Recovery, Reclaim and Cylinders: The 2024 AIM Act Checklist

The 2024 Emissions Reduction and Reclamation (ER&R) Program covers more than leak repair. Two of its other pieces — the reclamation standard and the disposable-cylinder requirement — set specific, dated obligations that are easy to miss because they don't show up on a pressure gauge.

Reclaimed refrigerant: the 15% cap

Starting January 1, 2026, reclaimed HFC refrigerant sold or used has to meet a purity standard: no more than 15%, by weight, of virgin HFCs, and the fact sheet's own summary table pairs that cap with a labeling requirement. In practical terms, a cylinder labeled and sold as reclaimed can't be mostly virgin product with a token amount of reclaimed material mixed in — the reclaimed share has to dominate.

Servicing with reclaimed HFCs: three subsectors, 2029

A second, later requirement narrows to specific equipment types. Starting January 1, 2029, servicing and repair of certain equipment has to use reclaimed HFCs rather than virgin product, in three named subsectors:

• supermarket systems
• refrigerated transport
• automatic commercial ice makers

Outside those three subsectors, the rule doesn't mandate reclaimed refrigerant for servicing, though the broader 15% cap still governs what counts as "reclaimed" wherever it's used.

Disposable cylinders: clearing them before disposal

The rule also closes off a source of HFC emissions that has nothing to do with a running system: refrigerant left in disposable cylinders that get thrown away. Starting January 1, 2028, EPA's fact sheet sets the requirement plainly: "Send certain disposable cylinders to either an EPA Clean Air Act (CAA) section 608 certified reclaimer, a fire suppressant recycler, a final processor, such as a landfill operator or scrap metal recycler, or a refrigerant supplier (including, but not limited to distributors and wholesalers) for its remaining contents to be removed". A separate, alternative path lets a certified technician handle it directly on site: "An EPA CAA section 608 certified technician evacuates a disposable cylinder to a vacuum level of 15 in-Hg, and provides a certification statement to the final processor". Either route, the goal is the same — nothing with meaningful refrigerant left in it goes straight to a landfill or scrap yard.

A quick checklist

• Buying or selling "reclaimed" refrigerant? Confirm it's no more than 15% virgin HFC by weight, and labeled as reclaimed.
• Servicing a supermarket system, refrigerated transport unit, or automatic commercial ice maker after January 1, 2029? Use reclaimed HFCs, not virgin product.
• Emptying a disposable cylinder for disposal after January 1, 2028? Either route it to a certified reclaimer, recycler, processor or supplier to clear it, or — if a certified technician is doing the work directly — evacuate it to 15 in-Hg vacuum and issue a certification statement to the final processor.

Section 608 certification itself is what qualifies a technician for the direct-evacuation path above; see EPA 608 certification types for what each certification type covers. For the separate leak-repair thresholds this same 2024 rule sets for HFC appliances, see refrigerant leak repair: which rule applies.