Servicing Retail HFC Refrigeration Equipment and the AIM Act
The American Innovation and Manufacturing (AIM) Act, enacted in December 2020, has brought significant changes to the refrigeration industry. As we navigate through 2025, the first set of restrictions under the AIM Act are now in effect, aiming to phase down the production and consumption of hydrofluorocarbons (HFCs) by 85% by 2036. These regulations are crucial for reducing greenhouse gas emissions and transitioning to more environmentally friendly refrigerants.
One of the key aspects of the AIM Act is the Technology Transition Rule. It impacts the repair and servicing of refrigerated display cases. The rule specifies that repairs are permissible unless they result in the creation of a new system. This means that while existing display cases can continue to operate and be serviced, certain extensive repairs may be restricted. For instance, assembling a system for the first time from used or new components, increasing the cooling capacity of an existing system, or replacing 75% or more of evaporators and 100% of the compressor racks, condensers, and connected evaporator loads are considered new installation
Understanding these repair restrictions is essential for businesses to ensure compliance and avoid potential penalties. As we move forward, staying informed and adapting to these regulations will be key to maintaining operational efficiency and environmental responsibility. This blog will help navigate the repair restrictions of refrigerated display cases.
What are the types of display cases?
- Remote Display Cases
- A remote display case is cooled by an external refrigeration system or condensing unit. The refrigeration components are located away from the display case in a mechanical room, outside the store, or on the roof. Their primary advantage is handling larger cooling loads and are ideal for supermarkets and large retail environments where multiple display cases can be connected to a single system. Not having the refrigeration equipment in the store also reduces heat production and noise in the immediate environment.
- Stand-alone or Self-contained Display Cases
- All the components necessary for refrigeration are integrated into self-contained display cases. The compressor, condenser, and evaporator are all housed within the display case itself. These units only require a power source and have the freedom to be placed wherever they fit. This type of display case is ideal for smaller retail spaces, convenience stores, and specialty shops where flexibility and ease of installation are key considerations.
- Zero Zone Hybrid™
- Zero Zone combined the perks of a self-contained unit with the durability and robustness of remote display cases. The Hybrid™ Merchandiser is a remote display case with a refrigeration system mounted on top. Since the two parts of this system are separate, the Hybrid™ Merchandiser falls into the remote display case category.
AIM Act Repair Restrictions
AIM Act Limits to Remote Display Cases
Remote display cases are cooled using either a remote condensing unit or a multiplex rack system, also known as a supermarket system. The types of supermarket systems include centralized direct expansion, distributed systems, cascade, and indirect/secondary loop systems.
While display cases are not explicitly mentioned in the regulations, the systems and components that provide cooling for them are. The compliance date for remote condensing units is January 1, 2026, while the compliance date for rack systems is January 1, 2027.
After these effective dates, the GWP limits for the systems are as follows:
- A GWP of 150 or less for systems with a refrigerant charge of 200 pounds or more, excluding the high-temperature side of a cascade system.
- A GWP of 300 or less for systems with a refrigerant charge of less than 200 pounds.
- A GWP of 300 or less for the high-temperature side of cascade systems.
Remote Display Case AIM Act Repair Restrictions
Before an installed system is considered a new installation, 75% of the evaporators and 100% of the compressors need to be replaced. In a rack system or remote condensing unit where 100% of the compressors have failed but the evaporators in the remote display cases are still serviceable, the system does not need to change from an HFC refrigerant. This also applies in reverse; if all the evaporators in the display cases fail but none of the compressors need replacement, the system does not need to change from an HFC refrigerant. Furthermore, additional display cases cannot be added to any location, as this would increase the system load.
A new installation of a system is still considered a new installation even when previously installed parts are utilized. Relocating a system from one location to another also qualifies as a new installation. However, provided that the existing compressors remain in place and are not replaced, previously installed display cases may be used to replace unserviceable equipment, as long as this does not exceed 75% of the total display cases.
AIM Act limits for the Hybrid™ Merchandiser
Hybrid™ Merchandiser AIM Act Repair Restrictions
Effective January 1, 2026, the installation of Hybrid™ Merchandiser display cases is prohibited under the AIM Act. However, remote display cases can be repaired throughout their life cycle. The AIM Act repair restrictions for Hybrid™ Merchandisers focus on the remote condensing unit and the evaporator coil. The AIM Act allows the replacement of either the remote condensing unit or the evaporator coil in a single repair, but not both simultaneously.
Hybrid™ Merchandisers in operation before the effective date may be relocated to other locations. However, new Hybrid™ Merchandisers cannot be moved from storage and installed.
The Future of Hybrid™ Merchandisers
The Hybrid™ Merchandiser will join the ranks of our legacy display cases on January 1, 2026. Zero Zone will honor all valid warranty claims and will assist with service and parts as long as supplies last. At Zero Zone, we understand how important it is to have the flexibility of a self-contained refrigerated display case. As the responsive company, we are committed to meeting our customers’ needs. For more information, please fill out a form on our Contact Us page.
AIM Act limits to Self-contained Display Case
Self-Contained Display Case AIM Act Repair Restrictions
Typically, self-contained units have a single compressor and a single evaporator. This instance is similar to the Hybrid™ Merchandisers. The compressor or evaporator can be replaced during a single repair, but not both simultaneously.
The Future of Self-Contained Display Cases
To comply with the AIM Act mandates, several refrigerants can be used in self-contained display cases. One such category is A2L refrigerants, known for their mild flammability and low toxicity. These synthetic blends are designed to operate similarly to HFC refrigerants. For example, R-1234yf is a hydrofluoroolefin (HFO) refrigerant with an ASHRAE safety rating of A2L and a GWP of 4.
Another option is propane, a natural refrigerant with a GWP of 3 and an ASHRAE safety designation of A3, indicating extreme flammability. Despite its flammability, safety precautions during transportation and use have significantly reduced the risk of accidents, ensuring safe handling.
Zero Zone Has the Answers
Staying ahead of regulatory changes and maintaining your commercial refrigeration systems through proactive measures is essential for ensuring compliance, efficiency, and longevity. By understanding and adapting to the AIM Act requirements, and implementing a robust preventative maintenance program, you can safeguard your operations, reduce costs, and maintain the quality of your products. At Zero Zone, we are committed to supporting you through these transitions and providing the necessary resources and services to keep your systems running smoothly. For more information or assistance, please fill out a form on our Contact Us page.
EPA Deregulation 2025
The EPA has launched a deregulation effort on March 12, 2025. We are closely monitoring the ongoing changes in regulations. Given the time required for any ruling to be effectively implemented and the Environmental Protection Agency’s (EPA) current position on reconsideration, we have decided to proceed under the assumption that the dates provided by the EPA will remain unchanged.
Our strategy involves preparing for the transition while adhering to the established timelines. This approach allows us to maintain compliance and readiness, regardless of potential modifications or delays. By staying informed and flexible, we aim to ensure a smooth transition and continue to meet regulatory standards.
We will continue to evaluate the situation and adjust our plans as necessary, prioritizing transparency and responsiveness to any further developments.