On August 1, the U.S. Court of Appeals for the D.C. Circuit issued a closely watched decision upholding the EPA’s 2024 rule for distributing hydrofluorocarbon (HFC) “allowances” under the 2020 American Innovation and Manufacturing (AIM) Act. The AIM Act directs the EPA to regulate and reduce HFCs, a class of refrigerants used in air conditioning, refrigeration, fire suppression, solvents, foam blowing agents, and aerosols. HFCs are significant contributors to climate change, with global warming potentials hundreds or thousands of times greater than carbon dioxide, as determined by the Intergovernmental Panel on Climate Change and adopted by Congress and the EPA.

The AIM Act mandates an 85% reduction in HFC production and consumption in the United States by 2036. The EPA’s phasedown oper

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