HFC Phasedown Schedule 2025–2036: What Every HVAC Contractor Needs to Know About Refrigerant Supply
The AIM Act is doing two things simultaneously. The compliance regulations under Subpart C — leak rate tracking, repair timelines, documentation — are what most contractors are focused on right now. But the other half of the AIM Act, the HFC production phasedown, is the force that will reshape the economics of your entire business over the next decade.
The phasedown systematically reduces how much HFC refrigerant can be produced and imported into the United States, dropping from today’s already-restricted levels to just 15% of the original baseline by 2036. For contractors who buy, install, recover, and manage refrigerant every day, understanding this schedule is not optional — it is strategic planning for the survival of your service business.
The phasedown timeline
The EPA’s HFC phasedown follows a stepped schedule established under the AIM Act, with each step-down reducing the allowable production and consumption of HFC refrigerants measured in million metric tons of CO₂ equivalent (MMTEVe).
2020–2023: 90% of baseline (10% reduction). This was the initial step-down. The reduction was modest and, for most contractors, the impact was minimal. Refrigerant remained widely available at relatively stable prices.
2024–2028: 60% of baseline (40% cumulative reduction). This is where we are now. The jump from 90% to 60% removed a significant chunk of available supply from the market. This step-down is the primary driver of the refrigerant price increases contractors have experienced over the past two years. R-454B prices surged from roughly $345 per cylinder in 2021 to over $2,000 by 2025. R-410A and R-404A prices have also climbed, though less dramatically since they benefit from existing inventory and reclaimed supply.
2029–2033: 30% of baseline (70% cumulative reduction). This is the cliff. On January 1, 2029, allowable production drops from 60% to 30% — cutting the available new supply in half compared to current levels. This step-down will likely produce the most dramatic price increases and supply constraints the industry has experienced. Contractors who have not adjusted their business practices, customer pricing, and equipment recommendations by 2029 will be caught off-guard.
2034–2035: 20% of baseline (80% cumulative reduction). A further tightening, though less dramatic in percentage terms than the 2029 step.
2036 onward: 15% of baseline (85% cumulative reduction). The terminal level. Only 15% of original baseline HFC production is permitted. At this point, new HFC refrigerant is a niche product. Reclaimed refrigerant becomes the primary supply source for maintaining existing HFC systems, and most new equipment will have transitioned to alternatives.
What this means for refrigerant pricing
Refrigerant pricing follows supply economics, and the phasedown creates a predictable supply squeeze at each step-down.
Current pricing pressure is driven by the 60% allocation. Wholesale HFC prices have increased 30–100% across common refrigerants compared to pre-phasedown levels, depending on the specific refrigerant and regional supply conditions. R-404A, with its very high GWP of 3,922, has seen among the steepest increases because each pound consumes a disproportionate share of the production allowance.
The 2029 pricing shock will be the most significant event. When available new supply is halved (from 60% to 30%), prices will increase substantially. How much depends on how quickly the market transitions to alternatives and how much reclaimed refrigerant enters the supply chain — but historical experience from the R-22 phasedown provides a reference. R-22 prices increased from roughly $10/pound to over $50/pound as production tightened, a 5x increase over the phasedown period. HFC prices may follow a similar trajectory, though the availability of alternatives and reclamation infrastructure could moderate the curve.
Long-term pricing trends make leak prevention increasingly economically rational. A system that leaks 15% of its charge annually at current prices loses hundreds of dollars in refrigerant. At 2029+ prices, that same leak rate could cost thousands of dollars annually in refrigerant alone — before penalties, repair costs, and regulatory compliance labor. Tracking refrigerant usage precisely becomes not just a compliance obligation but a financial imperative.
The transition to low-GWP alternatives
As HFC supply tightens and prices rise, the industry is transitioning to lower-GWP alternatives. Understanding this transition is relevant to every contractor’s business planning.
R-454B is the primary replacement for R-410A in residential and light commercial AC applications. With a GWP of 466 (compared to R-410A’s 2,088), R-454B operates at similar pressures and capacities. However, it is classified as A2L (mildly flammable), requiring updated safety codes, modified equipment designs, and technician training. Equipment manufacturers including Carrier, Trane, and Daikin are transitioning production lines to R-454B systems. Building codes must be updated to allow A2L refrigerants — adoption varies by state and local jurisdiction.
R-448A and R-449A are drop-in or near-drop-in alternatives for R-404A in commercial refrigeration. They offer GWP reductions of 50–60% while working in existing R-404A system architectures with relatively minor modifications. Many grocery chains and cold storage operators are already transitioning existing equipment to these alternatives.
Natural refrigerants — CO₂ (R-744), propane (R-290), and ammonia (R-717) — are gaining traction in specific applications. CO₂ transcritical systems are increasingly common in large commercial refrigeration. Propane is used in self-contained refrigeration units and small commercial applications. Ammonia remains dominant in industrial refrigeration. These refrigerants have negligible or zero GWP and are exempt from the phasedown entirely.
For contractors, the transition creates both risk and opportunity. Technicians need training on new refrigerants, particularly A2L safety handling. Service offerings must expand to cover new equipment types. But contractors who invest early in transition-era capabilities will be positioned as trusted advisors while competitors are still figuring out the basics.
Reclaimed refrigerant: the growing supply source
As new HFC production declines, reclaimed refrigerant becomes an increasingly important part of the supply chain. The AIM Act explicitly encourages reclamation — cleaning recovered refrigerant to meet AHRI 700 virgin-equivalent specifications — as a way to extend the useful life of existing HFC systems without consuming new production allowances.
Reclaimed refrigerant does not count against phasedown allocations. This is critical. A pound of reclaimed R-410A can be sold and used without consuming any production allowance, making it increasingly cost-competitive against new production as supply tightens. For contractors, this means recovered refrigerant has growing economic value — every pound you recover and send for reclamation rather than allowing it to leak supports the supply chain and generates revenue.
The AIM Act includes provisions that will eventually require the use of reclaimed refrigerant for certain maintenance and service applications. While these provisions are still being implemented, the trajectory is clear: reclaimed refrigerant will transition from “nice to have” to “required” for maintaining existing HFC systems.
Tracking refrigerant source — whether each addition came from new production, reclaimed supply, or customer-provided stock — is already part of the Subpart C documentation requirements. This tracking will become increasingly important as reclamation requirements tighten and as customers begin asking for evidence of responsible refrigerant sourcing.
How to prepare your business
The phasedown is not a surprise — the dates and percentages are published. Contractors who plan ahead will manage the transition smoothly. Those who react after the fact will face supply shortages, price shocks, and unhappy customers.
Track refrigerant usage across your entire customer base. Knowing exactly how much R-410A, R-404A, and other HFCs your business uses annually — and which customer systems consume the most — allows you to forecast costs, plan inventory, and prioritize system transitions. A customer with three systems that collectively leak 200 pounds of R-404A per year is spending far more on refrigerant than a customer whose systems are tight. Quantifying this enables informed conversations about equipment replacement timing.
Start advising customers on transition planning now. A system installed today with R-410A has an expected lifespan of 15–20 years. By 2036, that system will be operating in a market where only 15% of baseline HFC production is allowed. Customers who understand this trajectory will appreciate early guidance on when to plan equipment transitions. Contractors who proactively provide this analysis build loyalty and generate future installation revenue.
Invest in technician training for A2L and low-GWP refrigerants. R-454B, R-32, and other A2L refrigerants require specific handling procedures due to their mild flammability. Safety training, updated tools, and familiarity with new equipment designs are not optional — they are prerequisites for servicing the next generation of HVAC equipment.
Build recovery and reclamation into your standard practices. Every pound of HFC recovered cleanly is a pound that can be reclaimed and resold — and at rising prices, the economic incentive for thorough recovery grows with every phasedown step. Track recovery volumes alongside additions to understand your business’s net refrigerant efficiency.
Monitor your largest consumers. The Pareto principle applies to refrigerant usage: a small number of systems typically account for a disproportionate share of total refrigerant consumption. Identifying your top 20% of refrigerant-consuming systems and targeting them for leak repair, retrofit, or replacement generates the largest impact on both compliance and cost.
The role of tracking software in a tightening market
As refrigerant becomes more expensive and more regulated, the value of precise tracking increases proportionally. Knowing exactly how much refrigerant each customer system uses, identifying trends over time, and forecasting future needs are capabilities that transform a compliance tool into a business intelligence platform.
RefriComply tracks every pound of refrigerant added to and recovered from every system in your portfolio. Usage trends, customer-level consumption reports, and system-level leak rate histories help you make data-driven decisions about which systems need attention, which customers should consider equipment transitions, and how to price your services to reflect the rising cost of refrigerant.
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