New Refrigerant Rule Under the AIM Act
Driving the news: This rulemaking has two separate sets of regulations:
Why it matters: The new rule addresses the management of certain hydrofluorocarbons (HFCs) and has requirements that apply to owners/operators of equipment that contains common HFCs such as H-134A, R-404A, and R-410A.
- EPA is establishing an Emissions Reduction and Reclamation (ER&R) program for the management of HFCs and certain substitutes the AIM Act.
- EPA is amending a separate set of regulations promulgated under RCRA, a separate statutory authority from the AIM Act, to establish alternative standards for ignitable spent refrigerants when ‘‘recycled for reuse,’’ as the term is to be defined under RCRA. EPA is establishing that the alternative standards at 40 CFR part 266, subpart Q, under RCRA, apply to HFCs and other substitutes that are lower flammability.
Key compliance information:
- Leak Repair (compliance date of 1/1/2026): requirements will apply to refrigerant-containing appliances with a full charge of 15 lbs or more of a refrigerant that contains an HFC or substitute with a GWP above 53. This requirement will involve leak rate calculations (to be compared to leak rate thresholds), requirements to address leaks, appliance repair requirements, verification tests, etc. Facilities should be aware of recordkeeping requirements to be able to demonstrate compliance with these requirements.
- Automatic Leak Detection Systems (compliance date of 1/1/2026) applies to commercial and industrial process refrigeration appliances with a full charge size of 1,500 lbs. or more that contain an HFC or substitute with a GWP above 53.
Additional resources: There are additional requirements under the rule that relate to fire suppression systems; that relate to the reclamation and removal of HFCs; and that relate to those that service/repair or recycle/recover/reclaim HFCs. A fact sheet, including summary and the full rule can be found on the EPA’s website: https://www.epa.gov/climate-hfcs-reduction/regulatory-actions-managing-hfc-use-and-reuse For more information or assistance, please contact Chris Lampel (clampel@aegisenv.com).