AIM Act Compliance
for Commercial HVAC
Everything contractors and facility managers need to know about EPA refrigerant regulations, phase-down timelines, and choosing compliant equipment.
What is the AIM Act?
American Innovation and Manufacturing Act of 2020
The American Innovation and Manufacturing (AIM) Act was signed into law in December 2020 as part of the Consolidated Appropriations Act. It grants the EPA authority to phase down the production and consumption of hydrofluorocarbons (HFCs) by 85% over the next 15 years.
HFCs are potent greenhouse gases used primarily as refrigerants in air conditioning and refrigeration equipment. While they replaced ozone-depleting substances like R-22, many HFCs have global warming potentials (GWP) hundreds to thousands of times greater than CO2.
For the commercial HVAC industry, this means a mandatory transition away from high-GWP refrigerants like R-410A (GWP: 2,088) toward approved alternatives like R-32 (GWP: 675) and R-454B (GWP: 466).
Refrigerant Comparison
Understanding the key differences between current and next-generation commercial HVAC refrigerants.
R-32
Used by Daikin, Goodman, ACiQ in packaged rooftop units. Single-component refrigerant with excellent thermodynamic properties.
R-454B
Used by Trane, Carrier in commercial packaged systems. Zeotropic blend designed as a direct replacement for R-410A in existing system architectures.
R-410A
Legacy refrigerant still legal for existing equipment service. New equipment manufacturing transitioning to R-32 and R-454B. Expect rising costs as supply decreases.
Phase-Down Timeline
Key milestones in the HFC reduction schedule
AIM Act signed into law as part of the Consolidated Appropriations Act, directing EPA to phase down HFC production and consumption by 85% over 15 years.
EPA finalizes the HFC Allocation Rule, establishing the allowance allocation and trading program for HFC production and consumption.
Cumulative 40% reduction in HFC production baseline achieved. Manufacturers accelerate transition to low-GWP refrigerant systems.
New commercial AC and heat pump equipment must use refrigerants with GWP below 700. R-410A phase-down begins for new equipment manufacturing.
Further reductions scheduled. Equipment using R-410A expected to become increasingly difficult to source for new installations.
Final 85% reduction target. Only low-GWP refrigerants (R-32, R-454B, and next-gen alternatives) permitted in new commercial HVAC equipment.
Who is Affected?
Facility Managers
When replacing rooftop units, you must specify AIM Act compliant equipment. Plan ahead -- lead times for compliant units may be longer during the transition period.
HVAC Contractors
You need updated EPA 608 certification for A2L refrigerants, compatible recovery equipment, and familiarity with new system specifications from each manufacturer.
Business Owners
Budget for compliant equipment on your next replacement cycle. New units may qualify for federal tax credits and state rebates that offset the transition cost.
Environmental Impact
Why the transition matters
Projected global warming reduction from full HFC phase-down by 2100
Reduction in HFC production and consumption by 2036 under AIM Act
Metric tons of CO2 equivalent emissions avoided over 30 years
The transition to low-GWP refrigerants is one of the most impactful climate actions available today. By choosing R-32 or R-454B equipment, you are directly contributing to reduced greenhouse gas emissions while often achieving equal or better energy efficiency compared to legacy R-410A systems.
AIM Act by State: Additional Requirements
Some states have regulations that go beyond the federal AIM Act. Here are the key states with supplementary HVAC requirements.
California (Title 24 + CARB)
California enforces the most stringent HVAC regulations in the country. Title 24 energy standards require higher minimum efficiency ratings for commercial equipment beyond federal minimums. The California Air Resources Board (CARB) has additional refrigerant management regulations including leak detection, reporting, and repair requirements for commercial systems with 50+ pounds of refrigerant. All commercial HVAC equipment installed in California must meet both federal AIM Act and state Title 24 requirements.
Shop tax-free for California →New York (Climate Leadership and Community Protection Act)
New York's CLCPA sets aggressive emissions reduction targets that impact HVAC equipment selection. The state requires GHG emission reductions of 40% by 2030 and 85% by 2050 from 1990 levels. New York City has additional Local Law requirements for building emissions, which increasingly influence commercial HVAC specification toward high-efficiency, low-GWP equipment. Commercial buildings in NYC are subject to emissions caps under Local Law 97.
Washington State (HFC Regulations)
Washington has adopted its own HFC regulations that in some cases are more restrictive than the federal AIM Act. The state prohibits certain high-GWP refrigerants in new equipment and has specific reporting requirements for commercial HVAC systems. Washington's Clean Buildings Act also sets energy performance standards that favor high-efficiency equipment using low-GWP refrigerants.
Other States to Watch
Colorado, Maryland, New Jersey, and Vermont have adopted or are considering additional refrigerant management regulations beyond the federal AIM Act. HVAC contractors working in these states should verify local requirements before specifying equipment. All equipment on ClimateProDirect meets or exceeds federal AIM Act standards and is suitable for installation in any US state.
Frequently Asked Questions
Common questions about AIM Act compliance for commercial HVAC
Can I still service existing R-410A equipment?
Yes. The AIM Act targets production and consumption of HFCs, not the use of existing equipment. You can continue to service, repair, and recharge R-410A systems. However, refrigerant costs may increase as supply decreases.
Is R-454B safe to handle?
R-454B is classified as A2L (mildly flammable). It requires EPA 608 certification for handling, and technicians should follow updated safety protocols. The flammability risk is very low in properly installed commercial systems.
Do I need special tools for R-454B systems?
Most standard HVAC tools work with R-454B. However, you should use R-454B-rated recovery equipment, leak detectors calibrated for the refrigerant, and ensure your manifold gauges are compatible. Check manufacturer guidelines.
What happens if I install R-410A equipment after the deadline?
Installing new R-410A equipment after applicable phase-down dates may violate EPA regulations and could result in penalties. Additionally, manufacturers may void warranties on non-compliant installations. Always check current regulations before specifying equipment.
Are there financial incentives for switching to compliant equipment?
Yes. Federal tax credits under the Inflation Reduction Act (IRA) provide incentives for high-efficiency HVAC equipment. Many states and utilities also offer rebates for installing energy-efficient, low-GWP systems. Check our rebates page for details.
How does this affect packaged rooftop units?
Packaged units are directly impacted. New commercial packaged AC and heat pump units manufactured after January 1, 2025 should use approved low-GWP refrigerants. Climate Pro Direct stocks compliant units from all major manufacturers.
Can I still install R-410A equipment I already have in stock?
Equipment manufactured before the phase-down deadline can still be installed, but availability of R-410A refrigerant for servicing will decrease over time and costs will rise. For new projects, specifying AIM Act compliant equipment ensures long-term serviceability and avoids potential regulatory issues.
Does AIM Act apply to replacement units in existing systems?
The AIM Act primarily targets new equipment manufacturing. Replacing an existing R-410A unit with another R-410A unit may still be possible with pre-phase-down equipment. However, most manufacturers are transitioning their entire lineups, making compliant units the practical choice for replacements.
What training do technicians need for A2L refrigerants?
Technicians handling A2L refrigerants (R-32, R-454B) need updated training covering: proper charging procedures, leak detection protocols, brazing safety with mildly flammable refrigerants, and emergency response procedures. HVAC trade associations and manufacturers offer A2L certification programs.
What is the difference between GWP and ODP?
GWP (Global Warming Potential) measures how much heat a greenhouse gas traps relative to CO2 over 100 years. ODP (Ozone Depletion Potential) measures impact on the ozone layer. R-32 has a GWP of 675 and ODP of 0. R-454B has a GWP of 466 and ODP of 0. Both are dramatically lower than R-410A (GWP 2,088, ODP 0).
Ready to Go Compliant?
Browse our full selection of AIM Act compliant packaged units from Daikin, Goodman, Trane, Carrier, and ACiQ.
Free freight on orders over $999. Volume pricing available for contractors.