Thanks to ACCA’s persistent advocacy efforts, the Environmental Protection Agency’s latest rule under the AIM Act will allow more flexibility for contractors. There’s no doubt that the AIM Act and its regulations to phase down hydrofluorocarbons (HFCs) will impose unwanted costs and regulatory burdens on contractors, but we are pleased that EPA’s final rule on HFC management includes several significant changes that reflect our members’ needs.
Thanks in part to ACCA’s comments on the proposed rule and subsequent meetings with federal officials, our industry secured significant victories in three key areas. As a result, the implications for residential and light commercial contractors are very limited, and burdens impacting other market segments have been reduced.
No mandate for reclaimed HFCs in initial charges
One of ACCA’s top priorities was ensuring that EPA did not mandate the use of reclaimed HFCs for the initial charge of refrigerant-containing equipment. ACCA argued that this would place undue burdens on contractors due to potential limitations in reclaimed refrigerant availability that could drive prices through the roof. The EPA listened, and the final rule does not require reclaimed HFCs for initial charges.
Additionally, EPA narrowed the reclaimed HFC requirement for servicing existing equipment, aligning it with supermarket systems, refrigerated transport, and automatic commercial ice makers—slightly reducing the scope by excluding standalone commercial food refrigeration.
EPA also committed to monitoring the availability of reclaimed HFCs and promised that any future mandates for reclaimed HFC use will be based on available supply. This is a direct reflection of ACCA’s recommendation, ensuring that contractors are not forced to comply with regulations that are impractical due to market constraints.
Flexible disposable cylinder return
The proposed rule required that all disposable cylinders be returned to certified reclaimers for processing, which would have placed additional logistical and cost burdens on contractors. ACCA pushed for a more practical solution, and EPA introduced a DIY evacuation option.
Under the final rule, certified technicians can now evacuate disposable cylinders themselves, and then dispose of the cylinders to a final processor (such as a landfill operator or scrap metal recycler) without needing to return them to certified reclaimers for further processing. This flexibility is a major win for contractors, offering a cost-effective and time-saving alternative while still ensuring environmental compliance. It should also be noted that the cylinder disposal rules do not go into effect until 2028.
No QR code tracking system
ACCA also successfully opposed the inclusion of a QR code tracking system for refrigerant cylinders, which would have imposed unnecessary administrative complexity on contractors. The final rule does not include this tracking system, meaning contractors will avoid cumbersome and invasive reporting requirements that would have added time and cost to daily operations. This victory helps maintain a practical, streamlined workflow for HVACR professionals without additional regulatory burdens. This is the second time that ACCA has opposed and helped defeat the QR tracking requirement.
Continued advocacy to mitigate AIM Act impacts on contractors
The ACCA HVAC Blog previously covered two other significant rules under the 2020 AIM Act:
The 2021 rule phasing down production of HFCs
The 2023 technology transition rule, which we successfully amended to allow a sell-through period for R-410a equipment
This week’s final rule on refrigerant management is just the latest step in this regulatory odyssey, and ACCA has been there fighting for contractors every step of the way.
One element not addressed in EPA’s rollout is the technician training and certification requirements on which EPA sought advance comment in conjunction with this rulemaking. As detailed in ACCA’s comments, we remain committed to common sense training and certification requirements for technicians servicing equipment using ASHRAE A2, A2L and A3 flammable refrigerants, as well as modernization of the section 608 certification program. We will continue fighting for these reforms in the months ahead.
These wins are a testament to ACCA’s commitment to protecting the interests of HVACR contractors, ensuring that the regulations we face are reasonable, achievable, and based on real-world conditions. By engaging with EPA, ACCA has won flexibility for contractors to focus on delivering quality service to their customers without facing unnecessary hurdles.
For more details on how these changes will affect your business, contact ACCA’s policy team at govt@acca.org. We are here to keep you informed and prepared as the regulatory landscape evolves.
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