Every conversation about R-410A prices, A2L equipment or new leak repair paperwork traces back to one federal law. The AIM Act was signed on December 27, 2020, as section 103 of Division S of the Consolidated Appropriations Act, 20211, and it sits in the U.S. Code at 42 U.S.C. 76752. It doesn't name R-410A or tell anyone what to install. It hands EPA the authority to do that, and EPA's rules in 40 CFR Part 84 carry the details.
What does the AIM Act do?
The statute gives EPA three separate programs, each in its own subsection2. Contractors feel each one differently.
| Program | Subsection of 42 U.S.C. 7675 | What EPA does with it | What contractors notice |
|---|---|---|---|
| Phasedown | (e) Phase-down of production and consumption | Caps HFC production and import, and issues yearly allowances | R-410A and other HFC supply shrinks; prices tend to rise at each step |
| Management | (h) Management of regulated substances | Leak repair, leak detection, reclaim and cylinder rules (the 2024 ER&R rule) | New paperwork on commercial HFC systems of 15 lb or more |
| Technology Transitions | (i) Technology transitions | Sets GWP limits for new equipment, sector by sector | New residential AC and heat pumps ship with A2L refrigerants |
HFCs are hydrofluorocarbons, such as R-410A, R-134a and R-404A. They don't harm the ozone layer the way R-22 did, but many have a high global warming potential (GWP), a measure of how much heat a gas traps compared with carbon dioxide.
What is the HFC phasedown schedule?
The statute sets the cap as a share of a historic baseline. Production and consumption are measured in exchange-value-weighted tons, so high-GWP refrigerants use up allowance faster23.
2020 to 2023
90% of baseline
The first step, starting the year the law passed.
2024 to 2028
60% of baseline
The current step as of October 2026. EPA published the 2027 allowance allocations on October 6, 2026.
2029 to 2033
30% of baseline
The cap halves. Expect R-410A supply for service to tighten noticeably.
2034 to 2035
20% of baseline
Second-to-last step.
2036 onward
15% of baseline
The end point: an 85 percent reduction from the baseline.
The phasedown limits new supply. It doesn't ban using or servicing existing equipment. As new supply shrinks, recovered refrigerant that's sent for reclamation becomes a bigger share of what's available for service, which is why recovery matters more each year.
What does the AIM Act mean for HVAC contractors?
Here's an example of how the three programs show up in one week at a residential and light commercial shop:
- 1
Monday: a replacement sale
The customer chooses a new heat pump. It uses R-454B because Technology Transitions limits new residential split systems to refrigerants with a GWP of 700 or less.
- 2
Wednesday: a repair-or-replace call
A 14-year-old R-410A system has a major leak. The refrigerant price on the estimate reflects a supply that's capped at 60 percent of baseline and drops to 30 percent in 2029.
- 3
Friday: a commercial refrigeration call
A restaurant walk-in cooler system holds 40 lb of R-404A. That puts it under EPA's HFC leak repair rule: the owner must calculate the leak rate each time refrigerant is added, and the tech's service records are what that math is built on.
For the refrigerants themselves, see what an A2L refrigerant is. For the leak math, see how refrigerant leak rate is calculated. Repair-or-replace pricing is covered in how to price HVAC jobs.
Where do EPA's AIM Act rules stand in 2026?
The law hasn't changed. EPA's rules under it have moved several times, so here's the status as of October 15, 2026, checked against the Federal Register and EPA's own pages.
Technology Transitions: relaxed in May 2026. EPA finalized a reconsideration rule, signed May 21 and published May 26, 2026, effective July 27, 20264. For residential and light commercial AC and heat pumps, it removed the January 1, 2026 installation deadline for systems using refrigerants above the 700 limit that were manufactured or imported before January 1, 2025, so that inventory can be installed until supply runs out5. It also extended deadlines or raised GWP limits for supermarket systems, remote condensing units, cold storage warehouses and some industrial and laboratory equipment.
Leak repair and reclamation: in force, one proposed change. The 2024 Emissions Reduction and Reclamation (ER&R) rule's leak repair requirements started January 1, 2026 for appliances with 15 pounds or more of an HFC or a substitute with a GWP above 533. They exclude the residential and light commercial AC and heat pump subsector. On May 26, 2026, EPA proposed excluding road and intermodal transport refrigeration units, and said it was not proposing other amendments to the 2024 rule6. Comments closed July 10, 2026. EPA's ER&R page, last updated May 26, 2026, still lists that action as a proposal7.
Phasedown: continuing. EPA published its notice of 2027 allowance allocations on October 6, 20268, under the same statutory schedule.
AIM Act vs Clean Air Act Section 608
People often blur the two. Section 608 of the Clean Air Act is older and covers technician certification, the venting prohibition, recovery and the original leak repair rule for ozone-depleting refrigerants such as R-22, in 40 CFR Part 829. The AIM Act added HFC-specific powers on top: the phasedown, the GWP limits for new equipment, and HFC leak repair at a 15-pound threshold in 40 CFR Part 84. A tech still needs EPA 608 certification to work on any of it.
How TradesWork helps with AIM Act record-keeping
TradesWork logs every charge and recovery per unit and per tech with the tech's EPA 608 number, calculates leak rates with either of EPA's two methods, and opens a leak case with a 30-day repair date when a unit crosses its threshold. The AIM Act 15-pound HFC scope is a setting labelled pending legal review, and TradesWork doesn't file anything with EPA. See warranty and refrigerant tracking.
Footnotes
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U.S. EPA, Background on HFCs and the AIM Act (last updated July 1, 2026). https://www.epa.gov/climate-hfcs-reduction/aim-act ↩
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42 U.S.C. 7675, American innovation and manufacturing, subsections (e)(2)(C), (h) and (i). https://www.law.cornell.edu/uscode/text/42/7675 ↩ ↩2 ↩3
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40 CFR Part 84: 84.7 (phasedown schedule) and Subpart C, 84.106 (leak repair). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84 ↩ ↩2
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Federal Register, Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions, final rule, May 26, 2026, effective July 27, 2026. https://www.federalregister.gov/documents/2026/05/26/2026-10387/phasedown-of-hydrofluorocarbons-reconsideration-of-certain-regulatory-requirements-promulgated-under ↩
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U.S. EPA, Fact Sheet, Final Rule: Reconsideration of Certain Regulatory Requirements Promulgated under the Technology Transitions Provisions, May 2026. https://www.epa.gov/system/files/documents/2026-05/fact-sheet-san-12166-technology-transitions-frm.pdf ↩
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Federal Register, Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration Units From the HFC Leak Repair Requirements, proposed rule, May 26, 2026 (comments closed July 10, 2026). https://www.federalregister.gov/documents/2026/05/26/2026-10388/phasedown-of-hydrofluorocarbons-excluding-road-and-intermodal-container-transport-refrigeration ↩
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U.S. EPA, Regulatory Actions for Managing HFC Use and Reuse (last updated May 26, 2026). https://www.epa.gov/hfcs/regulatory-actions-managing-hfc-use-and-reuse ↩
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Federal Register, Phasedown of Hydrofluorocarbons: Notice of 2027 Allowance Allocations for Production and Consumption of Regulated Substances, October 6, 2026 (document 2026-20389). https://www.federalregister.gov/documents/2026/10/06/2026-20389/phasedown-of-hydrofluorocarbons-notice-of-2027-allowance-allocations-for-production-and-consumption ↩
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40 CFR Part 82, Subpart F, Recycling and Emissions Reduction. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F ↩
