Refrigerant planning starts with knowing your equipment. There is no single January 2026 replacement deadline for every commercial building using R-410A.
EPA administers separate programs for bulk HFC supply, refrigerants used in new equipment, and refrigerant management. Which requirements apply depends on the system, refrigerant, charge size, and activity.
Reviewed September 10, 2026. Use EPA's current sector tables and HFC frequently asked questions to check the rules for a specific project.
Background: What Is the AIM Act?
The AIM Act phases down bulk HFC production and consumption through allowances. This is distinct from restrictions on refrigerants in particular new products and systems.
What the Transition Means for Your Building
New-equipment restrictions have category-specific dates and exceptions. They do not require immediate replacement of existing equipment. When considering a replacement, select equipment and refrigerant together; R-454B is not a universal requirement or a drop-in refrigerant for R-410A systems.
Check Refrigerant-Management Requirements Separately
- Identify the equipment category, refrigerant, and full charge size.
- Check which leak-repair and inspection provisions apply.
- Confirm applicable recordkeeping and reporting duties.
- Use the current EPA requirements, not a blanket deadline for all buildings.
Three Immediate Steps for Chicago Business Owners
Conduct a Full Equipment Audit
Document every HVAC and refrigeration unit: model, age, refrigerant type, and most recent service history.
Establish a Formal Refrigerant Tracking Log
Log every refrigerant addition: date, technician, amount, and reason. Required for many facilities.
Build a Multi-Year Replacement Roadmap
Prioritize equipment based on condition and operational risk. Verify any incentive eligibility for the specific project before including it in the budget.