HFC Compliance: Emissions Reduction Training & Recordkeeping 2026
In the late 1990s, HFCs became the default replacement for halons. What we didn’t foresee was the global scaling that turned them into a major climate driver. Fast forward, the U.S. AIM Act phasedown aligned with the Kigali amendment’s global reach, and now EPA’s Final Rule brings the fire suppression sector directly into implementation reality.
And beginning January 1, 2026, this becomes operational for fire equipment dealers, refill centers, and service companies servicing equipment with HFC suppressants, HFC-227ea, HFC-236fa, & HFC-125.
This is not just about limiting virgin supply.
This is about how we handle agents already in the field. Doing it right strengthens brands and builds trust with clients.
Two obligations drive everything:
1) Technician Training
2) Traceable Recordkeeping of recovery + reuse
And unlike refrigerant management for HVAC under Clean Air Act §608… this one is AIM Act Section 103(h) specific, with its own expectations, especially for fire suppression.
This means companies should not wait.
This training needs to be incorporated into your compliance and field practice culture the same way you already treat DOT, OSHA, and hazmat.
What does “best practice” look like?
training content aligned to §84.110
recordkeeping aligned to §84.110(g)
all servicing done with recycled gas tested to AIM Act specs January 2026-forward
no venting, recycle all gas coming out of service
EPA didn’t prescribe one class or one certifying organization, so companies can develop it or select it, as long as it hits the capability standards.
Why leadership matters now
Our industry was one of the first environmental success stories. Halons → control → recovery → reuse → responsible handling. We’ve done this before.
We can do it again, but the sector has to prepare operationally, ideally before 2026 hits.
If you want help building AIM Act aligned training that integrates with the way your technicians already work, talk to me.
This is what Polits Strategies does!
We protect people AND climate when we do this right.