What is the AIM Act?

The American Innovation and Manufacturing Act (AIM Act) was signed into law on December 27, 2020. Its purpose is to reduce the production and consumption of hydrofluorocarbons (HFCs), granting the Environmental Protection Agency (EPA) authority to phase down HFC production and consumption significantly by 2036. This aligns the United States with the Kigali Amendment to the Montreal Protocol, an international agreement focused on reducing global HFC emissions and environmental impact.^{1, 8}

What are Hydrofluorocarbons and why is reducing emissions a priority?

According to the EPA, hydrofluorocarbons are man‑made fluorinated gases with very high global warming potential (GWP). Their use has increased in recent decades as substitutes for ozone‑depleting substances (ODS). As ODSs were phased out, HFC usage rose sharply.

Today, HFCs are widely used as refrigerants in modern refrigeration and air‑conditioning systems, as well as in fire suppression, solvents, foam‑blowing agents, and aerosols. Many fluorinated gases may remain in the atmosphere for decades or centuries before breaking down, making them among the most potent greenhouse gases still in use today.²

What is global warming potential?

The EPA explains global warming potential as a common unit of measure used to compare the warming impact of different greenhouse gases relative to carbon dioxide (CO₂). It measures how much energy 1 ton of a gas absorbs over a specific period compared to 1 ton of CO₂. A higher GWP indicates a stronger warming effect over that time period.

Because CO₂ is the reference gas, it has a GWP of 1. Fluorinated gases can have 100-year GWPs in the hundreds or thousands.³

What are the focal points of the AIM Act?

The AIM Act focuses on reducing HFC usage through three primary areas:

1. Production and consumption phasedown through an allowance allocation program
2. Transition to different technologies
3. Refrigerant management regulations

1. Production and Consumption Phasedown

The phasedown of HFC began with an initial 10% reduction between 2020 and 2023. Another 30% reduction between 2024 and 2028 is currently underway, which will bring production and consumption down by 40% from 2011-2013 baseline levels.

Future anticipated reductions include:

• 30% reduction from 2029 to 2033
• 10% reduction from 2034 to 2036
• Final 5% reduction in 2036

This results in an 85% total reduction by 2036.¹⁰

As supply decreases, refrigerant costs are expected to rise. Early leak detection becomes essential for cost control and environmental protection.

2. Transition to Different Technologies

The EPA’s Technology Transitions program under the AIM Act focuses on reducing demand for HFCs by establishing GWP‑based limits for certain refrigerants and adoption of lower-GWP alternatives in specific sectors, including HVAC‑R equipment manufacturing.

These restrictions began January 1, 2025, with additional sector‑specific limits rolled out in over the following years. These changes are expected to drive significant technological shifts across the HVAC‑R industry._¹¹

In May 2026, EPA finalized revisions to the 2023 Technology Transitions Rule, extending several compliance deadlines and adjusting GWP limits for specific sectors. Please see EPA’s latest Fact Sheet for further information._¹¹

3. Refrigerant Management

Subsection (h) of the AIM Act establishes regulations for HFC management, including leak reduction, reclamation, and technician safety . A final rule was published on October 11, 2024, with many key provisions going into effect as of January 1, 2026.⁴

A major component is the requirement for Automatic Leak Detection (ALD) systems for many new and existing refrigeration appliances. Additional regulations will address:

• Leak repair of appliances containing HFCs
• Reclamation standards
• Use of reclaimed HFCs in certain refrigeration, air conditioning, and heat pump applications
• Container tracking of HFCs
• Recordkeeping, reporting and labeling of HFCs
• Recovery of HFCs from disposable cylinders
• Service repair, disposal, or installation of HFC-containing fire suppression equipment⁵

With over 30 years helping safeguard people, places, and the planet, MSA offers a suite of products designed to support compliance with HFC regulations and enhance refrigerant leak detection. MSA provides direct detection ALD solutions using:

• Aspirated refrigerant monitoring systems
• Diffusion point detectors

What is an aspirated refrigerant monitoring system?

An aspirated system pulls air samples from leak‑prone areas for analysis. These systems detect extremely low‑level leaks, with Minimum Detectable Levels (MDL) as low as 1 ppm. Their continuous sampling and low detection thresholds make them highly effective for early leak identification.

What is a diffusion point detector?

A diffusion detector relies on gas dispersing into the air and reaching the sensor for a leak to be detected. These systems typically detect leaks at around 150 ppm and are best suited for personnel safety in mechanical or rack rooms.

MSA products supporting automatic leak detection requirements

The following MSA systems can be used to meet subsection (h) ALD requirements:

• MSA Single‑Zone Refrigerant Monitor
• MSA Bacharach Multi‑Zone Gas Monitor
• MSA Chillgard® 5000 Refrigerant Leak Monitor

All use aspirated sensing, detect leaks as low as 1 ppm, and can monitor up to 48 sample points across more than 60 refrigerants.

These MSA products are compatible with the MSA Bacharach award-winning Parasense Refrigerant Tracking & Compliance Software, which offers industry-leading refrigerant management and tracking tools to help users reduce operating costs and streamline regulatory compliance efforts, and become leaders in sustainability and efficiency.

MSA products supporting leak inspection requirements

The MSA Bacharach PGM‑IR Portable Refrigerant Monitor can help users meet the proposed inspection requirements of subsection (h) of the AIM Act. This sensor is portable and can be used to inspect areas and pinpoint exact locations where leaks are occurring. It detects leaks as low as 1 ppm, is resistant to humidity and temperature changes, and includes a charcoal purge filter for use in contaminated spaces.⁵

How can automatic leak detectors save users money?

In addition to supporting regulatory compliance needs, early leak detection can reduce refrigerant loss and prevent costly system recharges.

According to EPA Greenchill project reports, a typical supermarket refrigeration system experiences annual leak rates of roughly 13 to 25%. For a store with a system charge size of 4,000 lbs, this could mean losses of up to ~1,000 pounds of refrigerant per year.⁹ As requirements of the AIM Act are implemented, supply of HFC refrigerants will drop and cost is expected to rise. This rise in cost can potentially push recharge costs to $50,000–$100,000. Installing ALD systems can help mitigate these rising costs.²

Sources:

1. EPA (2026): Background on HFCs and the AIM Act
   https://www.epa.gov/climate-hfcs-reduction/background-hfcs-and-aim-act
2. EPA (2025). Technology Transitions Under the AIM Act.
   https://www.epa.gov/climate-hfcs-reduction/technology-transitions
3. EPA (2025). Understanding Global Warming Potentials
   https://www.epa.gov/ghgemissions/understanding-global-warming-potentials
4. EPA (2024). Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes (Final Rule). Federal Register, Published October 11, 2024.
   https://www.federalregister.gov/documents/2024/10/11/2024-21967/phasedown-of-hydrofluorocarbons-management-of-certain-hydrofluorocarbons-and-substitutes
5. EPA (2024). Regulatory Actions for Managing HFC Use and Reuse. https://www.epa.gov/climate-hfcs-reduction/regulatory-actions-managing-hfc-use-and-reuse
6. Hydrofluorocarbon Phasedown: Background and Issues Facing Congress https://www.congress.gov/crs_external_products/IF/PDF/IF11779/IF11779.6.pdf
7. Fact Sheet American Innovation and Manufacturing Act: Leak Repair Requirements for Appliances Containing Hydrofluorocarbons and Certain Substitutes https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-leak-repair-2026-01-13_1.pdf
8. ACHR News (2024). EPA Issues Final Rule on Managing HFCs.
   https://www.achrnews.com/articles/156990-epa-issues-final-rule-on-managing-hfcs
9. GreenChill – Keeping Cool for Fifiteen Years (2007-2022) https://www.epa.gov/system/files/documents/2022-09/GreenChill-Keeping-Cool-for-15-Years-2022_1.pdf
10. Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program Under the American Innovation and Manufacturing Act https://www.federalregister.gov/documents/2021/10/05/2021-21030/phasedown-of-hydrofluorocarbons-establishing-the-allowance-allocation-and-trading-program-under-the
11. Final Rule: Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020
    https://www.epa.gov/system/files/documents/2026-05/fact-sheet-san-12166-technology-transitions-frm.pdf