Operation: Disrupt HFCs

What are HFCs?

Hydrofluorocarbons (HFCs) are potent greenhouse gases characterized with high global warming potential. HFCs are commonly utilized as refrigerants, aerosol propellants, foam blowing agents, solvents, and fire retardants across residential, commercial, and industrial applications. The major source of HFC emissions is their use as refrigerants—for example, in air conditioning systems in both vehicles and buildings. Emissions occur during manufacturing, as well as through leaks, servicing, and disposal of equipment containing HFCs.

The American Innovation and Manufacturing (AIM) Act  of 2020 directs EPA to address HFCs in three main areas:

Phase down the production and consumption of listed HFCs in the United States by 85% by 2036
Manage these HFCs and their substitutes, and
Facilitate the transition to next-generation technologies that do not rely on HFCs.

Operation: Disrupt HFCs

EPA’s criminal enforcement program, the Office of Criminal Enforcement, Forensics and Training (OCEFT) is working with the Interagency Task Force on Illegal HFC Trade to protect American innovation, strengthen domestic manufacturing, and support lawful supply chains. Border security, preventing illegal imports, and ensuring a level playing field for United States manufacturing companies is an administration priority.

OCEFT has partnered with personnel at the EPA, Customs and Border Protection, Homeland Security Investigations, and Department of Justice to enhance awareness and enforcement of illegally imported HFCs. This Operation has substantially increased the number of criminal cases initiated, leading to charges against numerous defendants for smuggling HFCs into the United States. The EPA’s criminal enforcement program remains committed to working alongside its law enforcement and regulatory partners to identify and prosecute criminal organizations involved in the illegal importation of HFCs.

Enforcement results related to this initiative are underway. For example:

In March 2024, CBP detained, and the DOJ charged a person with smuggling HFCs, a potent greenhouse gas, into the United States from Mexico and then selling them for profit, in violation of regulations intended to curb the use of greenhouse gases and slow climate change. This is the first prosecution in the United States to include charges related to the AIM Act. (Read DOJ Press Release.)

Mitigating Climate Change National Enforcement and Compliance Initiative

EPA focuses its enforcement and compliance assurance resources on the most serious environmental violations by developing and implementing national program priorities called National Enforcement and Compliance Initiatives (NECIs). On August 17, 2023, EPA’s Office of Enforcement and Compliance Assurance (OECA) announced its selection of six priority areas as the National Enforcement and Compliance Initiatives (NECIs) for Fiscal Years 2024-2027.

For the first time, EPA created a NECI to address climate change. The “Mitigating Climate Change” NECI will address three separate and significant contributors to climate change:

Methane emissions from oil and gas facilities;
Methane emissions from landfills; and
Use, importation, and production of HFCs.

The EPA’s National Enforcement and Compliance Initiative: Mitigating Climate Change webpage provides information on HFC enforcement efforts taken under the initiative.

EPA Information Resources

On September 6, 2024, EPA issued an AIM-related enforcement alert entitled “EPA Targeting Illegal Imports of Hydrofluorocarbon Super-Pollutants to Combat Climate Change”. The alert provides information on common compliance issues related to the import of bulk HFCs and highlights recent civil and criminal enforcement actions. It also discusses climate change mitigation efforts, and is intended to help companies comply with the law by taking the steps necessary to avoid potential EPA enforcement actions.

More information related to HFCs, the AIM Act, and the Mitigating Climate Change National Enforcement and Compliance Initiative are available on EPA’s website: 