What You and Your Service Providers Need to Know About Refrigerant Management and the AIM Act
Introduction
In today’s regulatory environment, effective refrigerant management is not just a best practice—it’s a necessity. For businesses managing HVAC and refrigeration systems, understanding and complying with the latest regulations, such as the AIM Act, is crucial to avoid costly penalties, reduce environmental impact, and safeguard public health. But with evolving standards and an increasing focus on sustainability, what do facility managers and service providers really need to know?
This report breaks down the essentials of refrigerant management and the AIM Act, offering practical insights for both compliance and operational efficiency. We’ll explore the fundamentals of refrigerant management, the new mandates of the AIM Act, and the changes it brings to everyday practices. We’ll
also discuss specific protocols, cost implications, and the importance of proactive client communication. By the end, you’ll have a clear roadmap to navigate these regulations, enhance compliance, and play a part in a more sustainable future.
What is refrigerant management? Why is it important?
Refrigerant management involves the meticulous handling, monitoring, and regulation of refrigerants within HVAC and refrigeration systems to prevent leaks that release harmful substances into the atmosphere. These substances—often hydrofluorocarbons (HFCs) and other high-global warming potential (GWP) gasses—pose significant environmental risks, contributing to both ozone depletion and climate change. Managed improperly, these refrigerants can quickly escalate into serious issues, impacting asset performance, increasing operational costs, and potentially leading to substantial environmental damage.
Effective refrigerant management is more than just an operational protocol; it’s a critical part of sustainability efforts and regulatory compliance. Organizations that prioritize refrigerant management benefit from improved equipment efficiency, extended asset life, and minimized repair costs. Leaks can severely degrade system performance, requiring expensive maintenance or early replacement of equipment. By maintaining stringent control over refrigerant levels and integrity, businesses can lower operating costs, ensure better energy efficiency, and reduce their environmental footprint.
The regulatory landscape further underscores the importance of refrigerant management. In the U.S., the Environmental Protection Agency (EPA) mandates compliance with standards aimed at reducing refrigerant emissions. Under the recent AIM Act, these regulations have expanded to include a phasedown of HFCs, which will significantly impact the industry by introducing stricter limits on refrigerant production and imports. The AIM Act’s ambitious goals, including an 85% phasedown of HFCs by 2036 and a targeted reduction of 120 million metric tons of CO2 equivalents between 2026 and 2050, reflect the government’s commitment to reducing environmental harm.
By implementing robust refrigerant management practices, businesses not only avoid the hefty fines associated with non-compliance but also contribute positively to global climate goals. Effective refrigerant management involves proactive leak detection, regular system maintenance, proper documentation of refrigerant usage, and prompt response to any leaks or emissions. When fully integrated, these practices help companies uphold their environmental responsibilities, strengthen their sustainability initiatives, and build consumer trust. With today’s technology, organizations can now track and manage refrigerant use more efficiently than ever, ensuring they stay compliant and support a healthier planet for future generations.
What is the AIM Act, and what’s changing?
The American Innovation and Manufacturing (AIM) Act, enacted in 2020, represents a significant step forward in the regulation of refrigerants, specifically targeting hydrofluorocarbons (HFCs) due to their high global warming potential. HFCs, which have been widely used as substitutes for ozone-depleting substances (ODS) in refrigeration and air conditioning, have come under scrutiny for their substantial impact on climate change. The AIM Act mandates a phasedown of HFC production and import, with an ambitious target of reducing HFC levels by 85% by 2036. This phasedown aligns the U.S. with international agreements, such as the Kigali Amendment to the Montreal Protocol, which seeks to minimize the global use of these potent greenhouse gasses.
Building upon existing environmental regulations, the AIM Act expands the requirements traditionally applied to ODS to now include HFCs, introducing stringent controls on refrigerant management across industries. The AIM Act’s regulations encompass a range of new compliance measures, such as mandatory leak detection and repair protocols, more comprehensive record-keeping, and limitations on refrigerant purchases to prevent illegal sales.
These requirements apply not only to large industrial systems but also extend to smaller HVAC and refrigeration assets, broadening the scope and impact of compliance across the market.
One of the most transformative aspects of the AIM Act is the introduction of mandatory leak detection systems, especially for large-scale refrigeration and HVAC equipment. Under these new regulations, businesses must install automatic leak detection devices on systems with high refrigerant charges, ensuring quick identification and mitigation of leaks to reduce emissions. Additionally, the AIM Act requires the use of reclaimed or recycled HFCs when servicing existing equipment, promoting a sustainable approach to refrigerant use and reducing reliance on newly manufactured HFCs.
The AIM Act also imposes strict record-keeping and reporting standards for refrigerant usage, maintenance, and disposal. Companies are now responsible for maintaining detailed documentation of refrigerant handling, which includes tracking usage, leaks, repairs, and the amount of refrigerant reclaimed or recycled. This shift to enhanced documentation not only supports regulatory oversight but
also encourages companies to adopt more accountable and sustainable refrigerant management practices. Failure to comply with these requirements can lead to significant financial penalties, with fines potentially reaching over $60,000 per day for non-compliance.
In addition to its environmental objectives, the AIM Act reflects a shift in the industry’s approach to refrigerant management by encouraging the transition to next-generation refrigerants with lower global warming potentials. This push for innovation is expected to drive the development and adoption of alternative refrigerants, such as hydrofluoroolefins (HFOs), that offer the cooling effectiveness of HFCs but with a reduced environmental impact. This evolution toward sustainable refrigerants marks a critical change in the HVAC and refrigeration sectors, as companies begin phasing out high-GWP refrigerants and modernizing their equipment to align with the AIM Act’s requirements.
Overall, the AIM Act signifies a new era in refrigerant management, one that requires companies to be proactive in their environmental stewardship. Compliance with these updated standards is essential for companies aiming to avoid costly fines and minimize their environmental footprint, while also staying
competitive in an industry that increasingly values sustainability. Through rigorous adherence to the AIM Act’s provisions, businesses can not only ensure regulatory compliance but also contribute to global efforts to combat climate change and protect the environment.
Still not clear on what this means for you? Check out this flow chart and find out if your organization’s refrigeration and air conditioning assets are affected by new changes to the AIM Act. Also download our 2025 Refrigerant Regulations Roadmap—a valuable resource for preparing your refrigerant management
strategy for the future.
Are there specific protocols, restrictions, or record-keeping practices that technicians and service managers need to implement or update?
The AIM Act introduces a series of stringent protocols, restrictions, and recordkeeping practices designed to limit the environmental impact of refrigerants and improve compliance across HVAC and refrigeration systems. These new regulations demand a proactive approach from service providers, technicians, and facility managers to ensure they meet evolving standards.
Key protocols under the AIM Act include:
Strict Leak Repair Requirements and Timelines: Any detected leaks in refrigeration systems must be repaired promptly according to specific timelines set by the AIM Act. This ensures that refrigerants, especially those with high global warming potential, are contained and do not escape into the atmosphere. The regulations mandate timely follow-up checks to verify the effectiveness of repairs, minimizing potential environmental harm.
Mandatory Installation of Automatic Leak Detection Systems: For larger refrigeration and HVAC systems, the AIM Act requires the installation of automatic leak detection systems. These systems are designed to continuously monitor refrigerant levels and immediately alert facility managers and technicians to any irregularities or potential leaks. By catching leaks early, these detection systems help reduce refrigerant loss, avoid emergency repairs, and contribute to a more sustainable management approach.
Enhanced Record-Keeping and Documentation Standards: Service providers must now keep meticulous records documenting refrigerant usage, maintenance activities, leak incidents, repairs, and refrigerant recovery or recycling efforts. This documentation must be readily available for audits, as failure to maintain accurate records could result in hefty fines and penalties. Records should include specifics about the type and quantity of refrigerant used, dates of service activities, technician certifications, and compliance with the AIM Act’s required maintenance timelines.
Tracking and Reporting Compliance Data: In addition to leak detection and repair documentation, companies must now track and report data related to refrigerant purchases, inventory levels, and disposal practices. This data collection supports regulatory transparency, enabling both internal audits and external inspections to verify compliance.
These expanded requirements emphasize the need for service providers and facility managers to adopt robust refrigerant tracking systems. Implementing automated tracking tools and digital documentation can streamline compliance and minimize the risk of human error. Regular training on these new protocols is also essential, as technicians need to stay current with compliance mandates to avoid the high costs associated with regulatory violations. By adhering to these enhanced standards, organizations not only protect themselves from penalties but also contribute positively to environmental sustainability.
To ensure full compliance with the AIM Act’s updated requirements, service managers and technicians can refer to our Asset Inventory Checklist for a stepby-step guide on tracking refrigerant assets, documenting usage, and maintaining required records—essential tools for effective refrigerant management.
How will the AIM Act affect the costs and practices around refrigerant management?
Although effective refrigerant management can lower overall costs by reducing leaks and maintenance requirements, implementing these new practices may involve initial startup costs. Organizations should expect increased costs associated with establishing more stringent protocols, updating tracking systems, and possibly training staff to meet the AIM Act’s standards. However, these costs are often offset by long-term savings achieved through reduced refrigerant loss and improved equipment efficiency.
Should service providers anticipate changes in pricing, service frequency, or materials used?
How can they communicate these shifts to clients? Service providers may see shifts in service pricing, frequency, and materials as the AIM Act introduces more robust compliance requirements. Providers should communicate any changes clearly to clients, explaining that increased record-keeping requirements and stricter repair protocols are part of a regulatory effort to enhance sustainability. This proactive communication can help clients understand the value of compliance while managing expectations around potential cost adjustments.
Why is compliance important? What does non-compliance entail?
Compliance with refrigerant regulations is essential not only to avoid fines but also to support environmental sustainability. Penalties for non-compliance are steep, with fines exceeding $60,000 per day in some cases. Non-compliance also leads to inefficient operations, higher leak rates, and increased environmental harm, ultimately wasting valuable resources and potentially harming a company’s reputation.
What role do service providers play in educating their clients on compliance?
Service providers play a critical role in educating clients about compliance requirements under the AIM Act. Trusted technicians can inform clients on which assets are impacted by new regulations, helping facility leaders understand both immediate compliance needs and long-term maintenance impacts. By providing guidance on the AIM Act’s requirements, service providers can empower clients to make informed decisions about refrigerant management and compliance.
How should technicians and repair companies approach client education on AIM Act compliance and its impact on refrigerant systems?
Service providers should adopt a consultative approach, educating clients about the specific regulations that apply to their systems and the best practices for compliance. Providers should emphasize the cost and operational benefits of proper refrigerant management, including reduced leaks, improved system
efficiency, and minimized regulatory risk. By explaining the AIM Act’s impact in clear, practical terms, providers can help clients recognize the importance of adhering to these new standards.
What technologies or tools support compliance with the AIM Act?
Refrigerant management software solutions, such as Fexa Trakref, play an essential role in achieving AIM Act compliance. These tools provide comprehensive tracking capabilities, automated record-keeping, and real-time monitoring, helping organizations maintain accurate compliance documentation. Advanced features include:
- Real-time leak detection.
- Automated alerts for maintenance and compliance deadlines.
- Tracking and documentation for EPA and AIM Act reporting. These technologies streamline compliance efforts, reducing the administrative burden on technicians and ensuring that organizations can meet regulatory demands efficiently.
In addition, Trakref also released a new API that can integrate with any CMMS.
How can you ensure compliance and sustainable practices for the future?
With the enactment of the AIM Act, organizations must prioritize refrigerant management to ensure compliance and support environmental sustainability.
The Act’s expanded requirements mean that both facility managers and service providers must adapt to stricter protocols, increased documentation, and proactive leak management. Service providers, in particular, are pivotal in guiding clients through these regulatory changes, providing education on best
practices and leveraging advanced technologies to streamline compliance. Through diligent refrigerant management and a commitment to sustainable practices, organizations can protect both the environment and their bottom line.