The American Innovation and Manufacturing Act (AIM Act) directs the Environmental Protection Agency (EPA) to regulate the transition to alternative refrigerants by phasing down the production and consumption of HFC refrigerants. The EPA has published a proposed rule that will prohibit the manufacture of equipment containing HFCs by 1/1/2025 and prohibit the sale of those products by 1/1/2026.

Which states are affected?

This rule would apply to the entire country, which would finally bring alignment across the country instead of state-by-state regulations. States will still be able to issue their own, more stringent regulations, and some states will still require attention, such as California and New York.

Which refrigerants are affected?

This rule proposes to restrict the use of refrigerants by their global warming potential (GWP). Generally speaking, equipment that uses more than 200 lbs. of refrigerant will be subject to a GWP limit of 150, and equipment that uses less than 200 lbs. of refrigerant will be subject to a GWP limit of 300. Chiller systems will be subject to a GWP limit of 700.

These GWP limits will end the use of refrigerants such as R-404A (GWP of 3943), R-407A (GWP of 1923), R-410A (GWP of 1924), R-448A (GWP of 1273), R-449A (GWP of 1282), and R-507 (GWP of 3985) in new equipment. Going forward, refrigeration equipment will need to use natural refrigerants, such as CO2 (GWP of 1) and ammonia (GWP of 0), and HFO-based refrigerants since there are options below the proposed GWP limits.

When will the rule be finalized?

Currently the proposed rule is available for comments until 1/30/23. The proposed rule will be finalized in October 2023. We do not expect the GWP limits to change, but the implementation date might get pushed back to help manufacturers and end users complete existing projects. Industry leaders are also asking for clarification about how the implementation dates are defined, and for clarification about how “new projects” will be defined compared to retrofit or remodel projects.

Further Reading

Zero Zone has a new paper, “The National Plan for Refrigerant Regulations,” which has more information about the upcoming EPA regulations, which states will still have regulations to follow, and solutions that Zero Zone offers.

To know where we have come from, Zero Zone has a paper, “The State of Refrigerant Regulations,” which covers state regulations that affected the United States from 2019 through 2024.

The proposed rule and a succinct fact sheet are available on the EPA website:

If you have questions about these regulations, please contact Zero Zone and ask to speak to our Director of Regulatory Compliance & Refrigeration Technology. If you want to learn about our offerings and plan for these regulations, contact our sales team.