EPA AIM Act HFC Compliance: Refrigerant GWP Limits for US Imports (2026)

Q: What is the EPA AIM Act?

The American Innovation and Manufacturing Act of 2020 authorizes the EPA to phase down hydrofluorocarbons (HFCs). Its Technology Transitions Rule (40 CFR Part 84) restricts specific equipment categories from using high-GWP refrigerants.

Q: Can I still export equipment charged with R134a to the US?

Since January 1, 2026, chillers, cold therapy machines and industrial chillers (discharge temperature above -30°C) charged with R134a (GWP 1430) cannot be imported into the US because the GWP exceeds the 700 limit. AC and retail food refrigeration categories have been restricted since 2025.

Q: What refrigerant can replace R134a in my chiller?

Options meeting the 700 GWP chiller limit include R513A (GWP 631, non-flammable) and R450A (GWP 605, non-flammable). For very low GWP, consider R454C (146), R1234ze (7) or R290 propane (3). Note that R32/R454 series are A2L mildly flammable and R290 is A3 flammable — reassess safety design.

Q: How do EPA GWP limits relate to antidumping duties?

They are independent. The EPA AIM Act is an import ban — exceeding the GWP limit means the product cannot enter the US at all. Antidumping (e.g., case A-570-044 for R134a) is a trade remedy duty. Meet the EPA ban first, then confirm AD scope coverage.

Q: What did the May 2026 reconsideration change?

Three items: supermarket system GWP cap temporarily raised from 150/300 to 1,400 (reverting by 2032); semiconductor process cooling compliance extended to 2030; pre-charged equipment import allowance still under dispute. The chiller 700 limit is unchanged.

Q: What labeling is required for HFC equipment entering the US?

Products with GWP ≥ 53 must be labeled with the refrigerant chemical name, year of manufacture or date of first charge, and full refrigerant charge amount. Missing labels can trigger customs rejection.

Q: Where can I get help verifying my equipment compliance?

Contact Yinrui Logistics for end-to-end export compliance support: ocean freight, customs clearance, and tariff modeling. Visit our compliance center for the latest policy analysis.

1. What Is the AIM Act and Why It Matters Now

The American Innovation and Manufacturing Act of 2020 (AIM Act) authorizes the EPA to phase down hydrofluorocarbons (HFCs). Key implementing rules:

40 CFR Part 84 — Protection of Stratospheric Ozone: Phasedown of Hydrofluorocarbons
EPA Technology Transitions Rule (2023-10-24, 88 FR 73098)
EPA 2026 Reconsideration Rule (2026-05-26)

Three layers of control:

Layer	Scope	Who it applies to
① HFC Allowance Program	Production/import of bulk HFC	Bulk refrigerant importers, producers
② Technology Transitions	Equipment categories restricted from using high-GWP refrigerants	Equipment manufacturers & importers ← chillers, cold rooms, AC
③ Leak Repair & Management	Leak detection/repair for equipment with ≥15 lb HFC	Equipment users

Layer ② matters most to importers: it determines whether finished equipment charged with refrigerants such as R134a can enter the US at all.

2. Equipment Category × GWP Limit × Compliance Date (Quick Reference)

Refrigeration Equipment

Subcategory	Temperature Range	GWP Limit	Compliance Date (mfg/import)
Chiller ≥ -30°C (incl. cold therapy / ice bath machines)	Discharge ≥ -30°C	700	2026-01-01 ✅ in force
Chiller -50°C to -30°C	-50°C ≤ discharge < -30°C	700	2028-01-01
Chiller < -50°C	discharge < -50°C	No limit	N/A
Industrial refrigeration (non-chiller, ≥ -30°C, charge <200 lb)	Evaporator inlet ≥ -30°C	300	2026-01-01
Industrial refrigeration (non-chiller, ≥ -30°C, charge ≥200 lb)	Evaporator inlet ≥ -30°C	150	2026-01-01
Cold storage warehouse (charge <200 lb)	—	300	2026-01-01
Cold storage warehouse (charge ≥200 lb)	—	150	2026-01-01

Air Conditioning

Subcategory	GWP Limit	Compliance Date
Residential/light commercial split AC (central, mini-split)	700	2025-01-01 ✅
VRF systems	700	2026-01-01 ✅
Window / portable AC	700	2025-01-01 ✅
Data center cooling	700	2027-01-01

Retail Food Refrigeration

Subcategory	GWP Limit	Compliance Date
Standalone units	150	2025-01-01 ✅
Remote condensing (≥200 lb)	150	2026-01-01 ✅
Remote condensing (<200 lb)	300	2026-01-01 ✅
Supermarket systems	150/300	2026-01-01 (2026 reconsideration raises to 1400 until 2032)

Transport Refrigeration

Subcategory	GWP Limit	Compliance Date
Reefer truck / reefer container	Some refrigerants banned	2025-01-01

3. Refrigerant GWP Quick Reference: Does Yours Comply?

Refrigerant	GWP	Meets Chiller 700	Meets General 300	Flammability
R134a	1,430	❌	❌	A1 (non-flammable)
R410A	2,088	❌	❌	A1
R404A	3,943	❌	❌	A1
R407C	1,774	❌	❌	A1
R507	3,985	❌	❌	A1
R448A	1,273	❌	❌	A1
R449A	1,282	❌	❌	A1
R452A	2,140	❌	❌	A1
R32	675	✅	❌	A2L (mildly flammable)
R454B	466	✅	❌	A2L
R513A	631	✅	❌	A1
R450A	605	✅	❌	A1
R454C	146	✅	✅	A2L
R515B	293	✅	✅	A1
R290 (propane)	3	✅	✅	A3 (flammable)
R1234yf	4	✅	✅	A2L
R1234ze	7	✅	✅	A2L
CO2 (R744)	1	✅	✅	A1 (high pressure)
Ammonia (R717)	0	✅	✅	B2L (toxic)

4. Labeling Requirements (Easily Overlooked)

Any product or equipment containing HFCs (GWP ≥ 53) must be labeled with:

1. Chemical name of the refrigerant

2. Year of manufacture / date of first charge

3. Full refrigerant charge amount

5. 2026 Reconsideration: What Changed (IFR of 2026-05-26)

Item	Previous	New
Supermarket system temporary GWP cap	150/300	Raised to 1,400 (reverts by 2032)
Semiconductor process cooling delay	2026/2028	Extended to 2030
Pre-charged equipment import allowance	Not required	Under dispute, not enforced

⚠️ The chiller 700 GWP limit is NOT affected by this reconsideration — it remains in force since 2026-01-01.

6. Two Red Lines: EPA Ban + Antidumping

Equipment charged with R134a faces two separate risks when exporting to the US:

Risk	Nature	Severity
AD/CVD (case A-570-044; final admin review rate 167.02% for R134a)	Trade remedy	Scope-dependent, medium
EPA AIM Act GWP restriction	Hard regulatory ban	🔴 In force since 2026 — cannot import

Priority: The EPA AIM Act is a clearer, more urgent compliance red line than the AD scope dispute. Switch the refrigerant first; deal with tariffs second.

7. Action Checklist for Importers & Suppliers

1. Identify your equipment category: chiller / AC / retail food refrigeration / transport refrigeration?

2. Check refrigerant GWP: R134a (1430), R410A (2088), R404A (3943) — all exceed the limits.

3. Switch to compliant refrigerants: for chillers, R513A (631) or R450A (605); for low-GWP, R454C (146), R1234ze (7), R290 (3) — note flammability class changes (A2L/A3 may require redesign).

4. Add labels: GWP ≥ 53 requires chemical name, manufacture date, and charge amount.

5. Re-verify AD scope: after switching refrigerants, confirm whether the finished product is covered by the antidumping order.

8. FAQ

What is the EPA AIM Act?

The American Innovation and Manufacturing Act of 2020 authorizes the EPA to phase down hydrofluorocarbons (HFCs). Its Technology Transitions Rule (40 CFR Part 84) restricts specific equipment categories from using high-GWP refrigerants.

Can I still export equipment charged with R134a to the US?

Since January 1, 2026, chillers, cold therapy machines and industrial chillers (discharge temperature above -30°C) charged with R134a (GWP 1430) cannot be imported into the US because the GWP exceeds the 700 limit. AC and retail food refrigeration categories have been restricted since 2025.

What refrigerant can replace R134a in my chiller?

Options meeting the 700 GWP chiller limit include R513A (GWP 631, non-flammable) and R450A (GWP 605, non-flammable). For very low GWP, consider R454C (146), R1234ze (7) or R290 propane (3). Note that R32/R454 series are A2L mildly flammable and R290 is A3 flammable — reassess safety design.

How do EPA GWP limits relate to antidumping duties?

They are independent. The EPA AIM Act is an import ban — exceeding the GWP limit means the product cannot enter the US at all. Antidumping (e.g., case A-570-044 for R134a) is a trade remedy duty. Meet the EPA ban first, then confirm AD scope coverage.

What did the May 2026 reconsideration change?

Three items: supermarket system GWP cap temporarily raised from 150/300 to 1,400 (reverting by 2032); semiconductor process cooling compliance extended to 2030; pre-charged equipment import allowance still under dispute. The chiller 700 limit is unchanged.

What labeling is required for HFC equipment entering the US?