Under the AIM Act (American Innovation and Manufacturing Act), R-410A production and import in the United States is being phased down starting in 2025, with significant restrictions taking effect January 1, 2025, and a continued step-down through 2036. New HVAC equipment sold in the US after January 1, 2025, can no longer use R-410A. Existing systems can still be serviced with reclaimed or existing-stock R-410A, but supply will tighten and prices will rise. Southeast Michigan facility managers need to plan now, before a refrigerant shortage forces an unplanned equipment replacement during a Michigan summer or winter.
What the AIM Act Timeline Actually Means
The EPA’s AIM Act phase-down is not a ban on using R-410A in existing equipment. It’s a production and import limit that reduces the amount of new R-410A entering the US market each year. Here’s what matters practically:
- January 1, 2025: New HVAC equipment cannot be manufactured or sold in the US with R-410A. New equipment from Carrier, Lennox, Trane, and other manufacturers has already transitioned to lower-GWP alternatives, primarily R-454B.
- Existing systems: You can keep using your R-410A equipment and have it serviced as long as technicians can source the refrigerant. Reclaimed R-410A remains available for servicing existing equipment, but prices have already climbed sharply and will continue to do so as production decreases.
- 2025 to 2036: Annual production limits tighten each year. The cost and availability of R-410A for service will become progressively more challenging.
- No forced retirement: You are not legally required to replace existing R-410A equipment on any specific date. But repair economics will change: when an aging R-410A system needs a major repair, the combination of high refrigerant costs and parts availability for aging equipment may make replacement the better financial decision.
The New Refrigerants: R-454B and R-32
The two alternatives that have gained the most traction in commercial HVAC are R-454B (sold by Chemours as Opteon XL41) and R-32. Both have a significantly lower Global Warming Potential than R-410A.
- R-454B is mildly flammable (A2L classification) and is the refrigerant Carrier, Lennox, and Trane selected for their new residential and light commercial product lines. It requires updated equipment designed for A2L refrigerants. You cannot simply retrofit an R-410A system to use R-454B without equipment modifications.
- R-32 is also A2L and is used in some new equipment, particularly mini-split and VRF systems. Mitsubishi and Daikin have used R-32 for several years already.
- A2L designation means these refrigerants are mildly flammable under certain conditions, which has implications for equipment room design, leak detection requirements, and technician training. Facilities with refrigerant systems in enclosed spaces should discuss code implications with their service provider.
R-454B and R-32 are not interchangeable with R-410A. Existing R-410A systems cannot be converted. If you replace an R-410A unit, the new unit will come charged with the appropriate next-generation refrigerant from the factory.
What This Means for Michigan Facilities Specifically
Southeast Michigan’s climate makes refrigerant reliability a year-round concern, not just a summer issue. Commercial HVAC in this region handles extreme heating loads in winter and significant cooling loads from June through September. A refrigerant shortage that disrupts service during either peak season creates real operational risk.
Michigan businesses also face the practical reality of a large installed base of aging R-410A equipment. Many commercial rooftop units and split systems installed in the early to mid-2010s are approaching or past their expected service life. These units are the ones most likely to need a refrigerant-intensive repair in the next few years, at precisely the time when R-410A pricing and availability will be most constrained.
What Facility Managers Should Do Right Now
Acting before a crisis is significantly less expensive than reacting to one. Here’s a practical action list for Southeast Michigan facility managers:
- Audit your equipment: Document every refrigerant-containing system in your facility. Note the refrigerant type, tonnage, age, and last service date. This is the foundation of any phase-out plan.
- Identify aging R-410A systems: Any commercial HVAC unit that is 12 or more years old and uses R-410A should be flagged for priority evaluation. A system that was marginally viable at current refrigerant prices may not be worth repairing at 2026 or 2027 pricing.
- Plan replacements on your schedule, not a failure schedule: Replacing equipment proactively, during a planned capital cycle, is almost always cheaper than emergency replacement after a catastrophic failure in the middle of summer. Lead times for commercial HVAC equipment have also increased in recent years. Ordering in advance of need avoids lead-time surprises.
- Budget for higher refrigerant service costs: Even for systems you intend to keep running through the phase-down period, build in higher refrigerant line items in your maintenance budget. R-410A costs have already increased significantly from pre-2025 prices.
- Talk to your service provider: Your HVAC contractor should be able to give you a condition assessment of your existing equipment and a recommendation on which units are worth continued investment versus replacement.
SAMCO FM’s Capabilities with New Refrigerants
SAMCO FM’s technicians are trained and equipped to work with A2L refrigerants including R-454B and R-32. We’ve been following the AIM Act phase-down closely and have updated our equipment and procedures accordingly. We service new R-454B-charged equipment from Carrier, Lennox, and Trane, and we can perform the refrigerant equipment audits that Michigan facilities need to build a realistic phase-out plan.
SAMCO FM has been serving commercial HVAC and refrigeration accounts in Metro Detroit and Southeast Michigan since 1997. Our team brings 90+ years of combined experience across system types and refrigerant generations. We’ve seen refrigerant transitions before (R-22 to R-410A), and we know how to help clients manage the transition without being forced into rushed decisions.
When to Call a Professional
If you haven’t had a formal assessment of your R-410A equipment inventory in the context of the AIM Act phase-down, now is the right time. SAMCO FM can walk through your facility, evaluate your existing equipment, and give you a realistic picture of which systems are worth maintaining, which should be prioritized for replacement, and what a multi-year capital plan might look like.
Call (734) 838-6300, email service@samcofm.com, or schedule a site visit at samcofm.com. We serve facility managers at commercial, institutional, and food service operations across Wayne, Oakland, Macomb, Washtenaw, and surrounding counties in Southeast Michigan.
Frequently Asked Questions
Can I still get R-410A to service my existing equipment?
Yes, for now. Reclaimed R-410A is available for servicing existing systems and will remain legal for that purpose through the phase-down period. However, prices have risen sharply already and will continue to increase as production limits tighten. If your system has a significant refrigerant leak, the repair economics need to account for current and near-future refrigerant pricing, not pre-2025 baseline costs.
Do I have to replace my R-410A system by a certain date?
No. There is no federally mandated date by which you must retire existing R-410A equipment. The phase-down affects production and import of new refrigerant, not the use of existing systems. You can continue operating R-410A equipment and having it serviced as long as technicians can source refrigerant. The decision about when to replace should be driven by equipment condition, repair costs relative to replacement value, and refrigerant pricing trends.
Is R-454B safe? I heard the new refrigerants are flammable.
R-454B is classified A2L, meaning it is mildly flammable. In practice, A2L refrigerants require a specific ignition source and concentration to burn, and equipment manufacturers have redesigned systems to account for this. The risk is manageable with properly designed and installed equipment and qualified technicians. The EPA and equipment manufacturers have established safety standards for A2L systems. Facilities that store refrigerants in enclosed mechanical rooms should review code requirements for leak detection with their service provider.
What happens if my R-410A unit needs a major repair in 2026 or 2027?
You’ll face a decision: pay for the repair at higher refrigerant costs with an aging system, or use the failure as the trigger for a planned replacement. The answer depends on the unit’s age, condition, remaining useful life, and the cost of the specific repair. SAMCO FM can help you work through that analysis on a case-by-case basis. The worst outcome is being surprised by the decision when a system fails in the middle of a Michigan summer or winter with no plan in place.
