Attached below is a copy of the Environmental Protection Agency (EPA) Final Rule (89 Fed. Reg. 82682, Oct. 11, 2024) on the management and reclamation of HFCs under the AIM Act. The Rule goes into effect on December 10,2024.

Here is a summary of the Rule’s requirements applicable to use of HFC (Hydrofluorocarbons) agents in fire suppression systems. References below are in 40 CFR Part 84 of the Code of Federal Regulations.

Initial fill of fire suppression equipment

84.110(c)

As of January 1, 2030, recycled HFCs must be used for the initial installation (first fill) of new fire suppression equipment that is installed in the United States, including both total flooding systems and streaming applications.

Servicing of fire suppression equipment

84.110(c)

As of January 1, 2026, recycled HFCs must be used for the servicing and/or repair of existing fire suppression equipment in the United States, including both total flooding systems and streaming applications.

Maintenance, training, venting and disposal

84.110(a)

Prohibits knowingly venting HFCs in the installation, servicing, repair or disposal of fire suppression equipment as of January 1, 2026.  Exemptions are provided for testing of fire suppression equipment under certain conditions and for qualification testing during system design and development.

84.110(b)

Prohibits allowing the release of HFCs to occur as a result of failure to maintain fire suppression equipment as of January 1, 2026.

84.110(d)

Requires fire suppression technicians who install, service, repair, or dispose of fire suppression equipment containing HFCs to be trained on emissions reduction of HFCs by June 1, 2026.  The final rule includes topics that must be addressed in the training.

84.110(e)

Requires the recovery of HFCs from fire suppression equipment prior to disposal of the equipment as of January 1, 2026.

84.110(f)

As of January 1, 2026, HFCs used as fire suppression agents must be disposed of either by sending them to a certified recycler of reclaimer, or by sending them for destruction using an approved method.  The final rule includes requirements for the use and maintenance of recycling equipment to prevent emissions and cross contamination during transfer and storage.

Reporting and recordkeeping

84.110(g)

As of January 1, 2026, any company that performs first fill of fire suppression equipment, service (e.g., recharge) of fire suppression equipment, and/or recycles HFCs recovered from fire suppression equipment, such as equipment manufacturers, distributors, agent suppliers, or installers that recycle HFCs, must submit a report to EPA annually covering the prior year’s activity from January 1 through December 31. The first annual report must be submitted to the Agency on February 14, 2027, and subsequent annual reports must be submitted by February 14 of each subsequent year. 

As of January 1, 2026, companies that employ fire suppression technicians who service, repair, install, or dispose of fire suppression equipment containing HFCs must maintain an electronic or paper copy of the fire suppression technician training used to meet the requirements in paragraph (d). These entities must document that they have provided training to personnel as specified in paragraph (d) of this section and must maintain these records for three years after each training in either electronic or paper format. 

As of January 1, 2026, owners and operators of fire suppression equipment containing HFCs must maintain records documenting that HFCs are recovered from the fire suppression equipment before it is sent for disposal as specified in paragraph (e) of this section. Such records must be maintained for three years after the relevant equipment is sent for disposal in either electronic or paper format.

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