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AIM Act Restrictions 2025

Now that we have crossed into 2025, the first restrictions of the American Innovation and Manufacturing (AIM) Act are now in effect. The AIM Act of 2020 allows the EPA to restrict the production, import, and use of hydrofluorocarbons (HFCs). HFC refrigerants have a high global warming potential (GWP) and are being phased down by 85% through 2035.

The Refrigerants allowed by the AIM Act are not direct substitutes for HFC refrigerants. Refrigeration systems require different components, piping and programming with each refrigerant. The performance of refrigeration systems is influenced by the external ambient temperatures.

Equipment installed before restrictions go into effect are allowed to maintain operation throughout their useful life. This includes service, parts, and refrigerant. However, the availability of each is dependent on the manufacturer.

Retrofitted equipment and new installations have their own regulations and definitions. Retrofitted equipment, replacing at least 75% or more of the evaporators and 100% of the compressor racks, condensers, and connected evaporator loads of an existing system, will need to follow the restrictions for a new installation. For more information on the AIM Act and state regulations, visit our Refrigerant Regulations webpage.

AIM Act Quick Reference

For a quick reference sheet for the AIM Act, download our industrial or retail infographics.

Industrial Refrigeration Systems

If you need to know how industrial refrigeration systems are affected by the AIM Act, download our industrial systems infographic.
Download the Industrial Systems Infographic

Retail Refrigeration Equipment

If you need to know how retail refrigeration equipment and refrigerated display cases are affected by the AIM Act, download our retail infographic.
Download the Retail Infographic

Reporting and Record Keeping

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To track the sale, distribution, and use of HFCs, the EPA now requires manufacturers, importers and exporters to submit annual reports starting January 2025. The first report will be due by March 31, 2026. This requirement applies to all sectors and subsectors for Refrigeration Air Conditioning, and Heat Pump (RACHP) equipment. More information can be found at Reporting and Recordkeeping Resources | US EPA.

California and Washington have expanded these regulations to include end-user leak reporting. Facilities with more than 50 pounds of refrigerant charge are required to perform regular leak inspections, follow specific guidelines for repairing leaks, and maintain the service records on-site. In California, facilities can register online with the California Air Resource Board Refrigerant Management Program to report online. Washington’s reporting and registration are available through the Department of Ecology State of Washington Refrigerant Management Program.

New Regulations Affecting Industrial Refrigeration Systems and Retail Refrigeration in 2025

Industrial Regulations

As of January 1, 2025, ice rinks can no longer install chillers using a refrigerant with a GWP of 700 or greater. Chillers using natural refrigerants like ammonia (GWP 0) and CO2 (GWP 1) offer a future-proof solution to these regulations. The Zero Zone ColdLoop™ chillers and Genesys™ Natural Refrigeration Solutions are designed to operate with natural refrigerants to ensure your ice rink ready for use 24/7, year-round.

Retail Regulations

Regulations that went into effect January 1, 2025 also affect self-contained refrigeration units. These units are limited to refrigerants with a GWP 150 or less. As an alternative to a self-contained condensing unit, the Zero Zone Hybrid™ merchandisers are considered a remote display case with a remote condensing unit. They will be available for installation until January 1, 2026. Although the Hybrid™ merchandiser cannot be installed after 2026, you can expect service and support from Zero Zone after production has ceased.

Looking Ahead to 2026

 

The next step in the phasedown of HFC refrigerants happens January 1, 2026. This next stage affects cold storage warehouses, industrial chillers, and remote condensing units. The following equipment must be installed and operational before January 1, 2026.

  • Cold storage warehouses
    • For systems with 200 pounds of refrigerant charge (excluding the high-temperature side of cascade), the maximum GWP is 150.
    • For systems with less than 200 pounds of refrigerant charge, the restriction is a GWP limit of 300.
    • For high-temperature side of cascade systems, the limit is also a GWP of 300.
  • Chillers
    • Industrial process refrigeration facilities using chillers with an exiting fluid above -30° (-58°F) will have the refrigerant limited to 700 GWP
  • Industrial process refrigeration (not using chillers)
    • 200 or more lb refrigerant charge excluding high temperature side of cascade system temperature of the refrigerant entering the evaporator above -30°C (-22°F)
    • GWP 150
  • High temperature side of cascade systems and temperature of the refrigerant entering the evaporator above -30°C (-22°F)
    • GWP 300

Zero Zone has the Experts

The restrictions listed in the AIM Act and the California, Washington, and New York resource boards can be overwhelming to remember. However, Zero Zone knows them and will help you make the right choice for your specific needs. To learn more about refrigerant regulations, visit our refrigerant regulations webpage or fill out a general request on our contact us page.