The EPA has issued its Fire Suppressant Recycling Under the HFC Allocation Program Questions and Answers Fact Sheet dated May 2023. It provides guidance regarding when a company is considered an HFC Fire Suppressant Recycler, and its reporting obligations under the AIM Act. This guidance was first requested by FSSA in March 2022. A key provision in the fact sheet:

Who qualifies as an HFC fire suppressant recycler?

• An entity that collects used HFC fire suppressants and directly resells those collected and aggregated HFCs—with or without any additional reprocessing—to another entity for reuse as a fire suppressant would qualify as a fire suppressant recycler (also referred to as a “recycler for fire suppression” in 40 CFR part 84, subpart A).
• An entity that collects and aggregates used HFC fire suppressants for distribution to another entity for reprocessing before being sold for reuse as a fire suppressant would not be a fire suppressant recycler.
• An entity reselling HFC fire suppressants that have already been reprocessed for use as a fire suppressant by another entity would not be a fire suppressant recycler.

The fact sheet is located here.

Any questions should be directed to Luke Hall-Jordan at the EPA: [email protected].