Changes to HVAC refrigerants have created plenty of confusion for commercial building owners. Between discussions about R-410A, new refrigerants, equipment deadlines, and the approaching 2027 compliance dates for certain systems, it can be difficult to separate what actually affects your facility from what is simply industry noise.
At the center of these changes is the American Innovation and Manufacturing (AIM) Act.
The AIM Act is gradually reducing the production and consumption of hydrofluorocarbon (HFC) refrigerants and transitioning certain new HVAC equipment toward refrigerants with lower global warming potential (GWP). The EPA’s goal is an 85% reduction in HFC production and consumption from baseline levels by 2036.
For Colorado building owners, this does not mean every existing HVAC unit suddenly needs replacement. It does mean that refrigerant type, equipment age, future projects, and capital planning deserve greater attention.
What Is the AIM Act?
The AIM Act was enacted in 2020 and gives the U.S. Environmental Protection Agency authority to address HFCs.
HFC refrigerants have been widely used in refrigeration, air conditioning, and heat pump equipment. They became common alternatives to older ozone-depleting refrigerants, but many have relatively high GWPs.
The EPA is implementing the AIM Act through several programs. Two are especially relevant to commercial HVAC owners.
First, the HFC Phasedown Program gradually limits how much HFC refrigerant can be produced or imported into the United States. The allowable production and consumption cap is 60% of the established baseline from 2024 through 2028. It drops to 30% for 2029 through 2033 before eventually reaching 15% beginning in 2036.
Second, the Technology Transitions Program establishes GWP limits and refrigerant restrictions for certain categories of new refrigeration, air conditioning, and heat pump equipment.
That distinction matters: the AIM Act isn’t simply a ban on one refrigerant on one date.
Why Is Everyone Talking About R-410A?
R-410A has been widely used in air conditioning equipment, but its GWP is above the limits established for several categories of new equipment.
That is driving manufacturers toward lower-GWP alternatives.
However, owners should understand an important point: An existing R-410A system does not automatically have to be replaced because of the AIM Act.
EPA guidance allows components using R-410A to continue being manufactured and imported for servicing existing systems, provided applicable labeling requirements are followed. These service components cannot simply be used to construct prohibited new R-410A systems.
That means an operating R-410A rooftop unit or other existing system may still make sense to maintain and repair.
The decision should depend on the equipment’s condition, efficiency, repair history, and remaining useful life, not fear that R-410A equipment suddenly becomes unusable.
What Changes Before 2027?
There isn’t one universal January 1, 2027 deadline for commercial HVAC.
Compliance dates depend on the equipment and application.
For example, EPA’s current Technology Transitions rules establish a GWP limit of 700 for new variable refrigerant flow (VRF) systems, with an installation compliance date of January 1, 2027. Certain qualifying systems using higher-GWP refrigerants have additional provisions based on when components were manufactured or imported, and some previously permitted construction projects can qualify for later installation treatment.
Data center, computer-room air conditioning, and information-technology equipment cooling systems also face a 700 GWP limit with a January 1, 2027 compliance date under the current EPA schedule.
Other equipment categories have earlier or later dates.
For owners, the takeaway is simple: don’t assume a headline about “the 2027 HVAC deadline” applies equally to every piece of equipment in your building.
Your equipment type, project scope, refrigerant, and installation timeline all matter.
Does Existing HVAC Equipment Need to Be Replaced?
Generally, no, not solely because it contains an HFC such as R-410A.
If existing equipment is performing reliably and can be economically maintained, continuing to operate it may be the best financial decision.
Consider factors such as:
- Equipment age
- Maintenance history
- Frequency and cost of repairs
- Refrigerant leakage
- Energy efficiency
- Parts availability
- Building comfort
- Future renovation plans
A relatively young, well-maintained system shouldn’t necessarily become a replacement priority simply because the refrigerant market is changing.
On the other hand, the AIM Act adds another consideration when evaluating equipment already approaching the end of its useful life.
If an aging RTU is experiencing repeated failures, declining efficiency, and significant repair costs, investing heavily in it without considering future equipment options may not provide the best long-term value.
How Could the AIM Act Affect HVAC Costs?
The phasedown doesn’t prescribe what an individual contractor will charge for refrigerant, nor does it mean a particular refrigerant will disappear overnight.
It does, however, reduce the amount of HFC production and consumption permitted nationally over time. The next major step occurs in 2029, when the allowance cap falls from 60% to 30% of the baseline.
That makes refrigerant management increasingly important. Commercial owners can prepare by focusing on leak prevention, preventive maintenance, accurate service records, and thoughtful capital planning.
Instead of asking only, “Can this unit be repaired?” owners should increasingly consider: “Does repairing this equipment still make financial sense over the remainder of its expected life?”
Sometimes the answer will absolutely be yes. Other times, replacement may offer better value.
Why Preventive Maintenance Matters More During the Transition
A refrigerant transition makes taking care of existing equipment even more important.
Routine commercial HVAC maintenance can identify refrigerant leaks and other problems before they become larger failures. It can also help maintain efficiency and give facility managers a clearer picture of equipment condition.
A strong maintenance strategy should include appropriate inspections of refrigerant circuits alongside:
- Coil cleaning
- Filter changes
- Electrical inspections
- Control testing
- Airflow verification
- Belt and motor inspection
- Overall performance monitoring
Good maintenance also generates valuable historical information. If a particular unit repeatedly needs refrigerant or expensive repairs, that history can inform future replacement decisions.
Start Planning Instead of Panic-Buying
One of the biggest mistakes building owners can make is replacing functional equipment prematurely because they believe a refrigerant is suddenly being “banned.”
The opposite mistake is waiting until aging equipment fails unexpectedly. A better strategy is to inventory your HVAC assets now.
Document each system’s:
- Age
- Refrigerant
- Condition
- Repair history
- Maintenance costs
- Efficiency
- Expected remaining life
Then prioritize equipment based on actual risk.
A 20-year-old unit with recurring problems deserves different planning than a well-maintained R-410A system installed only a few years ago.
For facilities with multiple RTUs, VRF systems, chillers, or specialized cooling equipment, this approach can also help spread capital expenditures across multiple budget cycles.
What Colorado Commercial Building Owners Should Do Now
The AIM Act should be viewed as a long-term planning issue rather than an emergency.
Colorado building owners should work with a commercial HVAC provider to understand which systems are affected by changing refrigerant standards and when.
If you’re considering a tenant improvement, major retrofit, equipment replacement, or new construction project, refrigerant requirements should be evaluated during the design phase—not after equipment has already been specified.
That’s particularly important because EPA’s compliance dates differ substantially between the HVAC and refrigeration subsectors.
For existing equipment, continue maintaining systems appropriately while building a realistic replacement strategy around age, performance, and total cost of ownership.
FAQs
Is R-410A banned in 2027?
No. There is no blanket 2027 ban requiring existing R-410A equipment to stop operating. EPA restrictions vary by equipment category, and R-410A components can continue to be used for servicing qualifying existing systems.
Do I have to replace an existing R-410A commercial HVAC unit?
Not simply because it uses R-410A. Existing equipment can generally continue operating and being serviced. Replacement should be based on system condition, repair costs, efficiency, and long-term value.
What happens to HFCs after 2027?
The nationwide HFC phasedown continues beyond 2027. Production and consumption allowances remain at 60% of the baseline through 2028, then decrease to 30% for 2029–2033. The AIM Act ultimately targets an 85% phasedown by 2036.
Are all commercial HVAC systems subject to the same deadline?
No. EPA requirements differ by equipment category. VRF and certain data-center cooling systems, for example, have January 1, 2027, compliance dates under current rules, while other categories have different schedules.
Should I replace older equipment before 2027?
Maybe, but not automatically. An evaluation should consider equipment age, reliability, efficiency, repair history, refrigerant, and your facility’s long-term plans.
How should I prepare for the AIM Act?
Start with an equipment inventory, maintain existing systems carefully, identify aging or problematic assets, and incorporate refrigerant requirements into future retrofit and replacement planning.
Prepare for the Refrigerant Transition with Thrivaire
The AIM Act is changing commercial HVAC, but good decisions still come down to understanding your equipment and making investments at the right time.
At Thrivaire, we don’t believe changing regulations should be used as a reason to sell customers equipment they don’t need. Our team helps Colorado commercial building owners evaluate existing systems, maintain equipment properly, and plan replacements based on reliability, efficiency, regulatory requirements, and long-term value.
If you’re unsure how the AIM Act or changing refrigerant standards affect your facility, contact Thrivaire to review your equipment and develop a practical HVAC strategy for 2027 and beyond.