The Refrigerant Phasedown Is Here. Are You Ready?
By a HVAC and building systems industry contributor.
The cooling system in your commercial building might seem simple. It works, you maintain it, and you budget to replace it someday. But a quiet change in the law is turning that predictable part of your building into a possible problem. The common coolants that power most of today’s air conditioners, known as hydrofluorocarbons (HFCs), are being removed from the market on purpose.
This change isn’t years away; it is happening now. The switch is required by a federal law designed to stop the use of chemicals that are bad for the climate. This phasedown, which targets hydrofluorocarbons (HFCs), is detailed in guidance from the EPA. Understanding the details of the AIM Act is now a key job for anyone who manages a building. If you don’t plan for this change, you could face expensive emergency repairs, problems with the law, and long shutdowns when old systems break and their main parts are no longer available.
Quick answer: The AIM Act is getting rid of common coolants like R-410A used in most building air conditioners. This means repairs on older units will get harder and cost more. New systems will use different, better coolants, so planning for this change now is important to avoid expensive surprises.
What’s inside
- What Is the AIM Act and Why Does It Matter Now?
- How Does This Affect My Existing HVAC Equipment?
- What Are the New Refrigerant Options?
- Frequently Asked Questions About Refrigerant Changes
- The Bottom Line: From Reactive Repair to Strategic Replacement
What Is the AIM Act and Why Does It Matter Now?
This federal law matters because it cuts back on how much of these common HFC coolants can be made. This makes them harder to find and more expensive to use when servicing your current HVAC equipment.
The American Innovation and Manufacturing (AIM) Act doesn’t ban your current air conditioning system. Instead, it sets a limit on how much of these high-GWP HFCs can be made or brought into the country. This phasedown of HFCs is a key component of the act, as outlined by the CRS. That limit gets tighter every few years on a set schedule. Think of it as turning down a faucet. This is done on purpose to squeeze the supply, making it harder to keep using the old coolants over time.
This planned shortage has direct effects on your budget. As the supply of old coolants shrinks, the cost to refill your system after a leak will go up. A small leak used to be a simple, cheap fix. Soon, it could be a major expense. A big system failure could force a tough choice: pay a high price for a coolant that’s disappearing to fix an old unit, or do an expensive and unplanned emergency replacement.
❝ The biggest risk isn’t a fine from the government; it’s the risk to your business when a critical system fails and the coolant needed to fix it is either not available or too expensive. A repair could take weeks instead of days while you wait for the material or a new unit.
The main goal of the law is to speed up the switch to newer, better cooling systems. These new systems use coolants that have a much smaller impact on the climate. For facility managers, this means the discussion is no longer just about repair versus replace. It’s about making a smart plan to move your building away from technology that is being removed from the market on purpose. Waiting for a unit to break is no longer a good plan.
How Does This Affect My Existing HVAC Equipment?
It makes repairs cost more and get more complicated over time. Eventually, it will force you to replace your system with a new one designed for modern coolants.
Your current equipment is not being banned, but it won’t be a good option for much longer. The biggest issue is that new, lower-GWP coolants are not “drop-in” replacements for the HFCs in your current units. Their chemical properties are different. A system designed for R-410A runs at certain pressures and uses a special type of oil. A new coolant might need different pressures or not work with that oil, which could break the main compressor. You cannot simply top off an old system with a new chemical.
This problem directly affects your budget every time you need a repair. As the AIM Act limits the supply of new HFCs, the cost to fix a leak and refill the system will keep going up because of simple supply and demand. What used to be a small repair cost can become a major expense. A large leak could easily make a repair more expensive than a down payment on a new, compliant system. This changes how you should think about the cost of keeping old equipment.
❝ The question to ask your team is no longer just “How old is this unit?” It is now “How much are we willing to invest in technology with a supply chain that’s shrinking on purpose?” Every major repair is now a strategic decision about the future.
When you do need service, ask your HVAC provider if they use reclaimed refrigerant. This is older HFC coolant that has been recovered from other systems, cleaned to meet quality standards, and resold. While this can be a good way to save money, the supply of this recycled coolant is limited. It’s a temporary fix, not a long-term answer. Also, many of the new replacement coolants are classified as A2L, which means they are mildly flammable. Technicians need special training and tools to handle them safely, and building codes are being updated to include new safety rules for their use.
What Are the New Refrigerant Options?
The main replacements are coolants with an A2L safety rating, like R-32 and R-454B. They are much better for the climate but can’t be used in your old equipment.
For years, R-410A was the standard. It is a coolant that doesn’t catch fire and isn’t very toxic, so it’s called an A1 coolant. The new chemicals have a lower GWP (Global Warming Potential) because they use molecules that break down faster in the air. This chemical change, however, also makes them “mildly flammable,” putting them in the A2L safety group. This does not mean they are explosive or easy to light like propane (an A3 refrigerant). A2L coolants are hard to light on fire and burn very slowly.
The switch to A2L systems involves more than just a different chemical. It needs new equipment that is built just for these coolants. Key parts of the system, like compressors and sensors, are different. Safety rules and building codes have been updated for these new systems. For example, they now require built-in sensors that can detect a leak, shut the system down, and sound an alarm.
❝ The most important thing to understand is that this is a complete platform change, not just a new fluid. Technicians need different tools, recovery machines, and training to handle A2L refrigerants safely. When you hire a contractor, ask them if their team is trained and certified to work with A2L coolants.
This change gives building owners a clear choice. You cannot “retrofit” an old R-410A unit to use R-32 or R-454B. When a major part on an older system fails, you will have to replace the whole system, both the inside and outside units, with a new one made for the A2L standard. This makes planning ahead for the cost of new HVAC equipment more important than ever.
| Refrigerant | Safety Class | Global Warming Potential (GWP) | Compatible with Old Systems? |
| R-410A | A1 | High | N/A (Baseline) |
| R-32 | A2L | Low | No |
| R-454B | A2L | Low | No |
Understanding this table is key. The switch away from the high-GWP R-410A is final. The new A2L options are much better for the environment but require a full system replacement. This marks a new era in cooling technology and how it’s maintained.
Frequently Asked Questions About Refrigerant Changes
Is the AIM Act still in effect?
Yes, the AIM Act is a long-term government program. It’s not a single event but a series of planned cuts over many years in HFC production. The supply of old coolants will keep getting smaller according to the EPA’s official timeline, which goes on for more than a decade.
Can I still have new R-410A equipment installed?
The answer depends on when the equipment was built. After January 1, 2025, companies can no longer make or import new air conditioners that use high-GWP coolants like R-410A. A contractor can still install a unit they already have in stock after that date, but they won’t be able to get more. The best plan is to use the new A2L systems for any new projects.
What are the key regulatory changes for 2025 and 2026?
The biggest change is the 2025 cutoff for making most new comfort cooling systems that use high-GWP coolants. By 2026, similar rules will apply to other types of equipment, like variable refrigerant flow (VRF) systems. The rule sets a 750 Global Warming Potential (GWP) limit for most new air conditioners. This basically requires the switch to the new types of coolants.
Will I be forced to replace my working HVAC system?
No, the rules do not force you to remove working equipment. You can keep using and servicing your current system. The reason to upgrade is about money, not breaking the law. As the supply of the old coolants shrinks, the cost to fix leaks will go up. This makes a planned replacement a smarter financial choice than an expensive emergency repair.
How does this impact my building’s maintenance budget?
You should expect costs to go up and change more often for servicing any equipment that uses older HFCs. Adding more coolant is no longer a small expense. The best practice is to change from a budget for surprise repairs to a long-term plan for upgrades. This lets you replace the oldest or most important units first. It turns a possible emergency into a planned and predictable project.
The Bottom Line: From Reactive Repair to Strategic Replacement
The refrigerant transition driven by the AIM Act is a major change in how building owners need to manage their HVAC systems. This is not just a technical change for repair crews; it’s a key moment for your budget and strategy. The law doesn’t make you replace working equipment, but the financial effects of the phasedown create a strong reason to do it. The market, through rising service costs and shrinking supply, will make the decision for you if you do not make it yourself.
The main choice you have to make has changed. It is no longer a simple comparison of one repair cost versus the price of a new unit. Instead, the decision is about the total cost of continuing to invest in a technology with a future that is limited on purpose. Every major repair on an older HFC system is now spending money on equipment that is becoming obsolete and riskier to operate.
Ultimately, these new rules mean you can’t just wait for things to break anymore. The best strategy is to create a long-term plan to upgrade your HVAC systems. By finding and scheduling the replacement of your oldest or most critical units, you can turn a surprise crisis into a planned project that fits your budget. In this new environment, waiting for equipment to fail is no longer a good plan; it is a major financial risk.
About the author
This article is contributed by the technical team at Thrivaire, a commercial HVAC services company based in Denver, Colorado. The firm specializes in the maintenance, repair, replacement, and construction of HVAC systems for commercial, industrial, and mission-critical environments. Their work focuses on helping facility managers and building owners navigate complex equipment lifecycles, from system optimization and air balancing to long-term capital planning for regulatory transitions like the HFC phasedown.