15 Pounds to Compliance: How the New EPA Threshold Affects Your Business
Starting January 1, 2026, EPA is lowering the refrigerant threshold from 50 pounds to just 15 pounds. If you thought your equipment was too small to be regulated, think again. This change captures tens of thousands of previously unregulated systems—including walk-in coolers, small rooftop units, and most commercial refrigeration equipment.
What Changed and Why It Matters
For decades, EPA regulations only applied to refrigeration and HVAC systems containing 50 pounds or more of refrigerant. This meant smaller equipment—like individual walk-in coolers, small rooftop AC units, and standalone refrigeration systems—flew under the radar.
Under the new Subpart C regulations effective January 1, 2026, that threshold drops to just 15 pounds for refrigerants with a Global Warming Potential (GWP) greater than 53. This captures the vast majority of HFC refrigerants including R-134a, R-404A, R-410A, and many others commonly used in commercial and industrial applications.
Is Your Equipment Now Regulated?
If you answered "yes" to any of these questions, you're likely affected:
- Do you have walk-in coolers or freezers?
Most walk-ins contain 15-50 lbs of refrigerant—now regulated
- Do you operate rooftop HVAC units?
Commercial rooftop units typically contain 20-40 lbs
- Do you have display cases or reach-in coolers?
Remote condensing units often have 15-30 lbs of refrigerant
- Do you have process cooling or chillers?
Small industrial chillers and process cooling systems now covered
- Do you operate ice machines or beverage dispensers?
Commercial ice machines and dispensers often meet the 15 lb threshold
Which Refrigerants Are Covered?
The 15-pound threshold applies to refrigerants with a GWP greater than 53. This includes virtually all common HFC refrigerants:
High GWP (Covered)
- • R-404A (GWP 3,922) - Supermarkets, cold storage
- • R-410A (GWP 2,088) - Residential/commercial AC
- • R-134a (GWP 1,430) - Commercial refrigeration
- • R-407C (GWP 1,774) - Commercial HVAC
- • R-448A (GWP 1,386) - Retrofit replacement
- • R-449A (GWP 1,396) - Retrofit replacement
Low GWP (NOT Covered)
- • R-744 (CO₂, GWP 1) - Not regulated
- • R-717 (Ammonia, GWP 0) - Not regulated
- • R-290 (Propane, GWP 3) - Not regulated
- • R-600a (Isobutane, GWP 3) - Not regulated
Note: Low-GWP alternatives are exempt from these requirements
What You're Now Required to Do
If your equipment meets the 15-pound threshold, you must comply with these requirements:
1. Calculate Leak Rate Every Time Refrigerant is Added
Use either annualized (12-month sum) or rolling average method. Must compare against threshold: 20% (commercial refrigeration), 30% (industrial process), or 10% (comfort cooling).
2. Repair Leaks Within 30 Days if Threshold Exceeded
If leak rate exceeds your equipment's threshold, you have 30 days to repair (120 days for industrial process requiring shutdown). Verification tests required.
3. Maintain Detailed Records for 3 Years
Document all refrigerant additions, leak rate calculations, repairs, and verification tests. Records must be kept for 3 years after equipment retirement.
4. Conduct Follow-Up Inspections
Quarterly inspections for systems with 500+ lbs refrigerant; annual inspections for 15-500 lbs systems. Continue until leak rate drops below threshold.
5. Report to EPA if Leak Rate Exceeds 125%
Annual report due March 1 if your leak rate exceeds 125% of full charge capacity in a year.
Industries Most Affected
The Cost of Ignoring This
EPA enforcement carries penalties up to $69,733 per violation per day. "I didn't know I was regulated" is not a valid defense.
Example: A restaurant with 3 walk-in coolers, each non-compliant for 90 days = potential fines exceeding $18.8 million.
How to Check if You're Affected
3-Step Quick Assessment:
- Step 1: Check your equipment nameplates
Look for "refrigerant charge" or "factory charge" - if it says 15 lbs or more, you're regulated
- Step 2: Identify the refrigerant type
Check if it's an HFC (R-134a, R-404A, R-410A, etc.) with GWP >53
- Step 3: Calculate your baseline leak rate
Use our free calculator to determine if you're currently compliant
Not sure if you're compliant? Use our free calculator to check your leak rate against the new thresholds.
Calculate Your Leak Rate NowWhat to Do Right Now
If you've just discovered you're newly regulated, here's your action plan:
- 1. Inventory all equipment with 15+ lbs of refrigerant (GWP >53)
Create a list with equipment type, location, refrigerant type, and charge amount
- 2. Establish a leak rate tracking process
Decide on calculation method (annualized vs. rolling average) and set up documentation system
- 3. Review past 12 months of refrigerant additions
Calculate baseline leak rates to identify any current non-compliance
- 4. Train your technicians on new requirements
Ensure anyone adding refrigerant understands documentation requirements
- 5. Consider automation
Manual tracking is error-prone and time-consuming—especially across multiple locations
Don't Get Caught Off Guard
RefriTrak automatically tracks all equipment—no matter the size. We calculate leak rates instantly, maintain 3-year records, and alert you before inspections are due. Get compliant in minutes, not months.