The EPA’s AIM Act now requires leak detection and repair for any commercial system containing 15 pounds or more of HFC refrigerant, down from the previous 50-pound threshold. As of January 1, 2026, thousands of Michigan commercial buildings that were previously exempt now fall under mandatory compliance. Violations carry penalties up to $60,000 per day. Samco Facilities Maintenance helps commercial property owners across Southeast Michigan meet these new requirements. Call (734) 838-6300 for a compliance assessment.
Why the 2026 Refrigerant Rules Matter for Michigan Businesses
If you own or manage a commercial building in Wayne County, Oakland County, Macomb County, or Washtenaw County, this regulation change directly affects you. The AIM Act Subsection (h) enforcement expansion means that rooftop HVAC units, walk-in coolers, walk-in freezers, chillers, and refrigerated display cases in restaurants, grocery stores, healthcare facilities, manufacturing plants, and office buildings across Southeast Michigan now require documented leak inspection programs.
Before January 2026, only large commercial systems with 50 or more pounds of HFC refrigerant triggered federal compliance requirements. The new 15-pound threshold sweeps in the majority of mid-size commercial equipment, including the systems found in most Michigan businesses. Building owners who assumed they were exempt need to reassess immediately.
What Changed Under AIM Act Subsection (h)
The EPA finalized the Technology Transitions Rule under the American Innovation and Manufacturing (AIM) Act, and the January 1, 2026 enforcement date brought several major changes.
The threshold dropped from 50 lbs to 15 lbs. Any commercial refrigeration or HVAC system containing 15 pounds or more of HFC refrigerant now requires a formal leak inspection and repair program. Most commercial rooftop units, split systems, and walk-in coolers fall into this range.
Leak repair timelines are strict. Once a leak is identified, building owners have 14 days to complete repairs. If the system contains a charge of 1,500 pounds or more, real-time automated leak detection technology must be installed.
Penalties are steep. The EPA can assess fines of up to $60,000 per violation per day for non-compliance. This includes failure to conduct required inspections, failure to repair identified leaks within the mandated window, and failure to maintain proper documentation.
R-410A equipment is phasing out. As of January 1, 2026, manufacturers can no longer produce or import new R-410A variable refrigerant flow (VRF) systems. Replacement equipment using next-generation refrigerants costs 15 to 25 percent more, making proper maintenance of existing systems more important than ever.
The Michigan Angle: What Makes This Different Here
Michigan’s climate creates specific refrigerant compliance challenges. The freeze-thaw cycles common across Livonia, Dearborn, Detroit, Ann Arbor, Warren, Troy, Pontiac, and Sterling Heights stress refrigerant lines and fittings throughout the winter months. Thermal expansion and contraction accelerate micro-leaks in copper tubing and brazed joints, exactly the type of slow leaks the AIM Act now requires building owners to detect and repair.
Michigan is also adopting updated commercial energy codes based on IECC 2021 and ASHRAE 90.1-2019, which add commissioning and functional performance testing requirements for commercial HVAC systems. Building owners in Southeast Michigan face a convergence of federal refrigerant regulations and state energy code updates at the same time.
On top of that, Michigan’s commercial natural gas rates spiked across all three major providers (DTE Energy, Consumers Energy, and SEMCO Energy) effective January 2026. Leaking refrigerant forces systems to work harder, driving energy costs even higher during a winter when bills are already up.
7 Steps to Get Your Building AIM Act Compliant
- Inventory your systems. Identify every piece of HVAC and refrigeration equipment in your building. Document the refrigerant type and charge weight for each unit. Any system with 15+ lbs of HFC refrigerant falls under the new rules.
- Schedule a professional leak inspection. A certified technician should perform a thorough leak check using electronic detection equipment. This is not something facility staff should attempt with basic tools.
- Repair leaks within 14 days. If a leak is found, you have a strict two-week window to complete repairs. Document the date of detection, repair date, and verification test results.
- Install automated leak detection where required. Systems with a total charge of 1,500 lbs or more must have real-time monitoring installed. Some mid-size facilities with multiple connected systems may hit this threshold.
- Establish a recurring inspection schedule. The AIM Act requires ongoing leak monitoring, not a one-time check. Set up quarterly or semi-annual inspections depending on system size and type.
- Maintain compliance documentation. Keep records of every inspection, leak detected, repair performed, and refrigerant added. EPA auditors will request this documentation.
- Evaluate your refrigerant transition plan. With R-410A equipment no longer being manufactured, plan ahead for system replacements. A proactive transition strategy avoids emergency purchases at premium prices.
How Samco Handles AIM Act Compliance
At Samco Facilities Maintenance, we have been servicing commercial HVAC systems and refrigeration equipment across Southeast Michigan since 1997. Our team of 25+ technicians holds EPA 608 Universal Certification, the credential required to handle regulated refrigerants under the AIM Act.
We provide compliance assessments that include full system inventory, refrigerant charge documentation, electronic leak detection, and a written compliance plan tailored to your building. Our preventive maintenance programs include scheduled leak inspections that satisfy AIM Act requirements and keep your systems running efficiently.
Whether you manage a restaurant in Dearborn, a medical facility in Troy, or a warehouse in Southfield, we have the experience and credentials to get you compliant. We are NATE certified, BBB A+ rated, and carry a 4.9-star rating across 255+ Google reviews. Contact us at service@samcofm.com or call (734) 838-6300.
Frequently Asked Questions
Does the AIM Act apply to my building’s rooftop HVAC unit?
Yes, if your rooftop unit contains 15 pounds or more of HFC refrigerant, which most commercial rooftop units do. The January 2026 threshold change means the majority of commercial HVAC systems in Michigan now require formal leak inspection programs and documented compliance records.
How much does an AIM Act compliance assessment cost?
A professional compliance assessment for a single commercial building typically runs between $500 and $2,000, depending on the number of systems and building size. This covers system inventory, refrigerant documentation, leak detection, and a written compliance plan. Call Samco at (734) 838-6300 for a specific quote.
What happens if my building fails an EPA refrigerant inspection?
The EPA can issue penalties up to $60,000 per violation per day. Violations include failure to conduct required leak inspections, failure to repair leaks within 14 days, and failure to maintain proper records. First-time violations may receive a warning, but repeat or serious non-compliance triggers immediate fines.
How often do I need to inspect for refrigerant leaks under the AIM Act?
Commercial systems must be inspected at regular intervals based on their size and leak history. Systems with a history of leaks require more frequent checks. Most commercial buildings benefit from quarterly inspections as part of a preventive maintenance agreement.
Can I keep using R-410A refrigerant in my existing equipment?
Yes. Existing R-410A systems can continue operating and be recharged with R-410A refrigerant. However, new R-410A equipment is no longer being manufactured as of January 2026, and refrigerant prices are expected to rise as supply tightens. Maintaining your current systems properly extends their useful life and delays the need for costlier replacements.
Ready to Schedule a Compliance Assessment?
The AIM Act compliance deadline has already passed and enforcement is active now. Every day without a documented inspection program carries risk. Samco Facilities Maintenance provides AIM Act compliance assessments for commercial buildings throughout Southeast Michigan, from Livonia and Detroit to Ann Arbor and Sterling Heights.
Call (734) 838-6300 today or email service@samcofm.com to schedule your assessment. You can also contact us online or explore our full range of commercial services.
