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REGULATORY TIMELINE

AIM Act Timeline 2022–2036 - What Happens When

The complete AIM Act phase-down schedule, year by year, and what each step means for refrigerant supply and pricing.

February 3, 20264 min read
AIM Act Timeline 2022–2036 - What Happens When

The American Innovation and Manufacturing Act became law in December 2020 and gave EPA authority to phase down HFC production and consumption in the US by 85% over 15 years. Here's the year-by-year schedule and what each step has meant - or will mean - for the market.

The caps (% of baseline)

  • 2020: baseline (average of 2011–2013 production + consumption)
  • 2022–2023: 90% - minor squeeze, most contractors didn't feel it
  • 2024–2028: 60% - first real supply squeeze; R-410A prices begin climbing sharply
  • 2029–2033: 30% - steepest step; expect R-410A shortage windows to become routine
  • 2034–2035: 20%
  • 2036 onward: 15% - effectively an 85% reduction from baseline

Technology transitions (SNAP)

Separately from the cap, EPA's SNAP program restricts which refrigerants can be used in new equipment by application. Key dates:

  • January 1, 2025: new R-410A residential split systems may no longer be manufactured
  • January 1, 2025: many commercial refrigeration categories prohibit R-404A in new installs
  • Ongoing: rolling restrictions by equipment category

Servicing is separate

Important distinction: SNAP and AIM Act restrict NEW equipment manufacturing. Servicing existing installed equipment with existing refrigerant (including virgin stock and reclaimed product) remains legal through the full phase-down period for EPA 608 certified techs.

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