The Rule That Already Took Effect
On January 1, 2026, the EPA’s expanded refrigerant leak management requirements took effect under 40 CFR Part 84 Subpart C. If you operate commercial refrigeration or cooling equipment with a refrigerant charge of 15 pounds or more, and your refrigerant has a Global Warming Potential (GWP) greater than 53, you are now subject to federally mandated leak detection, repair, and recordkeeping requirements.
This is not a future compliance date. It is already in effect.
If you have not reviewed your leak monitoring and repair procedures since January 2026, do it now. The requirements are not onerous for well-maintained equipment, but facilities that are not tracking leak rates or maintaining records are currently out of compliance.
Primary source: 40 CFR Part 84 Subpart C, Section 84.106 — EPA Refrigerant Management Rule
What Changed and Why
Historically, the EPA’s refrigerant leak management rules mainly applied to ozone-depleting substances — CFC and HCFC refrigerants like R-22. HFC refrigerants such as R-410A, R-134a, and R-404A were widely used but not subject to the same mandatory leak repair framework.
The 2026 rule changes that. Under the AIM Act authority, the EPA extended similar requirements to the most common HFC refrigerants. The reasoning is straightforward: HFCs are potent greenhouse gases, and refrigerant leaks represent a meaningful portion of their climate impact. Leak management is one of the most cost-effective ways to reduce HFC emissions from existing equipment.
Does Your Equipment Fall Under This Rule?
Your equipment is covered if it meets both of these thresholds:
| Threshold | Value | Notes |
|---|---|---|
| Refrigerant charge | 15 pounds or more | Total charge in the system, not the amount leaking |
| Refrigerant GWP | Greater than 53 | Nearly all common HFC refrigerants exceed this threshold |
R-410A has a GWP of 2,088. R-404A has a GWP of 3,922. R-134a has a GWP of 1,430. R-32 has a GWP of 675. All are well above 53. The 53 threshold is deliberately set to exclude only a narrow set of very low-GWP refrigerants.
In practical terms: most commercial chillers, process cooling systems, and large refrigeration systems with 15 pounds or more of charge are covered by this rule.
What the Rule Requires
Leak Rate Monitoring
You must track the annual leak rate of covered systems. The EPA calculates leak rate as the amount of refrigerant added over 12 months divided by the full charge, expressed as a percentage. Systems that exceed certain thresholds trigger mandatory action.
Mandatory Leak Repair
If your system exceeds the applicable leak rate threshold, you must identify the source of the leak and complete repairs. The timeline is strict:
Repairs must generally be completed within 30 days of determining the leak rate was exceeded. If a system shutdown is required, the timeline can be extended — but this requires documentation. Allowing known leaks to persist without action or documentation is a compliance violation.
- Identify the source of the leak
- Complete repairs within 30 days
- Verify repairs have been completed
- Use EPA-certified technicians for all refrigerant handling
Recordkeeping Requirements
You must maintain records of:
- The amount of refrigerant added to each covered system at each service event
- The date refrigerant was added
- Leak inspections and their outcomes
- Repair actions taken and verification that repairs were completed
- Technician certifications for anyone handling covered refrigerants
Records must be kept for at least three years and must be available for EPA inspection on request.
Five Steps to Get Into Compliance Now
Inventory Your Systems
List every covered refrigeration and cooling system at your facility. Document the refrigerant type, total charge in pounds, and GWP. This baseline is the foundation for everything else.
Pull Refrigerant Addition Records
Ask your service contractor for records of refrigerant additions over the past 12 months for each covered system. If your contractor has not been recording this, start the tracking now and build backward where possible.
Calculate Your Leak Rates
Divide the refrigerant added per system over 12 months by the full charge. Any systems running at elevated rates are your highest-priority repair targets.
Confirm Technician Certifications
Anyone handling covered HFC refrigerants must hold appropriate EPA Section 608 certification. Verify your service contractors hold current certifications for the refrigerant types in your equipment.
Establish Ongoing Recordkeeping
Set up a simple log — even a spreadsheet — that captures refrigerant additions, dates, technician information, and any leak investigation or repair work for each covered system going forward.
The Connection to the Refrigerant Transition
If this rule feels connected to the broader refrigerant transition described in the companion article on the AIM Act, that is because it is. The same regulatory framework driving the shift away from R-410A in new equipment is also tightening leak management requirements for HFCs still in service.
For facility operators, the next few years involve two parallel compliance tracks: managing existing HFC equipment under the new leak rules, and planning for the refrigerant transition when that equipment is eventually replaced.
Official Sources
- The rule itself: 40 CFR 84.106 — Leak Repair Requirements
- Full subpart: 40 CFR Part 84 Subpart C
- EPA fact sheet: search “EPA refrigerant management rule 2026 fact sheet” on epa.gov
Note: Regulatory requirements can change and vary by application. This article summarizes the federal rule as written. Consult an environmental compliance specialist or qualified engineer for guidance specific to your facility.
Related: Why Chiller Manufacturers Are Switching Refrigerants — the AIM Act and the A2L Transition ›
Questions About Your Chiller and Compliance?
AG Chill engineers can walk through how your system is affected and what steps make sense for your operation.