Compliance Guide
AIM Act 2026: What HVAC Contractors Need to Know
Last updated: April 2026
Researched by the RefrigerantTrack Research Team
The AIM Act is phasing down HFC refrigerants through 2036. Learn the phase-down schedule, which refrigerants are affected, the 2029 reclamation mandate, and how to prepare your business now.
What Is the AIM Act?
The American Innovation and Manufacturing (AIM) Act was signed into law in December 2020, giving the EPA authority to phase down the production and import of hydrofluorocarbon (HFC) refrigerants in the United States. HFCs — including R-410A, R-404A, R-134a, and R-407C — replaced ozone-depleting refrigerants like R-22 but carry high global warming potential (GWP) values, making them a significant contributor to climate change. The AIM Act directs the EPA to reduce HFC production and imports according to a statutory schedule, using an allowance-based system that controls how much HFC can enter the U.S. market each year. For HVAC contractors, the practical effect is a shrinking supply of familiar refrigerants, rising prices, and the eventual need to transition to lower-GWP alternatives.
The HFC Phase-Down Schedule
The AIM Act phase-down reduces the baseline level of allowable HFC production and imports in steps tied to a global warming potential-weighted baseline. In 2024, production and import levels were cut to 60% of the 2011-2013 baseline — a 40% reduction. In 2029, the level drops further to 30% of baseline, representing a 70% cut from historical levels. By 2034, the limit reaches 20% of baseline (an 80% reduction), and by 2036 the cap falls to 15% of baseline — an 85% reduction from historical production levels. The phase-down does not ban existing refrigerants from use or service; it restricts new production and imports. Reclaimed and recycled refrigerant is not subject to the production caps, which is why the 2029 reclamation mandate is particularly significant.
How the AIM Act Affects HVAC Contractors
The most immediate effect for contractors is price and availability. As HFC production allowances decline, refrigerant prices rise — R-410A has already increased substantially since 2022, and further increases are expected as the 2029 step-down approaches. Contractors who stock refrigerant should plan inventory carefully to avoid being caught short during peak service season. Beyond price, the AIM Act affects equipment selection: new residential HVAC systems sold after January 1, 2025 must use refrigerants with a GWP below 750, which means R-410A equipment is no longer being manufactured for the residential market. Contractors need to learn installation and service procedures for R-454B (Puron Advance), R-32, and other A2L refrigerants that are replacing R-410A.
The HFC Allowance Allocation System
The EPA manages the phase-down through a system of tradeable allowances issued to HFC producers and importers. Allowance holders can use, trade, or sell their production rights. Contractors do not receive allowances directly — they purchase refrigerant from distributors who source from allowance holders. The practical effect of the allowance system is that refrigerant availability will tighten gradually rather than drop abruptly, giving the supply chain time to adapt. However, contractors operating without a predictable refrigerant procurement strategy face both supply uncertainty and price volatility. Building supplier relationships with distributors who have stable allowance access is increasingly important.
Which Refrigerants Are Affected
The AIM Act targets HFCs with high GWP values. R-410A (GWP 2,088) is the most widely used residential and light commercial refrigerant and is heavily affected — new R-410A systems for residential use were phased out in 2025. R-404A (GWP 3,922), widely used in commercial refrigeration, is also a primary target. R-134a (GWP 1,430), used in refrigeration and automotive systems, is affected. R-407C (GWP 1,774) is included. Lower-GWP alternatives including R-454B (GWP 466), R-32 (GWP 675), R-448A, R-449A, and R-744 (CO2, GWP 1) are not subject to the phase-down and represent the transition path for contractors. The RefrigerantTrack PT Chart at /tools/pt-chart covers pressure-temperature data for both legacy and transition refrigerants.
The 2029 Reclamation Requirement
One of the most operationally significant elements of the AIM Act is the requirement, effective in 2029, that refrigerant used in certain applications must be reclaimed to a specified purity standard before it can be re-used. The EPA is still finalizing the specific scope of the 2029 reclamation mandate, but it is expected to require that recovered HFC refrigerant be sent to certified reclaimers for processing before being resold or reused in covered appliances. This means contractors will need established relationships with certified refrigerant reclaimers and cannot simply reuse recovered refrigerant on-site. Proper recovery and documentation now — using tools like RefrigerantTrack — creates the compliance infrastructure that will be required under the 2029 rules.
State-Level Programs: California CARB
California's Air Resources Board (CARB) has implemented HFC regulations that go beyond federal requirements. CARB's Short-Lived Climate Pollutant (SLCP) regulation sets lower leak rate thresholds, stricter reclamation requirements, and additional reporting obligations for facilities operating refrigeration equipment in California. Contractors working in California must comply with both EPA Section 608 and CARB SLCP requirements — and the CARB requirements are often more stringent. Other states, including Washington, Colorado, and New York, have adopted or are considering similar programs. Contractors operating multi-state businesses need to track both federal and state requirements for each jurisdiction.
How to Prepare Your Business
The most important near-term actions for contractors are: get technicians trained and certified on A2L refrigerants (R-454B and R-32 require specific handling procedures due to mild flammability), build relationships with refrigerant distributors who have stable supply, begin tracking refrigerant usage and recovery with a compliant system now so you have documentation infrastructure ready for the 2029 reclamation rules, and evaluate your equipment inventory to understand which systems will require refrigerant transitions in the coming years. RefrigerantTrack's service log and refrigerant tracking features are designed to generate the documentation that both current EPA Section 608 requirements and coming AIM Act reclamation requirements will demand.
Key Facts and Figures
These figures are drawn directly from EPA regulations and federal enforcement data.
The AIM Act reduced U.S. HFC production and import allowances to 60% of baseline in 2024 — a 40% cut from historical levels.
In 2029, HFC production allowances drop to 30% of baseline under the AIM Act, representing a 70% reduction from historical levels.
By 2036, the AIM Act caps HFC production at 15% of the 2011-2013 baseline — an 85% reduction over the full phase-down period.
New residential HVAC systems sold after January 1, 2025 must use refrigerants with a GWP below 750, effectively ending new R-410A residential equipment production.
R-404A, the most common commercial refrigeration refrigerant, carries a GWP of 3,922 — nearly 4,000 times the climate impact of CO2 per pound.
The AIM Act reclamation requirement, taking effect in 2029, will require recovered HFC refrigerant to be processed by certified reclaimers before reuse in covered applications.
Frequently Asked Questions
Does the AIM Act ban R-410A from existing systems?
No. The AIM Act does not prohibit the continued use of R-410A or other HFCs in existing equipment. It restricts new production and imports of high-GWP HFCs, which will reduce supply and increase prices over time. Existing systems can continue to be serviced with R-410A for as long as supply is available. The practical pressure to transition comes from price and availability rather than an outright service ban.
When do I need to learn A2L refrigerant handling?
Now is the right time. New residential systems are already shipping with R-454B and R-32, classified as A2L (mildly flammable) refrigerants. ASHRAE 15 and local codes require specific ventilation, leak detection, and equipment considerations for A2L systems. Technicians who are not trained on A2L procedures before these systems become common in their service area will face a steep learning curve during busy service season. EPA certification does not automatically cover A2L-specific safety procedures — seek manufacturer training and ASHRAE 15 guidance.
How will the AIM Act affect refrigerant prices?
Prices for high-GWP HFCs like R-410A and R-404A are expected to continue rising as production allowances decline. R-410A wholesale prices have already increased significantly since 2022, and the 2029 step-down from 60% to 30% of baseline will put additional pressure on supply. Contractors who stock refrigerant will benefit from buying ahead of step-down dates. Long-term, the transition to lower-GWP refrigerants reduces exposure to phase-down price pressure.
What is the difference between AIM Act and EPA Section 608?
EPA Section 608 governs how refrigerants are handled in the field — leak rates, recovery requirements, technician certification, and record-keeping for service events. The AIM Act governs the supply of refrigerants — how much can be produced and imported each year. The two regulations work together: Section 608 ensures responsible use of the refrigerants that the AIM Act is progressively limiting. Contractors must comply with both simultaneously.
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