Who Got the Allowances Your Supplier Lost?

If you buy bulk HFC, the ceiling on what your supplier may legally sell you in 2027 was set last Thursday. The AIM Act gives EPA until October 1 each year, and the notice files in tomorrow's Federal Register.

The national production cap did not move. It was 229,521,263 MTEVe for 2026 and it is 229,521,263 for 2027, because 2024 through 2028 are one flat step at 60% of baseline.

Four million allowances changed hands anyway.

"If the cap never moved, who took four million tonnes off the people who make the stuff?"

What Moved Inside a Flat Cap

Every holder of a general-pool production allowance came out of October 1 with 1.858% less than it held for 2026. Arkema, Chemours, Mexichem Fluor, Solstice Advanced Materials and Iofina Chemical, all cut by the same proportion.

That is 4,063,142.1 MTEVe off the producers' column. The application-specific column went up by 4,063,142.1.

The two match to the tenth of a tonne.

Where it went (chart below):

• Department of Defense, mission-critical military end uses: +2,913,156.7, up 47.3%
• Metered dose inhaler propellants, seven holders: +1,163,407.7, up 73.1%
• Marine and trailer structural foam: +6,816.1
• Semiconductors, the whole sector: -20,238.4

The fab buildout did not do this. Thirty-three semiconductor holders share 2,000,871.9 MTEVe for 2027, less than thirty-seven of them shared for 2026, and five names from last year's table (General Electric, Google, LA Semiconductor, Newport Corporation and UC San Diego) are gone.

The Pentagon's single line is 4.53x the whole semiconductor column and 3.95% of the national cap.