EPA Issues Fact Sheet: Requirements for HFC Fire Suppression Systems
The American Innovation and Manufacturing (AIM) Act, enacted on December 27, 2020, authorizes the
U.S. Environmental Protection Agency (EPA) to address hydrofluorocarbons (HFCs) in three main ways:
- Phasing down HFC production and consumption through an allowance allocation program;
- Maximizing reclamation and minimizing releases of HFCs from equipment and ensuring the safety of technicians and consumers; and
- Facilitating the transition to next-generation technologies by restricting the use of HFCs in the sectors or subsectors in which they are used.
The Fact Sheet, released by the EPA in February 2026, primarily concerns the second area - maximizing reclamation and minimizing releases of HFCs from fire suppression equipment.
In the Fact Sheet, EPA provides information on requirements related to fire suppression equipment containing HFCs established under the 2024 Emissions Reduction and Reclamation (ER&R) final rule, published on October 11, 2024 (89 FR 82682). The rule establishes regulatory requirements to minimize the release of HFCs and certain substitutes from fire suppression equipment during installation, servicing, repair, or disposal; and to maximize the amount of HFCs reclaimed.
ACCESS THE FEBRUARY 2026 FACT SHEET
Reporting Requirements Certain entities are required to maintain and provide data on HFCs in the fire suppression sector. These include entities (e.g., equipment manufacturers, distributors, or recyclers) that: • Perform first fill of equipment; • Service (e.g., recharge) equipment; and/or • Recycle HFCs. Beginning in 2027, covered entities must submit data electronically each year by February 14 on the prior year’s activity, from January 1 through December 31. For information on reporting, refer to EPA’s Managing Use and Reuse of HFCs and Substitutes website. Annual reports must contain basic identification information and the following information for each HFC: • The quantity of material sold;* • The quantity of material in inventory onsite, broken out by recovered, recycled, and virgin;* • The total mass of each HFC sold;* • The total mass of each HFC in inventory onsite, broken out by recovered, recycled, and virgin; and* • The total mass of waste products the reporting entity sent for disposal, along with information about the disposal facility if waste is not processed by the reporting entity. * For installation of new fire suppression equipment, and servicing and/or repair of existing fire suppression equipment. Recordkeeping Requirements Beginning in 2027, certain entities must maintain records for three years, including a copy of the annual report submission, records documenting technician training, and records documenting that HFCs are recovered from fire suppression equipment before the equipment is sent for disposal.