American Innovation and Manufacturing (AIM) Act Compliance Guidance for Small Businesses
Last Update: March 2026
**Please refer to official Environmental Protection Agency (EPA) guidance to verify that applicable information on this website is up to date.**
The American Innovation and Manufacturing (AIM) Act is a federal law that guides the phasedown and management of hydrofluorocarbon (HFC) refrigerants, which have a negative impact on the environment. The act greatly affects businesses in the food industry, as well as businesses in other sectors that use refrigeration or HVAC equipment.
As of January 1, 2026, owners/operators of refrigerant-containing appliances with a full charge of 15 or more pounds of refrigerant, may be subject to AIM Act appliance management requirements. Requirements include keeping detailed records on appliances, properly monitoring and managing leaks, using only EPA-certified technicians, and creating plans for the retirement and retrofit of equipment. Businesses may also be required to submit reports to EPA.
In addition, businesses must plan for the eventual procurement and installation of new equipment that uses compliant refrigerants, instead of HFCs. Over the next few years, the purchase, sale, and installation of many HFC-containing equipment will be banned and HFC refrigerants themselves will become less available and more costly.
For a full look at the AIM Act’s requirements and how they may affect your business, read the AIM Act Compliance Guide for Small Businesses.
The EPA has a Frequently Asked Questions (FAQ) page about their Phasedown of Hydrofluorocarbons, which is a great place to begin familiarizing yourself with current refrigerant regulations and how they could affect you and your business – Frequent Questions on the Phasedown of Hydrofluorocarbons | US EPA.
Simple Compliance Checklist
- I have an inventory of all my appliances that contain AIM Act-regulated substances (see Table 1 and Section 2.1.1 of Guide).
- I know what records I must keep and have an organizational system in place (see Section 2.1 of Guide).
- I understand the AIM Act’s appliance service and maintenance requirements (see Section 2.2 of Guide)
- I have confirmed that my refrigerant technician is EPA 608-certified.
- I know what reports are required by EPA (see Section 2.3 of Guide).
- I have a plan for the retirement or retrofit of old or defunct appliances (see Section 2.2.4 of Guide).
- I have a plan for the procurement and installation of new compliant equipment (see Sections 3 and 4 of Guide).
See the Detailed Appliance Management Compliance Checklist for a more detailed guide to appliance management requirements under the AIM Act.
Appliance Management Templates, Forms, and Tools
| Appliance Inventory Record Template Individual Appliance Records Template, contains: -General Service and Maintenance Record -Leak Inspection Records -Verification Test Records -Purged Refrigerant Exclusion Record -Appliance Mothballing Record -Appliance Retrofit Plan Template -Appliance Retirement Plan Template Automatic Leak Detection System Record Template | Change of Leak Rate Calculation Method Record Template Chronically Leaking Appliance Report Template Request to Cease Retrofit or Retirement Plan Form Leak Repair Extension Request Form Retrofit & Retirement Plan Extension Request Form Leak Rate Calculator |
Additional Resources and Helpful Links
Contact Information
If you have any questions, please contact the Clean Air Branch using the following:
State of Hawaii
Clean Air Branch
2827 Waimano Home Road, #130
Pearl City, HI 96782
e-mail: [email protected]
Phone: (808) 586-4200 between 7:45 a.m. and 4:15 p.m.
Fax: (808) 586-4359