The AIM Act and What It Means For The Industry

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A major change is coming to the world of industrial refrigeration, and the clock is ticking. A federal regulation called the American Innovation and Manufacturing (AIM) Act is phasing out a common class of refrigerants known as hydrofluorocarbons (HFCs). For any business that relies on large-scale refrigeration, from cold storage warehouses to food processing plants, this is a quickly approaching deadline with significant operational and financial implications.

The AIM Act is designed to reduce the production and use of HFCs by 85% by the year 2036. The most important date for facility managers to have on their calendars is January 1, 2026. After this date, new industrial refrigeration systems will be prohibited from using refrigerants with a high Global Warming Potential (GWP), a measure of a substance's climate impact. For context, a common legacy refrigerant like R-404A has a GWP of over 3,900. The new rules will limit large systems to refrigerants with a GWP of 150 or less, and smaller systems to a GWP of 300 or less. This effectively makes traditional HFCs obsolete for new installations.

It's also important to understand that the law defines a "new installation" to include major retrofits. If you replace most of the key components of an existing system, it will have to comply with the new, stricter limits. This prevents facilities from simply swapping out parts to delay a full upgrade. With long lead times for designing and building new systems, the time to start planning for this transition is now.

The good news is that there are proven, sustainable alternatives.

The industry is shifting back to natural refrigerants like carbon dioxide (CO2) and hydrocarbons (like propane). CO2 is an excellent choice for large-scale systems. It has a GWP of just 1 and is non-toxic and non-flammable. Modern CO2 systems are also very energy-efficient and can even capture waste heat to be used for other facility needs, like heating water. The main engineering challenge with CO2 is that it operates at very high pressures, which requires specialized components and piping. Propane is another efficient option, but it is flammable. This means systems using propane have strict limits on how much refrigerant they can hold and require careful design to ensure safety.

To prepare for the 2026 deadline, facilities should start by auditing their current refrigeration assets to identify which systems use high-GWP refrigerants. This information can then be integrated into long-term capital planning. Given the technical shift, engaging with an expert partner like NWR  early in the process is key to approaching this change in regulation and ensuring a smooth, cost-effective transition.

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