The American Innovation and Manufacturing (AIM) Act

We would like the industry to be aware that there are new EPA reporting requirements as a result of The American Innovation and Manufacturing (AIM) Act. This was enacted by Congress on December 27, 2020. EPA will require allowances for all bulk imports of HFCs (regardless of size) beginning January 1, 2022. Please see the below link for FAQ’s regarding imports and to find further information:
Of note, however, is the requirement:
Import Notification
: Notification of imported shipments 14 days prior to the date of import provided via a Customs and Border Protection (CBP)-authorized electronic data interchange system, such as the Automated Broker Interface’
We have attended webinars to understand this rule and the reporting is to be done via the ACE Entry or Entry Summary Certified for Cargo Release process 14 days prior to importation. They indicated that this information can be provided via the PGA/EPA/ODS message set in combination with DIS.
Below is the required information per 40 CFR 84.31(c)(17)
  • Cargo Description
  • Quantity of Unit of Measure
  • Weight and Unit of Measure
  • Port of Entry
  • Scheduled Entry Date
  • HTS Code and Description
  • Origin Country
  • Importer Name and Importer Number
  • Consignee Entity Name
  • CAS Number(s) of the HFC(s) imported and, for HFCs that are a mixture, either the ASHRAE numerical designation of the refrigerant or the percentage of the mixture containing each HFC
  • If Importing HFCs for transformation or destruction, a copy of the non-objection notice issued consistent with §84.25
  • If Importing HFCs as a transshipment, a copy of the confirmation documenting the importer reported the transshipment consistent with §84.31(c)(3)(i)
note
The HTS numbers that will flag for this requirement are in the below link. These are new HTS numbers for 2022, so they will not directly correlate to existing HTS numbers, so please ensure you are checking to see if you will be impacted by this new requirement:
Finally, there has been no guidance provided for FTZ’s at this time. We have requested information and EPA advised they would provide and post additional information to their site. That can be found here: