As of January 1, 2026, several new EPA regulations under the American Innovation and Manufacturing (AIM) Act have gone into effect that directly impact commercial HVAC and refrigeration systems. If you own or manage a commercial building in Cleveland, Akron, Canton, Toledo, Youngstown, Wooster, or anywhere across Northeast Ohio, these changes affect how your equipment is maintained, monitored, and reported on.
At Air-Temp Mechanical, we've been tracking these regulatory changes closely and helping our clients prepare. Here's what you need to know heading into 2026.
The HFC Management Rule Is Now in Effect
The most significant change for commercial building owners is the HFC Management Rule, which took effect on January 1, 2026. This rule introduces mandatory leak detection and repair requirements for any refrigeration or HVAC system containing 15 or more pounds of HFC refrigerants with a global warming potential (GWP) greater than 53.
That 15-pound threshold is a major expansion from the previous ozone-depleting substance rules, which only applied to systems with 50 pounds or more. In practical terms, this means most commercial rooftop units, split systems, chillers, and refrigeration racks now fall under mandatory leak inspection requirements.
What This Means for Your Building
Regular leak inspections are now required — not optional. Systems must be checked according to EPA-defined schedules, and repairs must be completed within specified timeframes.
Documentation is mandatory. Every inspection, leak found, and repair performed must be recorded and retained.
Non-compliance carries penalties. The EPA has enforcement authority under the AIM Act, and fines for violations can be substantial.
Automatic Leak Detection for Large Systems
For larger commercial refrigeration and industrial process systems with a charge size of 1,500 pounds or more, the rule requires installation of automatic leak detection (ALD) systems. New systems meeting this threshold needed ALD installed by January 1, 2026. Existing systems have until January 1, 2027 to comply.
If you operate a cold storage facility, supermarket, or industrial plant in Northeast Ohio, this deadline is approaching fast. Planning the installation now avoids a last-minute scramble.
VRF Systems Face New GWP Limits
Variable refrigerant flow (VRF) systems — increasingly popular in commercial office buildings, hotels, and mixed-use developments — must now comply with a GWP limit of 700 or less for new installations as of January 1, 2026. This effectively rules out R-410A (GWP of 2,088) for new VRF equipment.
The industry has moved toward R-454B (GWP of 466) and R-32 (GWP of 675) as replacement refrigerants. Both are classified as A2L (mildly flammable) and are approved under updated ASHRAE 15 safety standards. Major manufacturers including Carrier, Trane, and Daikin are producing VRF equipment designed for these refrigerants.
For more background on the AIM Act phasedown schedule and how it impacts existing equipment, see our earlier guide: Understanding New EPA Refrigerant Regulations.
New Reporting Requirements Start This Year
Another change that catches many facility managers off guard is the new reporting requirement. Beginning with 2025 data, businesses covered by the HFC Management Rule must submit reports to the EPA by March 31, 2026, and annually thereafter.
This includes information on refrigerant types used, quantities purchased, leak rates, and repairs performed. If your maintenance provider hasn't been tracking this data, now is the time to get your records in order.
What Existing Equipment Owners Should Know
A common concern we hear from clients: "Do I need to rip out my R-410A equipment?"
The short answer is no. These regulations target new equipment manufacturing and installations, not existing systems. Your current R-410A rooftop units, split systems, and chillers can continue operating. However, there are practical considerations:
Refrigerant prices are rising. As HFC production quotas tighten under the AIM Act phasedown, R-410A and similar refrigerants will become more expensive. Budgeting for higher service costs is prudent.
Leak prevention is more important than ever. Every pound of refrigerant lost is harder and more expensive to replace. Proper preventative maintenance directly reduces your operating costs.
Plan replacements strategically. When existing equipment reaches end-of-life, the replacement will need to meet current GWP limits. Knowing this now helps you budget for capital expenses over the next 3–5 years.
How Air-Temp Mechanical Helps You Stay Compliant
We've been serving commercial and industrial facilities across Cleveland, Akron, Canton, Toledo, Youngstown, Wooster, Medina, Sandusky, and the greater Northeast Ohio region since 1978. Our team is fully trained on the latest EPA regulations and equipped to help you:
Conduct required leak inspections and maintain compliant documentation
Evaluate your refrigerant inventory and identify systems that fall under the new rules
Install automatic leak detection systems for large-capacity equipment
Recommend compliant replacement equipment when it's time to upgrade
Handle refrigerant recovery and reclamation using EPA-approved methods
Whether you're managing a single building or an entire portfolio of commercial properties, we provide the hands-on expertise to keep your systems running efficiently and within regulatory requirements.
Don't Wait for an Enforcement Notice
The EPA is actively enforcing the AIM Act provisions. The time to act is now — not after a failed inspection or a compliance inquiry. A proactive approach protects your business from penalties and positions you for long-term savings as the industry transitions to lower-GWP refrigerants.
Contact Air-Temp Mechanical today at (216) 579-1552 or reach out online to schedule a refrigerant compliance review. We'll assess your systems, identify what's required, and build a plan that works for your budget and timeline.
For the latest EPA guidance on HFC phasedown regulations, visit epa.gov/climate-hfcs-reduction.



