The Expert Opinion provides a platform on NaturalRefrigerants.com for experts to share their views on technology, market trends, policy developments and more. Contributors are not paid, and all opinions are their own. NaturalRefrigerants.com maintains full editorial control over each submission. If you’re interested in contributing to The Expert Opinion, please fill out this form.
This Expert Opinion column has been written by Amrit Robbins, CEO and Co-founder of Axiom Cloud, whose AI-powered refrigeration management software is used by grocery stores and cold storage facilities to enable predictive maintenance and early leak detection. Here, Robbins writes about the AIM (American Innovation and Manufacturing) Act and how two of its requirements will help prepare end users for the transition to natural refrigerants.
Amrit Robbins: There’s been significant confusion in the market about whether the Trump administration will reverse AIM Act requirements. While the status of the AIM Act’s Technology Transitions rule remains in limbo, it’s time to clear the air on the other two pillars of the AIM Act. The Emission Reduction and Reclamation (ER&R) Program and HFC Phasedown Programs are both locked in, and enforcement deadlines including January 1, 2026 remain unchanged.
Refrigeration leaders: Ignoring this deadline will put your company, your shareholders and your job at risk (and trigger large potential penalties/fines). However, this deadline also represents an opportunity. It is the perfect excuse to revisit your strategic refrigerant plan – including your natural refrigerant strategy – and make these critical issues a top priority.
The Political Reality: Trump Can’t Undo What Trump Created
The AIM Act isn’t some last-minute Obama-era regulation – it’s bipartisan legislation that President Trump himself signed into law in 2020. The bill passed with remarkable support, co-sponsored by 34 senators, including 17 Republicans, and backed by major industry players from the American Chamber of Commerce to refrigeration OEMs like Danfoss, Daikin, and Carrier.
This wasn’t regulatory overreach. It was coordinated industry transformation with federal backing.
The Congressional Review Act (CRA) offered the current Trump administration a narrow window for quick reversal, but that opportunity has expired. Both the Senate deadline (May 22, 2025) and House deadline (June 6, 2025) passed without action.
Even if Trump’s EPA wanted to reverse course, it would now require entirely new legislation. This is a heavy political lift that’s unlikely given the law’s broad industry support and the fact that approximately 12 states have already or since developed their own HFC regulations.
Enforcement is Coming January 1, 2026
The AIM Act comes with binding federal requirements with real financial consequences for non-compliance, with penalties reaching $57,000 per day per violation.
The regulatory framework is comprehensive: automatic leak detection requirements, 24-hour response protocols, quarterly inspection mandates for high-leak-rate systems and detailed documentation standards. For operators with HFC systems above certain thresholds, compliance isn’t optional. It’s mandatory and enforcement begins in just months.
But here’s what many facilities leaders miss: This regulatory certainty creates exactly the operational foundation needed for successful natural refrigerant transitions.
How the AIM Act Compliance Accelerates Natural Refrigerant Success
The reality is that most companies won’t fully transition to natural refrigerants for 20+ years. Even industry leaders project only 22% of stores will use natural refrigeration by 2028. Since refrigeration systems last 25 to 30 years, you’ll be managing HFC systems for decades while planning your eventual switch.
But here’s the opportunity most operators miss: The skills and systems you need for AIM Act compliance are exactly the same ones that make natural refrigerant transitions successful. Think of AIM Act compliance as natural refrigerant training wheels.
Here’s how it works:
- You’ll Build the Data Foundation You Need: Right now, most operators have no idea what their actual leak rates, repair costs or system performance really look like. AIM Act compliance forces you to track this data systematically. When it’s time to evaluate natural refrigerants, you’ll have real numbers to base your decisions on– not guesswork that leads to costly surprises.
- You’ll Develop Operational Discipline: Natural refrigerants aren’t more complex than HFCs, but they do require consistent, precise operations for safety reasons. The leak detection protocols, rapid response systems and preventive maintenance that the AIM Act demands? Those are exactly the operational habits that make natural refrigerant systems run safely and efficiently.
- You’ll Build Your Technical Team and Vendor Network: Installing automatic leak detection systems and advanced monitoring for AIM Act compliance means your team learns these technologies now while the stakes are lower. Your vendor relationships mature. Your internal expertise grows. When conversion time comes, you’re not starting from scratch.
- You’ll Have Your Documentation Systems Ready: Natural refrigerants operate under safety regulations rather than environmental ones, but they require the same level of systematic record-keeping and operational documentation. Master this for HFC compliance and you’re already prepared for natural refrigerant requirements.
The bottom line is that instead of viewing AIM Act compliance as a burden to endure until natural refrigerants arrive, smart operators recognize it as the operational foundation that will determine their success when they make the switch.
This Isn’t About Delaying Natural Refrigerant Adoption
Let’s be clear: This isn’t about using the maximum time under current regulations or treating HFC compliance as an excuse to delay natural refrigerant planning. It’s about recognizing that the operational capabilities required for AIM Act compliance are exactly the capabilities that determine natural refrigerant success.
The most successful natural refrigerant deployments happen at facilities that already demonstrate operational excellence with their current systems. Organizations that struggle with basic leak detection, maintenance protocols or compliance documentation consistently face challenges with natural refrigerant conversions – not because the technology doesn’t work, but because they lack the operational foundation for success.
The Competitive Advantage of Early Compliance
While competitors delay compliance hoping for regulatory relief that won’t come, forward-thinking operators are taking concrete steps to comply with AIM Act requirements, such as implementing “whole system” automatic lead detection systems.
They’re implementing whole-system leak detection that eliminates manual inspection requirements while providing the baseline data needed for natural refrigerant planning. They’re establishing rapid response protocols that reduce immediate compliance costs while building the operational capabilities that natural refrigerant safety requires. They’re developing vendor relationships and internal expertise that pays immediate compliance dividends while positioning them for successful natural refrigerant deployment when the time comes.
The Bottom Line: Regulatory Certainty Enables Strategic Planning
The AIM Act’s permanence removes the uncertainty that has paralyzed natural refrigerant planning. Instead of hoping regulations will disappear, operators can build strategic transition plans based on known compliance requirements and established operational capabilities.
The transition to natural refrigerants is inevitable. The question isn’t whether to prepare, but how effectively you’ll use current HFC compliance requirements to build the operational foundation that determines your success when conversion time arrives.
Because when you finally make the switch to natural refrigerants, operational excellence won’t be optional, it will be the difference between a successful transition and a costly failure.
