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AIM Act Refrigerant Compliance: A Boston Business Owner’s Guide to 2025 Requirements

If you own a restaurant, grocery store, or any business relying on commercial refrigeration in the Greater Boston area, you’ve likely heard about the AIM Act. But what does it really mean for your operations? The American Innovation and Manufacturing (AIM) Act represents one of the most significant shifts in refrigeration technology in decades—and compliance isn’t optional.

The EPA has mandated a phasedown of hydrofluorocarbon (HFC) refrigerants, starting immediately in 2025. For Massachusetts business owners, this means new equipment requirements, potential cost implications, and urgent decisions about your current systems. Royal Cooling specializes in helping Cambridge and Boston-area businesses navigate this transition smoothly.

Let’s break down what you need to know about AIM Act refrigerant compliance in Boston and how it affects your bottom line.

Understanding the AIM Act and HFC Phasedown

Congress passed the American Innovation and Manufacturing Act in December 2020 with a clear mandate: phase out hydrofluorocarbon refrigerants that contribute significantly to climate change.[1] HFCs are potent greenhouse gases with high Global Warming Potential (GWP), making them far more damaging to the environment than carbon dioxide.

The EPA’s response has been aggressive. The agency established the HFC phasedown commercial refrigeration schedule through three core regulatory pillars:[6]

1. HFC Allowance Allocation Rule – Controls production and import quotas. Producers must reduce HFC manufacturing by 10% initially, with steeper cuts reaching 60% of baseline by 2026.

2. Technology Transitions Rule – Sets Global Warming Potential (GWP) limits for new equipment. Most new HVAC systems must have a GWP of 700 or less as of January 1, 2025.[3] This immediately eliminates R-410A—the industry standard for decades—from new equipment.

3. HFC Management Rule – Beginning in 2026, end-users must comply with leak detection, repair, and refrigerant management requirements.[6]

For Boston-area businesses, this isn’t theoretical. These rules are in effect now.

What Changed in 2025: The Low-GWP Refrigerant Transition

The low-GWP refrigerant transition Massachusetts businesses are experiencing centers on replacing older refrigerants with environmentally friendly alternatives. Here’s what’s happening:

R-410A Phase-Out

R-410A has been the workhorse of commercial refrigeration for years. As of January 1, 2025, new equipment can no longer use R-410A.[3] The rule sets a GWP limit of 700 or less for most new HVAC systems, and R-410A exceeds this threshold significantly.

What this means: If your current system uses R-410A, you can continue operating it. However, as the EPA restricts production, R-410A will become scarce and expensive for future servicing. Eventually, you’ll face a choice—repair with costly refrigerant or upgrade to compliant equipment.

New Refrigerant Alternatives

The EPA’s SNAP Program (Significant New Alternatives Policy) has approved several lower-GWP refrigerants as acceptable replacements:[1]

R-454B and R-32 – These are the primary replacements for R-410A in new residential and light commercial systems. They offer improved performance and better energy efficiency compared to older refrigerants.[2]

A2L Refrigerants – The EPA finalized SNAP Rule 25 in April 2023, approving seven new low-GWP refrigerants for some comfort cooling and refrigeration equipment, subject to use conditions and safety protocols.[1]

Natural Refrigerants – The IIAR has advocated for systems using natural refrigerants, which have minimal environmental impact and align with stricter state regulations.[1]

For commercial refrigeration in Cambridge and Boston, your equipment manufacturer has already begun transitioning to these alternatives. When you purchase new equipment or upgrade your system, it will use one of these compliant refrigerants.

Refrigerant Compliance Requirements 2025: What Boston Businesses Must Do Now

Compliance isn’t just about new equipment. Here are the immediate refrigerant compliance requirements 2025 that affect your business:

Immediate Actions (January 2025 Onward)

Assess Your Current Equipment – Inventory all refrigeration systems. Identify which use R-410A or other high-GWP refrigerants. Document refrigerant charges and system age.

Plan Equipment Upgrades – If your systems are aging or approaching end-of-life, prioritize replacement with EPA-compliant equipment now. Delaying increases costs as R-410A becomes scarcer.

Review Your Service Contracts – Ensure your refrigeration service provider (like Royal Cooling) understands the new regulations and can service your existing equipment with compliant refrigerants when needed.

Compliance by 2026

Starting January 1, 2026, the HFC Management Rule takes effect. Your business must implement:[6]

Refrigerant Leak Detection Programs – Regular monitoring and documentation of refrigerant leaks. For systems with 50+ pounds of refrigerant, leak detection becomes mandatory.

Repair and Maintenance Records – Detailed logs of all refrigeration service, repairs, and refrigerant handling. The EPA may audit these records.

Proper Refrigerant Reclamation – When servicing equipment, refrigerants must be properly recovered and reclaimed, not vented to the atmosphere.

Royal Cooling’s commercial refrigeration compliance services help Boston businesses meet these requirements without disruption.

Special Considerations for Different Equipment Types

The EPA’s Technology Transitions Rule isn’t one-size-fits-all. Different commercial refrigeration systems face different compliance timelines:

Remote Condensing Units and Supermarket Systems

The EPA recently proposed modifications to address supply chain concerns. Under the revised proposal, remote condensing units and supermarket systems follow a phased approach:[4]

– Interim GWP Cap: 1,400 beginning January 1, 2026 (remote units) and January 1, 2027 (supermarket systems)

– Final Limit: 150 or 300 (depending on charge size) by January 1, 2032

This phased approach gives larger facilities more time to transition while still meeting climate goals.

Cold Storage and Industrial Refrigeration

Facilities with large refrigerant charges face extended timelines but must still plan transitions. Consult with Royal Cooling’s team to understand your specific equipment category and compliance deadlines.

State-Level Regulations: Massachusetts Goes Further

While the AIM Act sets federal minimums, some states—including Massachusetts’ neighbor New York—are implementing stri