The AIM Act is the biggest change to refrigerant regulation in decades, and if you own or manage a commercial building, it affects your HVAC systems in three distinct ways.
The headlines tend to focus on refrigerant bans, but the fuller picture matters more for your budget and your compliance.
Not all systems need a retrofit, and there’s a lot of fear around if a replacement is needed. Here is a plain-English breakdown of what the AIM Act is, how its three programs work, and what each one means for your yearly budget, the equipment on your roof or in your mechanical room.
What Is the AIM Act?
The American Innovation and Manufacturing Act, signed into law in 2020, directs the U.S. Environmental Protection Agency to phase down hydrofluorocarbons, or HFCs, by 85 percent by 2036. HFCs are the refrigerants in most commercial air conditioning and refrigeration equipment, including R-410A, R-134a, and R-404A.
They are potent greenhouse gases, and the AIM Act is the framework for reducing them. The EPA carries this out through three separate programs, and understanding the difference between them clears up most of the confusion.
The Three Programs of the AIM Act
1. The HFC Phasedown: supply and cost
The first program caps how much HFC refrigerant can be produced or imported in the United States, stepping down over time. The cap dropped to 60 percent of the baseline in 2024 and falls to 30 percent in 2029 on the way to an 85 percent cut by 2036. For your facility, this is the reason refrigerant prices are climbing and will keep climbing. Less supply of high-GWP refrigerants like R-410A means higher costs to recharge and repair the systems that use them.
2. Technology Transitions: new equipment
The second program sets limits on the global warming potential of refrigerant used in new equipment, sector by sector. New residential and light commercial air conditioners and heat pumps have had to use refrigerant below 700 GWP since January 1, 2025, which is why new systems now ship with A2L refrigerants such as R-454B and R-32 instead of R-410A. Larger commercial categories phase in on their own timelines. For the R-410A-specific details, including what is still legal to install and service, see our companion guide on R-410A in 2026.
Team: link the phrase “our companion guide on R-410A in 2026” to the published R-410A 2026 blog once it is live.
3. Refrigerant Management: operating your equipment
The third program is the newest and the most overlooked. The EPA’s HFC Management Rule, part of what is called the Emissions Reduction and Reclamation program, took effect January 1, 2026. It governs how you operate and service the equipment you already own, with requirements for leak repair, leak detection, reclaimed refrigerant, and recordkeeping. This is the part that creates ongoing obligations for commercial operators, so it deserves a closer look.
What the Refrigerant Management Rule Means for Your Systems
The most important change is the scope. The rule applies to appliances with a full refrigerant charge of 15 pounds or more using an HFC with a GWP above 53, which covers most commercial rooftop units, chillers, and refrigeration systems. It excludes residential and light commercial AC and heat pumps. That 15-pound threshold is much lower than the old 50-pound line, so many commercial systems that were never regulated before are now in scope.
Leak repair
Every time refrigerant is added to a covered system, a leak-rate calculation is required. If the annualized leak rate exceeds the threshold for your system type, which ranges from roughly 10 percent for comfort cooling up to 30 percent for industrial process refrigeration, with commercial refrigeration in between, a repair process is triggered.
Comfort cooling systems generally must be repaired within 30 days, and commercial and industrial refrigeration within 120 days, extendable to 180 with documentation. If a verified repair is not completed in time, you are required to develop a retrofit or retirement plan for the equipment.
Automatic leak detection
Larger refrigeration systems have an added requirement. Commercial and industrial process refrigeration systems with a charge of 1,500 pounds or more must have automatic leak detection installed, with new systems required to comply by January 1, 2026 and existing systems by January 1, 2027. Typical comfort-cooling HVAC does not trigger this, but it applies if your facility runs large refrigeration.
Reclaimed refrigerant
As virgin HFC production is capped, reclaimed refrigerant becomes a larger share of the servicing supply. Since 2026, refrigerant sold as reclaimed can contain no more than 15 percent virgin HFC. Beginning in 2029, certain refrigeration systems, including supermarket systems, refrigerated transport, and automatic commercial ice makers, must be serviced with reclaimed refrigerant. For everyone else, reclaimed refrigerant is simply becoming the practical way to keep older HFC systems running affordably.
Recordkeeping
Documentation is no longer optional under these rules. Covered facilities must keep detailed refrigerant records, including charges, refrigerant additions, leak-rate calculations, repairs and verification tests, automatic leak detection calibration, and any retrofit or retirement plans, and retain them for at least three years. Technicians must still hold EPA Section 608 certification. Clean records are your protection in an audit.
Why This Matters in Colorado
Colorado is one of the states that actively regulates refrigerants beyond the federal baseline. Under the Air Quality Control Commission’s Regulation 22, the state restricts high-GWP HFCs in chillers, stationary and commercial refrigeration, foam, and aerosols. That means Colorado commercial operators answer to both the federal AIM Act and state rules, and proactive refrigerant management is the safest way to stay ahead of both.
The Bottom Line for Commercial Operators
You do not have to tear out working equipment simply because it uses HFCs. What you do need is a plan. If you own larger commercial systems, the practical steps are straightforward:
- Inventory your refrigerant-containing equipment, noting type, refrigerant, and charge size
- Track every refrigerant addition and calculate leak rates as required
- Repair leaks within the deadline for your system type, or document a retrofit or retirement plan
- Keep clean, audit-ready records for at least three years
- Budget for rising refrigerant costs and plan A2L-ready replacements around real end of life
- Use Section 608 certified technicians and a preventive maintenance plan
The stakes are real. Civil penalties under the AIM Act can reach tens of thousands of dollars per day per violation, and states including Colorado enforce their own rules on top of the federal ones. Proactive management is far cheaper than a violation.
How Thrivaire Keeps You Compliant and Ahead
Keeping up with refrigerant regulation is part of our job so it does not have to become part of yours. Thrivaire is a Denver commercial HVAC team built on straight answers, not upsells.
Our preventive maintenance plans include the leak tracking and documentation these rules now require, which protects your compliance and catches small problems before they become expensive ones. When equipment reaches the end of its life, we handle A2L-ready replacements and new construction and we will always tell you honestly whether a repair or a replacement is the smarter move.
Want to know how the AIM Act applies to your specific systems? Contact our team or call (303) 935-1944, and we will walk your facility with you.
Frequently Asked Questions
Does the AIM Act apply to my commercial building?
If you operate HVAC or refrigeration equipment with a charge of 15 pounds or more of a regulated HFC, the refrigerant management rules likely apply, unless the equipment is residential or light commercial AC. The new-equipment rules apply whenever you replace or build, and the phasedown affects everyone through refrigerant pricing.
Do I have to replace my current system?
No. The AIM Act does not force you to retire working equipment for using HFCs. You do, however, take on leak-repair and recordkeeping obligations for covered systems, and any new equipment must meet the lower-GWP standards.
What records do I need to keep?
For covered systems, keep records of refrigerant charges, additions, leak-rate calculations, repairs and verification tests, automatic leak detection calibration, and any retrofit or retirement plans, and retain them for at least three years in case of an audit.
What happens if I do not comply?
Civil penalties can reach tens of thousands of dollars per day per violation, and criminal penalties are possible for knowing violations. States including Colorado also enforce their own refrigerant rules, so compliance is worth taking seriously.