The American Innovation and Manufacturing (AIM) Act directs the EPA to sharply phase down hydrofluorocarbon (HFC) refrigerants. That rulemaking is already changing what refrigerants and equipment manufacturers can produce and what installers can put in the field. By 2026 commercial HVAC teams will be deep in the transition — more low-GWP refrigerants (A2Ls and others), shifting equipment availability, new sector restrictions, and stronger emphasis on reclamation, training, and safety. Here’s what you need to know and the concrete steps to take this year.
Quick background: what the AIM Act requires
The AIM Act (enacted December 2020) gives the EPA authority to phase down HFC production and consumption in the U.S. through an allowance/trading program and to set sector-specific restrictions and reporting requirements. The overall goal is an 85% reduction from baseline levels by 2036 (i.e., reaching about 15% of baseline). That phasedown drives both supply constraints for legacy HFCs and regulatory limits on which refrigerants can be used in newly manufactured equipment. US EPA+1
What’s changing by 2026
- Lower-GWP requirements for many new commercial products are already in force — and 2026 is a key compliance year. EPA rules implementing the AIM Act included sector-based “technology transition” restrictions. Some product categories were subject to 2025 compliance dates, while several commercial subsectors (notably multi-zone VRF, certain rooftop and split systems and other commercial equipment) have compliance windows that place important restrictions on manufacturers and installers into 2026. That means many manufacturers stopped shipping new equipment designed for high-GWP HFCs and shifted to lower-GWP blends or A2L refrigerants. US EPA+1
- R-410A new equipment manufacturing and installation timeline. Manufacturers were required to stop producing many types of R-410A equipment after 2024/2025, and installers should not expect unlimited availability of new R-410A systems after 2025 — with installations of some legacy equipment effectively expected to end by January 1, 2026 in practice. Service parts for existing systems are still permitted, but full-system replacements and new multi-zone systems must comply with the GWP thresholds. (This has been widely communicated by major manufacturers and industry guidance.) Johnson Controls+1
- GWP thresholds and product categories matter. The EPA’s approach uses both an HFC allowance market (reducing supply) and specific GWP limits for equipment categories (the “technology transitions” restrictions). Different categories (e.g., chillers, VRF, refrigerated warehouses, industrial process refrigeration) have different thresholds and dates — so the exact impact depends on the equipment type. US EPA+1
- Legal/regulatory direction is stable but evolving. Courts have largely upheld the EPA’s AIM Act rules, which strengthens the regulatory certainty for the phasedown. The agency has also been refining and, at times, reconsidering specific regulatory requirements — meaning rule text and compliance dates can see updates. Stay current. Reuters+1
What this means for commercial HVAC owners and contractors in 2026
- Equipment selection: New commercial HVAC purchases increasingly will specify low-GWP refrigerants (A2L refrigerants, R-454B, R-1234ze in some chillers, or natural refrigerants where applicable). Expect more A2L-charged equipment in rooftop, VRF and split systems.
- Installation practice & codes: A2Ls (mildly flammable refrigerants) change installation and safety requirements. Code updates and manufacturer guidance require updated ventilation, leak-detection, and charge-limit considerations. Technicians must be trained and certified to handle A2Ls safely
- Service & repair: Legacy systems remain serviceable, but refrigerant supplies will tighten and become more expensive over time. Reclaimed refrigerant, reduced venting, and leak prevention become financially and operationally important.
- Procurement & inventory: Manufacturers may limit production of high-GWP refrigerants and equipment. Plan purchases sooner rather than later for projects that require legacy refrigerants, or better, redesign specs to accept low-GWP alternatives.
Practical checklist for contractors and facility managers
- Audit your portfolio — list all systems by refrigerant type, charge size, age, and criticality. Prioritize high-risk or high-leak systems for replacement or retrofits.
- Start (or update) a refrigerant transition plan — include timelines, budgets, and equipment options that use low-GWP refrigerants. Factor in potential supply and allowance impacts.
- Train staff on A2L safety and code changes — ensure technicians have A2L handling training, and that your procedures and PPE are updated. Confirm local building code acceptance of A2L installations.
- Lock in supply and parts — for critical legacy systems you must keep running, secure service parts and reclaimed refrigerant now; evaluate OEM and aftermarket options. Johnson Controls
- Update contract language and warranties — add clauses covering refrigerant availability, refrigerant substitution, and long-term service strategies.
- Emphasize leak detection and preventative maintenance — smaller leak rates and faster repair extend equipment life and reduce need for new refrigerant allotments.
- Talk to manufacturers and AHJs — coordinate with OEM reps and your authority having jurisdiction (AHJ) early on equipment specs and code compliance. Industry groups (e.g., AHRI) are actively engaging on implementation details. AHRI
Cost & incentives — what to expect
- Upfront cost vs lifecycle savings: Low-GWP systems (and retrofits) may carry higher upfront cost or require new components, but can deliver lifecycle savings through higher efficiency, lower refrigerant expense, or lower regulatory risk.
- Incentives: State or utility incentives for low-GWP equipment, energy efficiency, or electrification projects may be available. Check local programs.
- Reclaimed refrigerant market: As production of certain HFCs is curtailed, reclaimed refrigerant will be more valuable — factor reclamation into service economics. US EPA
Final thoughts
2026 is not an abrupt cutoff so much as a ramped, enforced shift: supply reductions, equipment GWP limits, and technology-specific dates will combine to make low-GWP refrigerants the norm for new commercial HVAC equipment. That creates risk for teams who wait and opportunity for those who plan: safer, future-proof specifications, technician upskilling, leak control, and proactive procurement will keep systems reliable and costs manageable.
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