Written on: December 1, 2025 by Nicholas Georges
This past year has brought a new wave of reporting obligations for companies, largely due to the implementation of Extended Producer Responsibility (EPR) laws across the U.S. Companies must now report annually to Circular Action Alliance (CAA)i for covered products in Oregon,ii Coloradoiii and Californiavi—with more States expected to follow suit.v However, EPR is not the only area where new reporting obligations are emerging. Additional requirements are on the horizon for 2026 that companies should keep in mind.
Next year, companies will face two new reporting obligations, both beginning on March 31, 2026. The first applies to the U.S. Environmental Protection Agency (EPA) for the Technology Transitions regulation under the American Innovation & Manufacturing (AIM) Act.vi The second was initiated by the New York State Dept. of Environmental Conservation (NYSDEC), and requires reporting beyond Hydrofluorocarbons (HFCs) under Part 494, Hydrofluorocarbon Standards & Reporting.vii
Under the Technology Transitions regulation—which restricts the use of HFCs with a global warming potential (GWP) greater than 150 in most aerosol products—the EPA now requires annual reporting from manufacturers and importers of covered products and equipment. Please note that the GWP restriction for technical aerosols does not take effect until Jan. 1, 2028, but these products still need to be included in 2026 reporting. For reporting purposes, the “manufacturer” is defined as the company listed on the product label.
Reports must be submitted to the EPA within 90 days of the end of each calendar year, with the initial report covering 2025 data. The scope includes the 18 HFCs listed under the AIM Act, such as HFC-152a.viii While most aerosol products containing HFCs will be subject to these reporting obligations, certain products are excluded, including metered dose inhalers (MDIs) and defense sprays.
The EPA has indicated plans to host webinars and other stakeholder engagement sessions once the reporting tool is ready. The timing of these trainings is unknown as we go to print because of the U.S. Federal Government shutdown.
The original Part 494 regulation, adopted in 2020, focused primarily on HFCs. However, the 2024 amendments significantly broadened the scope and may now apply to additional companies, even those that don’t use HFCs in their products.
While the original regulation drew requirements from the EPA’s Significant New Alternatives Policy (SNAP) Rules 20 and 21,ix, x the amended rule goes beyond the restrictions imposed by the Technology Transitions regulation. For aerosol products, the amended Part 494 regulation restricts any substance with a GWP above 10, measured over a 20-year timeframe (compared with the 100-year timeframe used in the AIM Act), starting on Jan. 1, 2034. This includes substances other than HFCs, including hydrofluoroolefins (HFOs) and even hydrocarbons. While efforts are underway to modify or roll back some of these upcoming restrictions, companies should still be thinking about how these restrictions may impact their products.
Regarding reporting obligations in New York, suppliers of products and equipment containing substances with a GWP greater than 10 (under the 20-year timeframe) will be required, starting in 2026, to report the total quantities supplied within the State. As of the writing of this column, the reporting tool is not yet available. However, the Household & Commercial Products Association (HCPA) remains engaged with NYSDEC and will provide member companies with information as it’s released.
Although both reports are due on the same day and initially target HFCs, it is important to recognize that the substances and data that companies report on next year may differ depending on their product portfolio.
HCPA continues to engage with both the EPA and NYSDEC to clarify regulatory requirements and advocate for reporting tools that are practical and accessible, ensuring that aerosol manufacturers and marketers may fulfill their obligations efficiently.
To participate in these discussions directly, or if you have any questions, please contact me at [email protected]. SPRAY
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ii Initial reports were due March 31, 2025
iii Initial reports were due July 31, 2025
vi Initial reports were due Nov. 15, 2025
v CAA will require initial reports in May 2026 for Maine; however, companies need to also be aware of additional state registration obligations coming in 2026 as well.
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viii 42 U.S. Code § 7675(c)(1)
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