AIM Act Refrigerant Changes 2026: What EPA 608 Technicians Need to Know
HFC phasedown deadlines, A2L refrigerant transition, new leak detection thresholds, and what the AIM Act means for your EPA 608 exam.
EPA 608 certification covers Section 608 of the Clean Air Act — but the regulatory landscape for refrigerants extends beyond Section 608. If you are new to EPA 608, see our overview of what EPA 608 certification is before reading this guide. The American Innovation and Manufacturing Act of 2022 (AIM Act) is the most significant U.S. refrigerant regulation since the Montreal Protocol, and its 2025–2026 implementation milestones are now changing what refrigerants appear in new equipment, what leak rates trigger mandatory repair, and what appears on the EPA 608 exam.
What the AIM Act Is and Why It Matters for EPA 608
The AIM Act — the American Innovation and Manufacturing Act of 2022 — authorizes the EPA to phase down production and consumption of HFCs (hydrofluorocarbons) in the United States. The law targets an 85% phasedown of HFC production and consumption by 2036 relative to a 2011–2013 baseline.
The AIM Act operates through three regulatory tools: Allowances (production/import limits), Technology Transitions (equipment-level phasedowns mandating new refrigerant use), and HFC Management Rules (handling, reporting, and leak repair obligations).
Why It Matters for EPA 608 Technicians
The Technology Transitions and HFC Management Rules directly affect which refrigerants technicians encounter in the field, what leak rate thresholds trigger mandatory repair, and what A2L refrigerant handling knowledge is tested on the Type II exam. Technicians who learned their EPA 608 facts before 2025 may be studying outdated information about equipment and refrigerants.
2026 HFC Phasedown Deadlines: What Changes This Year
The AIM Act's HFC Management Rule introduced new mandatory leak detection and repair requirements that took effect January 1, 2026. These are the most significant changes for EPA 608 technicians working on commercial and industrial equipment.
Key 2026 Change — Expanded Leak Detection Threshold
Prior to January 1, 2026: Mandatory leak repair rules applied to HFC-containing equipment with 50 or more pounds of refrigerant (the existing Section 608 threshold for high-pressure systems).
Effective January 1, 2026: Mandatory leak detection systems are required for HFC-containing appliances with 15 or more pounds of refrigerant. This significantly expands the universe of equipment subject to mandatory leak monitoring — many medium-sized commercial refrigeration units that were below the 50-lb threshold now require leak detection.
What This Means for the Exam
The EPA 608 exam is updated by certifying organizations (ESCO, Mainstream, HVAC Excellence) to reflect current regulatory requirements. Exam questions that previously focused on the 50-lb trigger for commercial refrigeration now increasingly test the 15-lb threshold introduced by the AIM Act HFC Management Rule.
R-410A and New Equipment Production
Beginning January 1, 2025, the AIM Act's Technology Transitions Rule limited production of R-410A-based equipment. New residential HVAC equipment manufactured in 2025 and beyond primarily uses A2L refrigerants — R-454B and R-32 — with GWP significantly lower than R-410A (466 and 675, respectively, versus R-410A's GWP of 2,088).
R-410A itself remains available for servicing existing equipment through existing supply channels and reclamation. Only new equipment production is affected — technicians will encounter R-410A systems in the field for decades as existing equipment remains in service.
A2L Refrigerants on the EPA 608 Exam: R-454B, R-32, and R-1234yf
A2L is an ASHRAE Standard 34 safety classification indicating mildly flammable refrigerants — lower flammability limit greater than 0.10 kg/m³ and burning velocity of 10 cm/s or less. A2L refrigerants are not considered "flammable" in the conventional sense but require specific handling precautions that differ from the A1 (non-flammable) refrigerants they replace.
Primary A2L Refrigerants Replacing HFCs
R-454B (Opteon XL41): Primary replacement for R-410A in new residential and light commercial split systems. GWP of 466 — 78% lower than R-410A. Requires A2L-rated equipment and installation practices. Already the dominant refrigerant in new residential equipment.
R-32: Used in some new residential split systems as a standalone refrigerant. GWP of 675. Mildly flammable (A2L). Common in new equipment from some manufacturers.
R-1234yf: Primary replacement refrigerant in automotive MVAC systems (covered by Section 609, not 608), but technicians encounter it in some commercial refrigeration applications.
What EPA 608 Type II Technicians Need to Know About A2L
The Type II section now includes A2L refrigerant content. Key tested facts: A2L classification means mildly flammable (not explosive); ventilation requirements differ from A1 refrigerants; ignition source management is required during service; A2L-specific leak detectors are recommended; equipment must be A2L-rated. A technician trained exclusively on R-410A systems needs to understand A2L safety differences before servicing new equipment.
New Leak Detection Requirements Under the AIM Act
The AIM Act's HFC Management Rule expanded leak repair obligations beyond the Section 608 framework in two ways:
1. Lower refrigerant charge threshold (2026): Mandatory leak detection now applies to systems with 15+ lbs of HFC refrigerant (down from 50 lbs). This catches medium commercial refrigeration, light commercial chillers, and larger light commercial HVAC units that were previously below the mandatory threshold.
2. Automatic leak detection systems: For larger equipment (specific thresholds apply by equipment type), the AIM Act requires automatic leak detection — not just periodic inspection. This is a new requirement that goes beyond Section 608's manual inspection framework.
Exam Note: Two Overlapping Frameworks
For EPA 608 exam purposes, the exam primarily tests Section 608 regulatory requirements (50-lb threshold for commercial refrigeration leak repair, 30-day repair window). AIM Act HFC Management Rule requirements are emerging exam content as certifying organizations update their question banks. Technicians sitting for the exam in 2026 and beyond should be aware of both frameworks.
AIM Act FAQ for EPA 608 Technicians
AIM Act HFC Phasedown Timeline
| Year | AIM Act Milestone | Refrigerant / System Affected |
|---|---|---|
| 2022 | AIM Act signed; HFC allowance system begins | All HFCs (phasedown schedule starts) |
| 2022–2023 | First HFC production/import reductions | High-GWP refrigerants including R-404A, R-507 |
| 2025 | Technology Transitions Rule effective; R-410A new equipment phaseout | New residential HVAC equipment |
| January 1, 2026 | HFC Management Rule: mandatory leak detection at 15+ lbs | All HFC appliances with 15 lbs or more of refrigerant |
| 2028 | Next reduction milestone | Further HFC production limits |
| 2036 | 85% phasedown target reached | All HFCs (full phasedown complete) |
EPA 608 Practice Questions
A) 25% B) 50% C) 85% D) 100%
A) 5 lbs or more B) 15 lbs or more C) 50 lbs or more D) 100 lbs or more
A) R-22 B) R-134a C) R-404A D) R-454B
A) Non-toxic, non-flammable B) Highly toxic C) Mildly flammable D) Highly flammable
A) R-410A was completely banned B) R-410A production for new residential HVAC equipment was phased down under the AIM Act Technology Transitions Rule C) R-410A was reclassified as an A2L refrigerant D) R-410A was grandfathered for all applications
A) American HVAC Infrastructure Modernization Act B) American Innovation and Manufacturing Act C) Air Infrastructure and Management Act D) Atmospheric Impact Mitigation Act
A) Section 609 B) Section 608 C) Section 112 D) Section 202
A) Higher GWP than R-410A B) The same GWP as R-410A C) Lower GWP than R-410A (675 vs 2,088) D) Zero GWP
Practice the Updated EPA 608 Type II Exam
The AIM Act's A2L transition is now tested on the EPA 608 Type II exam. Practice with updated questions covering A2L refrigerants, new leak detection thresholds, and the current R-410A phasedown.