Enforcement Alert: HFC Technology Transitions Rule

Companies manufacturing or importing products or specified components in the refrigeration, air conditioning, heat pump, foam, or aerosol sectors should be aware of an ongoing Environmental Protection Agency (EPA or Agency) compliance initiative related to the Technology Transitions Rule reporting obligations.[1] Under the Rule, which implements subsection (i) of the AIM Act,[2] annual reporting is required of manufacturers or importers of certain products and specified components that fall into these three sectors and use, or are intended to use, a regulated hydrofluorocarbon.[3] Companies that imported or manufactured products or specified components in 2025 that meet these parameters were required to submit their first annual report to EPA by March 31, 2026.

Deregulatory revisions to the Technology Transitions Program earlier this year may have given the impression that the Agency was deprioritizing compliance.[4] Relying on what it styles as “available data and public information,” however, the Agency has been sending emails to companies it believes were required to submit the annual report. In the various communications we have seen, the Agency is giving companies one week to either: (1) submit the late report via EPA’s Central Data Exchange (CDX); (2) provide the submission date and report ID if the annual report has already been filed; or (3) explain briefly why the company is not subject to reporting.

This reporting outreach comes amidst a renewed emphasis on compliance with other aspects of the Technology Transitions Rule. EPA has finalized several settlements against companies the Agency alleged imported products in violation of the AIM Act’s HFC restrictions. Penalties in these cases can be significant as they are calculated by multiplying the total monetary value of the goods by a percentage multiplier ranging from 20-50%, which is assigned based on the GWP of the product or exchange value of the HFC used.

Notwithstanding the Agency’s deregulatory efforts, this initiative is a reminder that compliance with the AIM Act remains a priority for EPA.[5] Please contact JC Walker (walker@khlaw.com) or Alexa Pecht (pecht@khlaw.com) if you have questions about EPA’s compliance outreach or how the Technology Transitions Rule may impact your products. 

[1] See 40 C.F.R. Part 84, Subpart B. 

[2] American Innovation and Manufacturing (AIM) Act of 2020, 42 U.S.C. § 7675(i).

[3] 40 C.F.R. § 54.60. 

[4] See Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Promulgated Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020, 91 Fed. Reg. 31,284 (May 26, 2026). 

[5] See U.S. EPA, Implementing National Enforcement and Compliance Initiatives Consistently with Executive Orders and Agency Priorities (May 12, 2025).