EPA Subpart C: Complete Compliance Checklist for January 1, 2026
On January 1, 2026, sweeping new EPA regulations under 40 CFR Part 84 Subpart C take effect for HFC refrigerants. Use this checklist to ensure your facility is ready for the new leak rate requirements, automatic leak detection mandates, and recordkeeping obligations.
What's Changing on January 1, 2026?
EPA's new Subpart C regulations dramatically expand refrigerant management requirements. The most significant change: equipment containing just 15 pounds of HFC refrigerant (with GWP >53) now requires leak rate tracking—down from the previous 50-pound threshold. This captures tens of thousands of previously unregulated systems.
Your Compliance Checklist
This includes supermarket systems, walk-in coolers, rooftop units, cold storage systems, and most commercial refrigeration equipment.
Only refrigerants with GWP >53 are regulated. Common HFCs like R-134a (GWP 1,430), R-404A (GWP 3,922), and R-410A (GWP 2,088) all qualify.
Check equipment nameplates or manufacturer specs. You'll need this for leak rate calculations.
Supermarkets, convenience stores, restaurants, grocery stores
Manufacturing facilities, chemical plants, industrial cooling systems
Office buildings, warehouses, refrigerated trucks, chillers
Required for every addition except retrofits, new installs, and seasonal variances.
Most facilities use annualized (sum of 12 months). Must be consistent.
Records must be kept for 3 years after equipment retirement.
These require automatic leak detection (ALD) systems.
Any new systems with 1,500+ lbs must have ALD upon installation.
You have one year to retrofit existing large systems.
120 days allowed if industrial process shutdown required.
Confirms leak was successfully repaired.
Second verification required shortly after initial test.
Quarterly for 500+ lbs systems, annually for 15-500 lbs systems.
If your leak rate exceeds 125% of full charge in a year, EPA reporting required.
Annual report must be submitted by March 1 each year.
Common Compliance Mistakes to Avoid
- ❌ Assuming only 50+ lb systems are regulated (new threshold is 15 lbs)
- ❌ Using old Section 608 thresholds (35%/10%) instead of new Subpart C thresholds (20%/30%/10%)
- ❌ Not calculating leak rate after every refrigerant addition
- ❌ Forgetting about 1,500+ lb ALD requirement deadline (Jan 1, 2027 for existing equipment)
- ❌ Poor recordkeeping that won't survive an EPA audit
Use our free leak rate calculator to determine if your equipment meets compliance thresholds.
Try Free CalculatorThe Cost of Non-Compliance
EPA enforcement of Subpart C violations carries penalties up to $69,733 per violation per day. For a facility with multiple non-compliant systems, fines can accumulate rapidly. Beyond financial penalties, violations can trigger operational shutdowns, legal liability, and reputational damage.
Automate Your Compliance
Managing Subpart C compliance manually across multiple locations and equipment types is time-consuming and error-prone. RefriTrak automatically calculates leak rates every time refrigerant is added, tracks required inspections, schedules ALD installations, maintains 3-year records, and generates EPA-compliant reports—keeping you audit-ready 24/7.
Ready for January 1, 2026?
RefriTrak automates every item on this checklist. Stop worrying about deadlines, calculations, and recordkeeping—let us handle compliance while you focus on your business.