Back to app

The AIM Act and the HFC Phasedown

Written by an EPA 608 certified technician · Reviewed July 21, 2026 · About the author

Section 608 was written to protect the ozone layer. The AIM Act is the newer law layered on top of it, aimed at climate change. If you are studying for the EPA 608 exam today, you need to understand both, because the refrigerants you will actually work with for the rest of your career are being shaped by the AIM Act right now. This guide explains what it is and what it means for technicians.

What the AIM Act Is

The American Innovation and Manufacturing Act — the AIM Act — was enacted in December 2020. While Section 608 targets ozone-depleting substances, the AIM Act targets hydrofluorocarbons (HFCs). HFCs such as R-410A and R-134a contain no chlorine, so they do not harm the ozone layer, but many of them have a very high global warming potential (GWP). The AIM Act gives the EPA authority to bring those emissions down.

The law works through three connected programs:

Phasing down HFC production and consumption.
Facilitating the transition to next-generation technologies (the Technology Transitions program).
Managing HFCs already in use — leak repair, recovery, reclamation, and refrigerant management.

The 85 Percent Phasedown

The headline requirement: the AIM Act directs the EPA to phase down the production and consumption of HFCs in the United States by 85 percent over a 15-year period. This is done with an allowance system — the EPA issues a shrinking number of allowances each year, so less HFC can be legally produced or imported as time goes on.

For a technician, the phasedown shows up indirectly: as supply tightens, high-GWP refrigerants get more expensive and harder to find, which pushes the whole industry toward lower-GWP alternatives — the same supply-and-price pattern that played out with the R-22 phaseout.

The Technology Transitions Rule

The Technology Transitions program sets limits on the GWP of refrigerants allowed in new equipment, sector by sector — new residential and light commercial air conditioning, refrigeration, and so on. The practical result is that new air conditioning systems are moving away from R-410A toward refrigerants with a much lower GWP.

EPA finalized a reconsideration of several Technology Transitions requirements in May 2026. Compliance dates and GWP limits vary by sector and subsector, so a technician should use EPA's current sector tables rather than treating one deadline as universal. The broad direction remains the same: new equipment is moving toward lower-GWP refrigerants.

A2L Refrigerants: The New Normal

The low-GWP refrigerants replacing R-410A in new equipment — such as R-32 and R-454B — are classified as A2L. The "2L" means they are mildly flammable. They are far less flammable than propane-type refrigerants, but they are not non-flammable like R-410A.

For technicians, this is a real change in daily work. A2L equipment comes with new requirements around leak detection, ventilation, charge limits, and service procedures, and technicians need training specific to handling mildly flammable refrigerants safely. If you are entering the trade now, expect A2L systems to be a routine part of the job.

2026 Leak Repair and Management Requirements

The HFC management side of the AIM Act brought significant rules that took effect on January 1, 2026. Under 40 CFR 84.106, leak-repair requirements generally cover appliances with 15 pounds or more of an HFC, or certain HFC substitutes, with a GWP above 53. Residential and light-commercial air-conditioning and heat-pump appliances are excluded from this program.

This is a separate AIM Act program, not a reduction of Section 608's 50-pound threshold for ozone-depleting refrigerants. The ER&R rule also contains a one-time training requirement for fire-suppression technicians; it is not a blanket new training mandate for every HVAC/R service technician. The two leak-repair programs are compared in our leak-repair guide.

How This Connects to Section 608

The AIM Act does not replace Section 608 — it runs alongside it. Section 608 still governs ozone-depleting refrigerants and the core practices of recovery, recycling, reclaiming, and the venting prohibition. The AIM Act extends similar management ideas to HFCs and adds the phasedown and technology transition pieces. A well-prepared technician understands both, because real equipment in the field is now a mix of older R-22 systems, R-410A systems, and new A2L systems.

Study Takeaways

The AIM Act (2020) targets HFCs and climate, complementing Section 608's ozone focus.
It phases down HFC production and consumption by 85 percent over 15 years.
The Technology Transitions rule pushes new equipment to low-GWP refrigerants.
R-32 and R-454B are A2L — mildly flammable — and need specific training.
As of January 2026, a separate AIM Act program covers many HFC appliances at 15 pounds or more, with important exclusions.

Official Sources Used for This Review

Not affiliated with the EPA. For study practice only. AIM Act rules continue to be updated — always verify current GWP limits, dates, coverage, and exceptions with EPA.