The AIM Act: What It Actually Means If You Service HVAC
The AIM Act is a separate statute from Section 608, with its own rules at 40 CFR Part 84. It does not change your certification — but since January 2026 it does impose leak repair duties Section 608 never reached.
On this page
- What is the AIM Act?
- Does the AIM Act change my EPA 608 certification?
- What does the phase-down actually cap?
- What does the Technology Transitions rule ban?
- Where the AIM Act does bind a technician
- What this means on the job
- Frequently asked questions
- Is R-410A being phased out?
- Can we still install R-410A equipment in 2026?
- Who signed the AIM Act into law?
- Does the AIM Act require me to get recertified?
- Do I need a 608 card to buy HFC refrigerant?
- Sources
The AIM Act is a 2020 federal statute, 42 U.S.C. § 7675, that directs EPA to cut US production and consumption of HFCs by 85% below a historic baseline by 2036. Its rules live at 40 CFR Part 84 and are entirely separate from Section 608. It does not change, renew or add to your technician certification. It does regulate the refrigerant itself.
Most of what is written about the AIM Act is aimed at facility managers and compliance officers. That leaves technicians with a confused picture in which the AIM Act, Section 608, and a supposed "A2L license" all blur into one thing. They are three different things, and one of them does not exist. Here is the boundary, drawn properly.
What is the AIM Act?
The American Innovation and Manufacturing Act was enacted on December 27, 2020 as part of the Consolidated Appropriations Act, 2021. It gives EPA three distinct authorities over hydrofluorocarbons, and each one produced its own rulemaking (EPA).
| Subsection | What it authorizes | What it produced |
|---|---|---|
| (e) | Phase down production and consumption of listed HFCs | The allowance allocation program — a supply cap on the chemical |
| (i) | Restrict HFC use by sector to push next-generation technology | The Technology Transitions rule — GWP limits on new equipment |
| (h) | Maximize reclamation, minimize releases from equipment | The Emissions Reduction and Reclamation (ER&R) rule |
Note what is not on that list. Nothing in the AIM Act touches technician certification. That remains what it has always been: Section 608 of the Clean Air Act, implemented at 40 CFR Part 82, Subpart F.
Does the AIM Act change my EPA 608 certification?
No. Your card is issued under a different statute, administered under a different CFR part, and unaffected by any AIM Act rulemaking.
Section 608 certification does not expire, and the AIM Act did not create an expiry, a renewal cycle, or a continuing-education requirement. If you hold Type I, Type II, Type III or Universal, you hold it on the same terms you did in 2019.
There is also no federal "A2L license." EPA has not created a separate credential for mildly flammable refrigerants, and anyone selling you one is selling a training course, not a certification. The details of what actually does and does not apply to A2Ls are covered in what EPA requires for A2L refrigerants.
What does the phase-down actually cap?
Subsection (e) caps how many tonnes of listed HFCs may be produced in or imported into the United States. It is a ceiling on supply, enforced against producers and importers through an allowance system. It does not tell you what to do on a job, and it does not restrict your right to buy refrigerant or service a system.
The steps, as a percentage of the historic baseline (EPA):
| Period | Cap, as % of baseline |
|---|---|
| 2020–2023 | 90% |
| 2024–2028 | 60% |
| 2029–2033 | 30% |
| 2034–2035 | 20% |
| 2036 onward | 15% |
The 2024 drop from 90% to 60% is the one that moved prices. The 2029 drop to 30% is the steepest step still ahead. Neither makes any refrigerant illegal to use — they make it scarcer, which shows up on your invoice rather than in an enforcement action.
What does the Technology Transitions rule ban?
Subsection (i) sets global warming potential limits on newly manufactured and imported equipment, sector by sector. It says nothing about equipment already in service.
For residential and light commercial air conditioning and heat pumps, the limit is 700 GWP, which R-410A sits far above. That is why manufacturers moved to R-454B and R-32. It is also why so much homeowner-facing content wrongly claims R-410A is banned — the equipment restriction gets reported as a refrigerant ban. The full picture, including the installation deadline EPA removed in 2026, is in the R-410A phase-out.
The rule you are working under when you open that system is still Section 608. The AIM Act determined what the manufacturer could build. It did not change your recovery obligations.
Where the AIM Act does bind a technician
This is the part almost nobody covers, and since January 2026 it is the most consequential thing on this page.
Section 608's leak repair rule at 40 CFR 82.157 has a gap in it. It applies only to appliances with a full charge of 50 pounds or more of a Class I or Class II refrigerant, or a blend containing one. It expressly does not apply to appliances containing solely substitute refrigerants. An R-410A rack, whatever its size, was never covered by it.
The ER&R rule under subsection (h) closes that gap. EPA finalized it on October 11, 2024, and established leak repair requirements at 40 CFR 84.106 for appliances with a full charge of 15 pounds or more containing an HFC or certain HFC substitutes, with compliance beginning January 1, 2026 (EPA).
| Section 608 — 82.157 | AIM Act — 84.106 | |
|---|---|---|
| Statute | Clean Air Act § 608 | AIM Act § (h) |
| Refrigerants covered | Class I and Class II, and blends containing them | HFCs and certain substitutes |
| Charge threshold | 50 lb or more | 15 lb or more |
| Applies since | January 1, 2019 | January 1, 2026 |
Two leak repair regimes now run in parallel, on different refrigerants, at different charge sizes. A 40-pound R-410A system that fell outside every leak repair rule in 2024 is inside one now. The duty sits on the owner or operator, but it runs on your paperwork: under 82.157(b) the technician who adds or removes refrigerant must hand the owner documentation of what moved. Without that record the leak rate cannot be calculated, and the failure traces straight back to the person who did the work.
What this means on the job
Four practical consequences.
Your certification is untouched. Do not pay for an AIM Act renewal, an A2L card, or any credential someone claims the 2024 rules created. Nothing created one.
Document every charge, on every system. The old mental shortcut — "it's R-410A, the leak rule doesn't reach it" — expired on January 1, 2026. Assume the charge record matters and write it down.
Recovery discipline is now economics as well as law. Each step down in the cap makes what you vent harder to replace. The procedure itself has not changed; what Section 608 requires when you recover is the same rule it was before the AIM Act existed.
Know which statute a question is testing. The 608 exam is written to Part 82, not Part 84. If a question asks about a leak rate or an evacuation level, it wants the Section 608 answer. Working through a full set of practice questions is the fastest way to stop the two rulebooks bleeding into each other.
Frequently asked questions
Is R-410A being phased out?
R-410A production is being phased down, not banned. New residential and light commercial equipment designed for it can no longer be manufactured or imported for the US market because of the 700 GWP limit, but existing systems may be serviced, topped up and repaired indefinitely. EPA has announced no end date for servicing.
Can we still install R-410A equipment in 2026?
Yes. EPA finalized a rule in May 2026 removing the January 1, 2026 installation deadline for systems whose components were manufactured or imported before January 1, 2025. Pre-2025 distributor stock can be installed until it runs out. Advice published before mid-2026 describes a deadline that no longer exists.
Who signed the AIM Act into law?
President Trump signed the AIM Act on December 27, 2020. It was enacted as Section 103 of Division S, "Innovation for the Environment," of the Consolidated Appropriations Act, 2021. It passed with bipartisan support and backing from US refrigerant and equipment manufacturers, who preferred a single federal phase-down schedule to a patchwork of state rules.
Does the AIM Act require me to get recertified?
No. Section 608 certification has no expiry date and the AIM Act did not add one. No AIM Act rulemaking creates a technician credential, a renewal, or a continuing-education requirement. Any product sold to you as an "AIM Act certification" is a training course, not a federal requirement.
Do I need a 608 card to buy HFC refrigerant?
Yes, and that rule predates the AIM Act. Under 40 CFR 82.154(c), non-exempt substitute refrigerants may only be sold to a certified technician or their employer. That has applied to HFCs since 2018. The AIM Act changed the price of the cylinder, not the condition of buying it.
Sources
Notice
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