1. What Is the AIM Act?

The AIM Act, enforced by the Environmental Protection Agency (EPA), seeks to phase down the use of hydrofluorocarbons (HFCs), potent greenhouse gases used in refrigeration, air conditioning, and fire suppression systems. The law introduces new regulations to minimize leaks, promote reclamation, and tighten refrigerant management practices.

Key Provisions of the AIM Act

• Phase Down of HFC Production and Consumption: Targets a 85% reduction in HFC use by 2036.
• Emission Reduction and Reclamation (ER&R) Program: Encourages reuse of reclaimed refrigerants in servicing equipment.
• Stricter Refrigerant Leak Management: Mandates leak detection systems and faster repair timelines for regulated equipment.

These new rules reflect growing concerns about global warming potential (GWP) associated with HFCs. Systems using refrigerants with a GWP greater than 53—like R-410A and R-134a—are now under heightened scrutiny.

2. Who’s Affected by the AIM Act?

The AIM Act’s broad scope affects a wide range of industries and businesses, even those that were previously exempt under older refrigerant regulations. Whether you manage a large industrial refrigeration system or operate a small business with air conditioning, the new rules likely apply to you.

Industries Impacted by the AIM Act

• Industrial Refrigeration: Large-scale cooling systems used in manufacturing or food storage.
• Commercial Refrigeration: Systems in grocery stores, warehouses, and restaurants.
• Comfort Cooling Systems: Air conditioning in offices, hotels, and residential complexes.
• Small Businesses: Any business with 15+ pounds of refrigerants is now subject to the AIM Act’s requirements.

Even businesses currently regulated under Section 608 of the Clean Air Act will need to expand their asset inventories to account for new system types covered by the AIM Act.

3. What Changes Are Happening on January 1, 2026?

By January 1, 2026, businesses using HFCs must implement specific operational and reporting changes to remain compliant. Many of these new rules focus on preventing refrigerant leaks, increasing tracking accuracy, and enforcing stricter reporting timelines.

Key Changes to Prepare For

1. Automatic Leak Detection Systems (ALDs):
   • Larger systems (1,500+ pounds of refrigerant) must have real-time leak detection technology installed.
   • ALDs should be capable of continuous monitoring and automatic reporting.
2. Lower Thresholds for Regulation:
   • Systems containing 15+ pounds of refrigerants with a GWP > 53 will now be regulated.
   • This means smaller commercial systems that were previously exempt are now covered.
3. Enhanced Reporting & Record-Keeping Requirements:
   • Businesses must track refrigerant use, leaks, and repairs in detail.
   • Reports must be available for EPA audits on demand.

The 2026 deadline is fast approaching, making it essential to plan operational changes now to avoid non-compliance.

4. How Do You Prepare for the AIM Act?

Preparation is essential to ensure a smooth transition to compliance before the January 2026 deadline. Here’s a step-by-step breakdown of what you need to do.

Step 1: Conduct an Asset Inventory

• Identify all equipment containing refrigerants, including type, charge size, and GWP rating.
• Assign unique tags to each asset for easy tracking and maintenance.

Step 2: Install Automatic Leak Detection Systems (ALDs)

• Larger systems (1,500+ pounds of refrigerant) require real-time leak monitoring.
• Partner with service providers to ensure proper installation and calibration of ALDs.

Step 3: Set Up a Regular Inspection Schedule

• Monthly inspections for large systems; annual check-ups for smaller systems.
• Document all maintenance, repairs, and refrigerant top-ups to stay compliant.

Step 4: Implement New Record-Keeping Procedures

• Train staff on record-keeping best practices to ensure compliance during EPA audits.
• Use refrigerant management software to automate tracking and reporting.

5. What Other Regulations Should I Watch Out For?

While the AIM Act provides a federal framework for refrigerant management, state-level regulations are evolving rapidly. Several states are introducing stricter policies that may exceed federal standards, meaning businesses must stay vigilant to remain compliant across different jurisdictions.

Here’s a breakdown of the key state regulations to watch out for and how they impact your compliance strategy.

1. New York: Amendments to Part 494

New York is set to introduce amendments to Part 494 of the Hydrofluorocarbon Standards, tightening controls on HFC use, reporting, and record-keeping. The state aims to align with federal rules while implementing its own prohibitions and enhanced accountability measures.

Key Changes in Part 494

• Prohibitions on HFC Use: Aligns with the EPA’s Significant New Alternatives Policy (SNAP) program by restricting certain HFC applications.
• Mandatory Reporting: Businesses must submit regular reports on refrigerant usage, sales, and inventory.
• Stricter Record-Keeping: Companies need to track the entire lifecycle of HFC-containing products, from acquisition to disposal.

Action Tip: Begin assessing your current use of HFCs and invest in record-keeping systems to prepare for the updated requirements. Training your staff on the new reporting rules will be essential.

2. Washington State: Phased-In HFC Regulations

Washington is leading the charge with aggressive HFC management policies under Chapter 173-443 WAC, aiming to curb emissions and set GWP limits for refrigerants. The phased approach requires registration and frequent inspections of refrigerant systems based on their size.

Compliance Timeline

• Large Facilities (>1,500 pounds): Register by March 15, 2024.
• Medium Facilities (200-1,499 pounds): Register by March 15, 2026.
• Small Facilities (50-199 pounds): Register by March 15, 2028.

Leak Inspection & Repair Requirements

• Large assets: Monthly inspections.
• Medium assets: Quarterly inspections.
• Small assets: Annual inspections.

Facilities must also repair leaks within 14 days, faster than the EPA’s 30-day requirement, or submit a retrofit or retirement plan if repairs are not feasible.

Recordkeeping & Reporting

• Annual facility reports required for medium and large systems.
• Comprehensive records must be maintained throughout the entire lifecycle of refrigerant-containing systems.

Washington’s proactive approach emphasizes early preparation. Businesses need to gather asset data now to meet registration deadlines and stay compliant with frequent inspections.

3. California: Climate Disclosure Rules Impacting Refrigerant Management

California is moving forward with climate-related disclosure laws that will affect how businesses manage and report refrigerant usage. While some compliance deadlines may shift, businesses must prepare for these stringent requirements as part of the state’s commitment to environmental transparency and accountability.

Overview of California’s Climate Laws

• S.B. 253: Requires companies to disclose Scope 1, Scope 2, and Scope 3 emissions, including refrigerant usage.
• S.B. 261: Mandates climate-risk reporting following the Task Force on Climate-Related Financial Disclosures (TCFD) framework.
• A.B. 1305: Governs the reporting of voluntary carbon offsets and emissions reduction efforts.

Compliance Timeline

• Scope 1 and 2 Reporting: Begins in 2028 (limited assurance); reasonable assurance by 2032.
• Scope 3 Reporting: Begins in 2029, with assurance required by 2032.

How Refrigerant Management Is Affected

• Detailed refrigerant disclosures will become mandatory as part of Scope 1 emissions reporting.
• Companies must document refrigerant types, leakage rates, and emissions with accurate record-keeping systems.
• Regular audits will be required to verify reported data, ensuring alignment with California’s environmental standards.

Pro Tip: Start building refrigerant tracking systems now to collect the necessary data for future disclosures. Early preparation will prevent non-compliance as reporting deadlines approach.

How to Stay Compliant Across State Lines

Operating in multiple states means businesses need to navigate both federal and state regulations. To ensure compliance, consider the following steps:

1. Centralize Record-Keeping: Use refrigerant management software like Trakref to consolidate data and automate reporting.
2. Monitor Regulatory Updates: Stay informed about changes to state and federal regulations to avoid surprises.
3. Train Staff Across Locations: Ensure all relevant personnel understand the specific requirements for each state in which you operate.
4. Conduct Regular Audits: Proactively audit refrigerant usage and reporting practices to catch issues early.

Why It Matters: By staying compliant with both AIM Act regulations and state-specific rules, businesses can avoid penalties and contribute to sustainability efforts.

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