EPA v. CARRIER INTERAMERICA CORP.

Case summary

EPA Recommendation for Denial: 11/06/2025 EPA Recommendation for Denial of Entry #231-34587713: Items containing HFCs (Items) Imported by Carrier InterAmerica Corp. ( Importer ), Docket No. AIM-04-2026-8800 The U.S. Environmental Protection Agency has reviewed the above-referenced entry, identified as Entry #231-34587713, and by this letter recommends that the U.S. Customs and Border Protection (CBP) deny entry of the items in this shipment containing hydrofluorocarbons (HFCs) imported by Carrier InterAmerica Corp. (Importer). This letter summarizes the applicable law and sets forth the basis for the EPA's recommendation for denial of entry and determination that the Importer has violated the American Innovation and Manufacturing Act ( AIM Act ). The AIM Act provides the EPA with the authority to regulate HFCs by: (1) phasing down production and consumption; (2) maximizing reclamation and minimizing releases from equipment; and (3) facilitating the transition to next-generation technologies through sector-based restrictions. The EPA regulations at 40 C.F.R. Part 84, Subpart B ( Technology Transitions Rule ) implement the AIM Act requirement to facilitate the transition to next-generation technologies. The Technology Transitions Rule includes requirements for importers of products and systems that utilize HFCs. Starting January 1, 2025, with phased implementation running through January 1, 2031, companies in various industries are prohibited from importing items containing HFCs with Global Warming Potentials ( GWPs ) above specified limits. These products typically include Refrigeration, Air Conditioning, Heat Pump ( RACHP ) products, aerosols with HFCs as propellants, and foams produced using HFC as a blowing agent. The Technology Transitions Rule at 40 C.F.R. 84.54(a) provides that, starting January 1, 2025: No person may manufacture or import any product in the following sectors or subsectors that use a regulated substance as listed in this paragraph. Basic components of RACHP items used to assemble larger RACHP systems may continue to be imported to ensure appropriate replacements parts are available to service existing equipment; however, importation of specified components are subject to certain labeling requirements. Self-contained RACHP products containing regulated substances or blends of regulated substances exceeding the GWP are prohibited from importation following the import compliance date applicable to the subsector. The Technology Transitions Rule then identifies 16 sectors or subsectors of products which are restricted, and the associated GWP limit for each type of product. Information on these sectors/subsectors, their associated compliance dates and applicable GWP limits may be found on EPA's website at: https://www.epa.gov/climate-hfcs-reduction/technology-transitions-hfc-restrictions-sector. The term regulated substance shares the definition found in the HFC Allocation Regulations at 40 C.F.R. 84.36 which defines a regulated substance to mean: [A] hydrofluorocarbon listed in the table contained in subsection (c)(1) of the AIM Act and a substance included as a regulated substance by the Administrator under the authority granted in subsection (c)(3). A current list of regulated substances can be found in Appendix A to 40 C.F.R. Part 84. Based on the facts discussed below in Table 1 (Enclosure), the EPA has determined that the Subject Items are products and/or specified components regulated by the Technology Transitions Rule, which contain regulated substances with GWPs above the allowable limit. By importing the Subject Items after the applicable import compliance date, the Importer has violated the Technology Transitions Rule regulations at 40 C.F.R. 84.54(c) and 84.54(f). Therefore, the EPA recommends that CBP deny entry of the shipment identified as Entry #231-34587713.

Defendants (1)

• CARRIER INTERAMERICA CORP.Named in settlement

Facilities (1)

• CARRIER INTERAMERICA CORPORATION

  10801 NW 103RD STREET, MIAMI, FL, 33178

  Registry ID: 110061279343

Statutes cited

• AIM PART84 — Phasedown of Hydrofluorocarbons

Enforcement conclusions (1)

• CARRIER INTERAMERICA CORP.entered 2025-11-06

  Primary law: AIM

Timeline (3 milestones)

• 2025-11-06Enforcement Action Closed
• 2025-11-06Final Order Issued
• 2026-09-28Enforcement Action Data Entered