U.S. AIM Act (HFC Regulation): The Phase-Down Framework and 2026 Technology Transitions Flexibility Measures
Overview
The American Innovation and Manufacturing Act of 2020 (AIM Act) requires the phased reduction of production and consumption of high-global-warming-potential (GWP) hydrofluorocarbons (HFCs) in accordance with the Kigali Amendment (an 85% reduction by 2036). Under the "Technology Transitions Rule," EPA progressively prohibits, by product category, the use of HFCs exceeding specified GWP thresholds in refrigeration and air conditioning equipment (HVAC), aerosols, foam products, and other applications. In 2026, in response to applications from manufacturers, EPA published transitional compliance flexibility measures regarding the timing of application of manufacturing and import prohibitions for certain commercial air conditioning and refrigeration equipment, in order to address supply chain shortages of compressors and low-GWP alternative refrigerants.
Enforcement Timeline
December 2020: The AIM Act is enacted, granting EPA authority to phase down HFCs
October 2023: EPA publishes the "Technology Transitions Final Rule" (establishing sector-specific HFC use prohibition schedules for 2025–2028)
January 2024: The 40% reduction step of the federal HFC production and import allocation takes effect
2026: EPA publishes compliance flexibility guidance for the Technology Transitions rule for specific equipment categories in response to supply chain congestion
Business Impact
Manufacturers exporting or producing air conditioning equipment (air conditioners, heat pumps), commercial refrigeration units, insulation foam materials, and aerosol products for the U.S. market are in principle required to comply with the transition requirements to low-GWP refrigerants (below GWP 700, etc.) that took effect in 2025–2026. While this flexibility measure allows for a transitional shipment grace period in some cases where products faced temporary refrigerant procurement difficulty, there is no change to the overall HFC allocation reduction schedule (a 40% reduction by 2029, etc.), making steady execution of product transition plans to alternative refrigerants (R-32, R-454B, etc.) essential.