The AIM Act and the HFC Phasedown
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.
These rules are still being refined. The EPA published a proposed reconsideration of the Technology Transitions Rule in late 2025, and a final rule is expected in 2026. Because the exact GWP thresholds and dates can shift, treat the specific numbers as something to verify against current EPA material — but the direction is settled: new equipment is going low-GWP.
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 new rules that took effect on January 1, 2026. Most importantly, leak repair requirements that previously applied only to larger appliances now reach much smaller systems: the charge size that triggers leak repair obligations dropped from 50 pounds to 15 pounds, and the requirements now cover HFC appliances, not just ozone-depleting refrigerants.
There is also a training requirement: regulated businesses must provide their technicians with training on reducing HFC emissions, with a compliance deadline in mid-2026 and ongoing training for new hires after that. The details of the leak rules are covered in our leak repair requirements 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, leak repair rules reach HFC appliances down to 15 pounds.
Not affiliated with the EPA. For study practice only. AIM Act rules are still being finalized and updated — always verify current GWP thresholds, dates, and requirements with official EPA materials.