HFC Allowances
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Background
What is the AIM Act?
The American Innovation and Manufacturing (AIM) Act was enacted on December 27, 2020. The AIM Act directs the U.S. Environmental Protection Agency (EPA) to phase down production and consumption[1] of HFCs to 15% of their baseline levels in a stepwise manner by 2036 through an allowance allocation and trading program.
How do Allowances Work?
EPA uses an allowance as the unit of measure that controls production and consumption of bulk HFCs. EPA will issue allowances that will be valid between January 1 and December 31 of a given year, known as a “calendar-year allowance.” A calendar-year allowance represents the privilege granted to an entity to produce or import bulk regulated substances (i.e., bulk regulated HFCs) in that year.
Entities must expend allowances in order to produce or import bulk HFCs. Producing HFCs requires expending both production allowances and consumption allowances. Importing HFCs requires expending only consumption allowances. A third category of allowances called “application-specific allowances” can be used to either produce or import HFCs exclusively for use in one of the allowed applications (see the list of allowed applications at 40 CFR 84.13). A fourth category of allowances called “production for export allowances” can be used to produce HFCs that will be exported in the same calendar year and exclusively used for the etching of semiconductor material or wafers and the cleaning of chemical vapor deposition chambers within the semiconductor manufacturing sector.
Entities must expend the correct number of allowances for each kilogram of HFCs that they produce and/or import. EPA has developed a calculator to help allowance holders understand how allowances translate to quantities of various HFCs they intend to produce or import.
For information on requirements for products containing and using HFCs that are not bulk substances and do not require allowances to import, please see the Technology Transitions resources.
Issuance of 2026 HFC Allowances
How do Entities Receive Allowances for 2026?
EPA issued allowances to entities that produced and/or imported HFCs in 2021 or 2022, or both 2021 and 2022, based on the three highest years of production or consumption between 2011-2019. EPA has also issued allowances to entities that were previously allocated allowances as new market entrants on March 31, 2022. EPA also issued “application-specific allowances” to five applications consistent with the recent rule titled "Phasedown of Hydrofluorocarbons: Review and Renewal of Eligibility for Application-Specific Allowances” (90 FR 41676, August 26, 2025), hereinafter referred to as the 2025 Application-specific Allowance Review and Renewal Rule. These entities will be able to confer their allowances to producers or importers to acquire needed HFCs.
EPA signed "Phasedown of Hydrofluorocarbons: Notice of 2026 Allowance Allocations for Production and Consumption of Regulated Substances under the American Innovation and Manufacturing Act of 2020," on October 1, 2025, to provide notice in the Federal Register of EPA’s allocation of calendar year 2026 allowances. EPA published "Phasedown of Hydrofluorocarbons: Notice of 2026 Allowance Allocations for Production and Consumption of Regulated Substances under the American Innovation and Manufacturing Act of 2020" in the Federal Register on November 20, 2025.
- Federal Register link to the Notice of 2026 Allowance Allocations for Production and Consumption of HFCs
- Overview of Allowances and Exchange Values (pdf)
How Did Finalized Administrative Consequences Affect the Number of Allowances Available?
EPA finalized a number of independent administrative consequences effective September 30, 2025 (see the full list of finalized administrative consequences). These final actions retired, revoked, or withheld application-specific, production, or consumption allowances. In the instances where EPA revoked calendar year 2026 consumption allowances, the allowances are taken back from an allowance holder and redistributed to all other allowance holders. EPA redistributed consumption allowances that were revoked to consumption allowance holders that were not subject to a final administrative consequence effective September 30, 2025, or had an administrative consequence solely withholding allowances.
EPA had also previously finalized a number of separate, independent administrative consequences effective September 29, 2023 (see the full list of finalized administrative consequences). Some of these previously finalized actions also revoked calendar year 2026 consumption allowances, and EPA redistributed consumption allowances that were revoked to consumption allowance holders that were not subject to a final administrative consequence effective September 29, 2023, or had an administrative consequence solely withholding allowances.
Accordingly, the Agency’s announcement of allowances includes the number of available application-specific, production, and consumption allowances as of October 1, 2025, for all eligible allowance holders due to finalized administrative consequences. More information is also available in the Federal Register notice to announce EPA’s issuance of calendar year 2026 allowances.
Application-specific Allowance Allocations for 2026
The figure and table below illustrate the application-specific allowances allocated to each entity for calendar year 2026. In the figure, click on an application (i.e., inner slice) to view all entities allocated allowances for that application along with their respective allowances. Click the inner circle again to return to the full figure. Hover over any slice to view the allowances allocated for that entity or application.
Distribution of Application-specific HFC Allowances for 2026
Application-specific HFC Allowances for 2026
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The allowances listed as available as of October 1, 2025 account for administrative consequences for certain entities that are effective on September 30, 2025. Additional details can be found in the Federal Register notice and on EPA’s administrative consequences webpage.
Distribution of 2026 HFC Allowances Set Aside for MDIs
Pursuant to the 2025 rule “Review and Renewal of Eligibility for Application-Specific Allowances,” (90 FR 41676, August 26, 2025) and 40 CFR 84.9(c), 84.11(c), and 84.15(h), EPA withheld 1,000,000 MTEVe of consumption and production allowances from all general pool allowance holders. These allowances were set aside to accommodate unforeseen HFC needs resulting from a global pandemic, other public health emergency, or other healthcare system need (referred to hereafter as the “MDI set-aside”). Entities that use HFCs as a propellant in MDIs had until April 30, 2026, to apply for these allowances. After that deadline, EPA was to evaluate such requests and issue allowances within 60 days. EPA’s intent, as outlined in the 2025 “Review and Renewal of Eligibility for Application-Specific Allowances,” was to distribute any remaining MDI set-aside allowances pro rata amongst general pool allowance holders within 60 days of the April 30, 2026, deadline. EPA received no applications for MDI set-aside allowances by the April 30, 2026, deadline. Therefore, EPA distributed the entire MDI set-aside pro rata to general pool allowance holders following the methodology that EPA established in the rule, “Phasedown of Hydrofluorocarbons: Allowance Allocation Methodology for 2024 and Later Years,” (88 FR 46836, July 20, 2023) on May 22, 2026.
EPA signed “Phasedown of Hydrofluorocarbons: Allocation of 2026 Production and Consumption Allowances Set Aside for Metered Dose Inhalers,” on May 22, 2026, to provide notice in the Federal Register of EPA’s allocation of MDI set-aside allowances to general pool production and consumption allowance holders for calendar year 2026. EPA published "Phasedown of Hydrofluorocarbons: Allocation of 2026 Production and Consumption Allowances Set Aside for Metered Dose Inhalers" in the Federal Register on May 27, 2026.
The tables for 2026 consumption and production allowances are updated to include the MDI set-aside allowances allocated to each entity for calendar year 2026, adjusted for administrative consequences and eligibility.
Consumption Allowance Allocations for 2026
The figures and table below illustrate the consumption allowances allocated to each entity for calendar year 2026. The first figure shows allowances for entities receiving greater than 0.5% of all consumption allowances and aggregates those entities receiving fewer than 0.5% of all consumption allowances. The second figure shows allowances for entities receiving less than 0.5% of all consumption allowances (i.e., those aggregated in the first figure). In the figures, hover over an entity (i.e., slice) to view its allowances. In the legend, double click on an entity to show only that entity in the pie chart. Click on an entity in the legend to hide it from the pie chart, and click it again to add it back.
Distribution of HFC Consumption Allowances for 2026, with Entities Receiving <0.5% Aggregated
Distribution of HFC Consumption Allowances for 2026, Showing Only Entities Receiving <0.5%
HFC Consumption Allowances Allocated and Available for 2026
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These values do not reflect allowances expended, transferred or conferred. The values reflect allowances available as of October 1, 2025, plus allowances allocated from the MDI set-aside and adjusted for administrative consequences for certain entities that became effective on September 29, 2023, and September 30, 2025. Additional details can be found in the Federal Register notice and on EPA’s administrative consequences webpage.
For more information on application-specific allowances, see Application-specific allowances allocated under 40 CFR 84.13.
Production for Export Allowance Allocations for 2026
EPA created a new form of allowances called “production for export allowances” in the 2025 Application-specific Allowance Review and Renewal Rule. In accordance with the provisions codified in that rule at 40 CFR 84.18, prior to issuing general pool production allowances, EPA allocated 3,000 MTEVe production for export allowances to Iofina Chemical.
Production Allowance Allocations for 2026
The figure and table below illustrate the production allowances allocated to each entity for calendar year 2026. In the figure, hover over an entity (i.e., slice) to view its allowances. In the legend, double click on an entity to show only that entity in the pie chart. Click on an entity in the legend to hide it from the pie chart, and click it again to add it back.
Distribution of HFC Production Allowances for 2026
HFC Production Allowances Allocated and Available for 2026
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For more information on application-specific allowances, see Application-specific allowances allocated under 40 CFR 84.13.
Frequent Questions on the Phasedown of HFCs
[1] Consumption is the amount of HFCs newly added to the U.S. market through production and import, minus exports and destruction.