate compliance requirements. If you don’t have a compliance manager in your organization, the job likely falls to the facilities manager. Non-compliance may lead expensive fines, operational disruptions, legal action against your organization, revocation of licneses, increased insurance premiums, and reputational damage. 

There are essentially three questions that determine your requirements for compliance with the new AIM Act. 

Does your equipment use refrigerants with a Global Warming Potential (GWP) greater than 53?

Because we needed a way to quantify the impact of greenhouse gases, the International Panel of Climate Change (IPCC) came up with an equation for each gas’s Global Warming Potential.  GWP is calculated as a way to measure and compare the ways that different greenhouse gases trap heat in the atmosphere.

If a greenhouse gas is 53 times more effective at trapping heat in the atmosphere than CO2 over a 100-year period, it would have a GWP of 53. This means that one pound of this gas would have the same warming effect as 53 pounds of CO2 during that century. The rating comes from measuring how efficiently the gas absorbs heat and how long it persists in the atmosphere, compared to CO2’s baseline GWP of 1.

This specific GWP value of 53 is significant because according to the AIM Act, facilities using refrigerants with GWPs above 53 must comply with new regulatory requirements 

Do any assets have a charge size of 15 pounds or greater? 

The second key factor in determining if your organization needs to comply with the AIM Act is the refrigerant charge size. A charge refers to the amount of refrigerant in a system. The new threshold is 15 pounds, which is significantly lower than the previous requirement of 50 pounds. 

There are several methods you can use to determine your system’s charge size. You can: 

• Check equipment nameplates
• Review maintenance records
• Consult with service technicians
• Check manufacturer specifications

This information should be documented for each asset. Even if you’re unsure about exact amounts, technicians can help verify charge sizes. Keep in mind that a single commercial refrigeration unit like a walk-in cooler often contains more than 15 pounds of refrigerant. 

Do any of your installations contain 1500+ pounds of HFCs? 

This third critical factor in determining AIM Act compliance requirements is to review the size of your installations. 

Larger installations, which contain at least 1500+ pounds of HFCs, are required to have an Automatic Leak Detection (ALD) system installed.  

For these large systems:

• Leak detection is mandator
• You must abide by continuous monitoring requirements
• There are required calibration and maintenance of ALD systems
• Regular inspections (monthly for facilities >1500 lbs)

This requirement represents one of the most significant operational changes under the new regulations, as it requires substantial investment in new monitoring technology for facilities with large refrigerant systems. 

However, if your equipment meets any of the above criteria (using refrigerant with a GWP above 53, having a charge size of 15 pounds or greater, or having an installation that contains 1500+ pounds of HFC), your organization must comply with the AIM Act’s new requirements starting January 1, 2026.

The easiest way to know if your organization will be affected by the changes to the AIM Act is to use our Fexa Trakref Flow Chart! We designed it specifically with multi-site operators in mind! Check out the flow chart to determine what changes you have to make.

Compliance Checklist 

• Asset Inventory
  • Document all refrigerant-containing equipment in your operations, including model numbers and manufacturer information 
  • Record each type of assets (commercial refrigeration, comfort cooling, industrial process refrigeration, etc) 
  • Note the refrigerant types used in each asset
  • Identify the GWP rating of each refrigerant
  • Document the system capabilities of each asset
  • Record charge sizes of each system
  • Create a unique identifier for each asset
• Automatic Leak Detection Systems for Large Installations (1500+ pounds)
  • Install appropriate detection systems
  • Document detection limits and alarm set points
  • Maintain calibration records
  • Establish monitoring protocols (such as a current and flexible CMMS)
• Record-Keeping Systems 
  • Track your refrigerant usage
  • Track leak rates and repairs
  • Keep detailed maintenance records
  • Retain technicians’ certifications for later reference
  • Record equipment performance data
  • Document all HFC disposal numbers 
• Compliance Protocols
  • Conduct regular inspection based on system size
  • Perform prompt leak repairs within mandated timeframes
  • Document all service activities
  • Verify the effectiveness of all repairs 
• Technology Infrastructure
  • Select a CMMS platform that can integrate with refrigerant management tools
  • Ensure your system can handle automated compliance tracking
  • Implement real-time leak detection monitoring capabilities
  • Set up integrated work order management
  • Enable comprehensive reporting features
  • Verify the platform can scale with changing regulations 
• Training and Personnel
  • Train staff on new compliance requirements
  • Ensure technicians maintain proper certifications
  • Establish clear roles and responsibilities
  • Document emergency response procedures 
• Vendor Management
  • Verify contractor certifications
  • Document service provider compliance
  • Establish communication protocols
  • Maintain vendor performance records

How Fexa Trakref Can Help You Prepare

The Fexa Trakref API integration, launching in Q1 2025, offers a comprehensive solution for managing these new requirements. Key features include:

• Seamless data synchronization between systems
• Automated compliance tracking
• Real-time leak detection monitoring
• Integrated work order management
• Comprehensive reporting capabilities 

The platform helps your organization to:

• Ensure consistent regulatory compliance across facilities
• Reduce operational costs through improved efficiency
• Minimize environmental impact
• Improve equipment performance
• Protect organizational reputation through demonstrated environmental responsibility

Looking Ahead with Fexa Trakref

The AIM Act represents just one part of an evolving regulatory landscape. State-level requirements in California, New York, and Washington add additional complexity for multi-state operations.

The best way to comply with these new requirements is to prepare, prepare, prepare. Facilities managers already know the importance of routine maintenance in preventing crises later down the road–think of 2025 as your routine maintenance year for these upcoming compliance changes. Now is your chance to implement new systems that will keep you compliant, test them, and make any required changes to your operations. 

When your approach to HFC management is integrated with robust refrigerant management systems today, you can prepare for the AIM Act and future regulatory changes. 

Ready to ensure your organization is prepared for the January 2026 deadline? Contact Fexa today to learn how our integrated solutions can help you achieve your compliance and sustainability goals. Get your free demo today. 

Say goodbye to the never-ending to-do list.