Don’t Gamble on a Trump Reversal of the AIM Act: Countdown to January 1, 2026
Over the past few years, business leaders and elected officials from both parties worked together to address environmental risks across industries with new federal regulations and guidelines. For the grocery and cold storage facility sector, the top target was refrigerants known as hydrofluorocarbons (HFCs).
The result? The AIM Act, which places new compliance rules on refrigerant leak monitoring, recovery, repair, and documentation. Not only did this law have broad industry support from key trade organizations, refrigerant gas suppliers, and refrigeration OEMs, it was passed with bipartisan support in Congress and signed into law by President Trump back in 2020.
Now the January 1, 2026 deadline is fast approaching, and there is no turning back. Ignoring this rule exposes your company, your shareholders, and you as an individual to unacceptable legal and financial risks. With Axiom Cloud, it's easy to become compliant with the AIM Act since you don't need to install any new hardware or sensors - just let us connect our software and you're off and running. The regulation is here, the clock is ticking. The smartest teams are already taking action.
Background: Trump signed the AIM Act in 2020
In 2020, President Trump signed the AIM Act into law, after it was co-sponsored by 34 senators (including 17 Republic senators). Since then, the AIM Act has had broad industry support from key trade organizations, leading refrigerant gas suppliers, and leading refrigeration OEMs, which continues to this day.
Between 2021 and 2024, the EPA issued three rules to regulate HFC refrigerants under the AIM Act:
Reduce supply of HFCs (85% by 2036)
Restrict the use of HFCs (drive technology transitions)
Minimize refrigerant leaks and maximize reclamation of HFCs (Subsection h - the focus for this post, full text here)
Even though Subsection (h) was finalized in October 2024, the majority of the industry has lagged in compliance in the hopes that the Trump administration or a Republican Congress would reverse this EPA regulation before it goes into effect. However, the deadline for the regulation to be reversed has elapsed. Now, the industry must rush to achieve compliance before enforcement begins.
The CRA “Quick Repeal” Window Is Closed
Some executives were betting on Congress to kill this rule using the Congressional Review Act (CRA). As of June 2025, that option is no longer available, as the CRA window has expired without action. Enforcement is coming whether you’re ready or not.
Here’s what happened:
The Senate CRA resolution (S.J.Res.14) was introduced on February 5, 2025
The House version (H.J.Res.38) followed on February 7, 2025
Under the CRA, Congress had 60 legislative days to vote on a repeal
And here’s where that landed:
Bottom line: as of June 6, 2025, the CRA window is closed in both chambers, and no vote occurred. The rule stands.
And, a CRA “do-over” isn’t an option. As refrigerant policy expert Keilly Witman put it:
“The new people coming in only have a certain period of time to actually introduce resolutions under the Congressional Review Act. And that has passed. I don’t think you can introduce anything else under the Congressional Review Act.”
She’s right. Congress chose not to deregulate. The rule is now locked in — and the countdown to enforcement continues.
What Subsection (h) of the AIM Act Actually Requires
If you own or operate commercial refrigeration equipment, this rule applies to you (full text here). Starting January 1, 2026, regulated entities must:
Install leak monitoring systems (direct or indirect)
Respond to leak notifications within a strict timeframe
Perform timely leak repairsTrack, report, and document refrigerant usage and losses
Recover, reclaim, or destroy refrigerants according to EPA protocols
These new EPA refrigerant regulations affect grocery stores, cold storage warehouses, convenience retailers, pharmacies, distribution centers — anyone with a fleet of HFC-using refrigeration systems.
Can Trump Undo Subsection (h) of the AIM Act?
President Trump has returned to office and resumed his administration's focus on deregulation, but that doesn't mean you can ignore this EPA refrigerant law. Since the AIM Act was signed into law five years ago, Congress has solidified the final rules of the legislation and the deadline to repeal it has passed. With just five months until enforcement begins, it is highly unlikely any legislative changes to this law will move forward and override the requirements in the foreseeable future.
Here's why you still need to comply despite the change in administration:
The rule was finalized in October 2024 and is already legally binding.
The CRA window closed without action. Repealing it now would require a brand-new act of Congress — a heavy political lift, even with GOP momentum.
Trump’s EPA has chosen to focus on deregulating technology transition rules (governing the transition to low-GWP refrigerants), not on reversing the Subsection (h) rules regarding leak management, which go into effect on January 1, 2026.
Even if Trump’s EPA chooses to minimize enforcement of this rule, the EPA can “reach back” 3+ years, and future administrations may choose to enforce this act.
Refrigeration regulations are already in effect in California, New York and Washington, with similar requirements spreading to 20+ states. Companies will now need to comply with a patchwork of state-level regulations, in addition to federal regulations.
So unless Congress successfully introduces and passes new legislation at record speed, the rules aren’t going anywhere.
If the EPA rescinds the 2009 CO₂ Endangerment Finding, will the AIM Act remain intact and enforceable?
In July 2025, Trump’s EPA proposed rescinding the 2009 CO₂ Endangerment Finding, which underpins the legal foundation of many environmental regulation policies. But even if this is rescinded, the AIM Act remains fully intact and enforceable, and altering the AIM Act would require congressional action, not administrative rollback.
The 2009 Endangerment Finding declared that CO₂ and other greenhouse gases pose threats to public health and welfare. Dismantling this would significantly undermine the EPA’s authority to regulate CO₂ emissions from vehicles, power plants, industrial sources, and more.
However, the AIM Act, passed in 2020, is different. It is a standalone statute that specifically mandates the EPA to phase down HFCs. Because the AIM Act is separate from the Clean Air Act’s greenhouse gas authorities, it does not depend on the Endangerment Finding. Thus, even if the EPA dismantles the legal underpinning for CO₂ regulation, the AIM Act’s HFC phasedown schedule remains intact and must continue.
If You’re Waiting to Act, You’re Already Behind
Say you’ve been waiting to see what happens. Maybe you’ve been assuming Trump would fix it. Now it's mid-2025, and enforcement begins in just a few months.
This is not a December problem. It’s a today problem. Waiting any longer exposes you, your shareholders, and your company to unacceptable compliance risk.
And Yes, Enforcement Will Be Real
The EPA can impose civil penalties of up to $57,000 per day for each violation, along with potential jail time for breaches of its refrigerant leak regulations. That’s not hypothetical. Many have already faced penalties and enforcement actions (and some individuals have faced jail time) under the AIM Act. That’s not a risk you can ignore. That’s the kind of thing that makes headlines, lowers stock prices, and costs people their jobs.
If you’re a leader in facilities, operations, or compliance (or the P&L owner for a refrigeration-heavy portfolio), this risk is on your desk.
The Bottom Line: Don’t bet your job on Trump.
Some companies are already in motion: auditing their refrigeration assets, implementing whole-system ALD systems, upgrading systems, rewriting SOPs, and training teams. Others are asleep at the wheel.
Meeting the AIM Act requirements shouldn't be a December scramble. Get ahead of this deadline by evaluating your ALD options now.
Develop a program and choose vendors who can help you:
Conduct an asset inventory of your refrigeration systems
Select and install compliant Automatic Leak Detection Systems (ideally, "whole system" ALD solutions to avoid additional manual leak inspection requirements)
Train your teams
Build compliant workflows for leak response and recordkeeping
Implement an "enforcement readiness program" to help prepare for EPA audits
Axiom Cloud’s software-only approach enables deployment across hundreds of sites without any onsite installation of new hardware or sensors. When enforcement begins, the difference will be obvious. Because once 2026 arrives, 'I was waiting to see what would happen' won't be a valid excuse.