HFC Phasedown: AIM Act Export Bans, Kigali Trade Restrictions & Illegal Trade Risks
The AIM Act bans U.S. HFC exports to countries lacking comparable phasedown rules (effective 2023), while the Kigali Amendment requires parties to ban HFC trade with non-ratifying countries by 2033; Congress is weighing oversight of EPA/CBP enforcement against illegal HFC trade and misreporting of pre-charged equipment. EPA issued a May 2026 final rule extending compliance deadlines for select sectors, and the One...
What changed
Congressional Research Service published a research or oversight record: The AIM Act bans U.S. HFC exports to countries lacking comparable phasedown rules (effective 2023), while the Kigali Amendment requires parties to ban HFC trade with non-ratifying countries by 2033; Congress is weighing oversight of EPA/CBP enforcement against illegal HFC trade and misreporting of pre-charged equipment. EPA issued a May 2026 final rule extending compliance deadlines for select sectors, and the One.
Procedural posture
This is background, analysis, or oversight material and does not itself impose a binding import, export, or sanctions obligation.
Affected scope
HS scope: 29, 84, 85; countries: US; instruments: AIM Act, Kigali Amendment, Montreal Protocol
Practical impact
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Source limits
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