RefriTrak Now Generates EPA Compliance Documents Automatically

Chronic Leaker Annual Reports — All 12 Required Elements, Auto-Populated

Under §84.106(j), if an appliance triggers the chronic leaker threshold, you're required to submit an annual report to the EPA by March 1 of the following year. That report must include twelve specific data elements defined in §84.106(m)(4) — everything from facility details and appliance specifications to full-charge amounts, leak rates, refrigerant addition records, and verification test dates.

Manually assembling that information from service records, spreadsheets, and memory is where mistakes happen. And mistakes on EPA filings carry real consequences.

RefriTrak's Chronic Leaker Annual Report feature pulls directly from the data you've already entered: facility information, equipment details, refrigerant transfer history, calculated leak rates, and verification test dates. The report pre-fills automatically. You just need to add three things that only a human can provide: the cause of refrigerant losses, a narrative of repair actions taken, and the current status of any retrofit or retirement plan.

Once complete, you capture a digital signature from the authorized company official, and RefriTrak generates two outputs:

• An EPA-ready Excel file formatted to the official HAWK template (form 3520-36) that you can upload directly to the EPA's CDX portal.
• A PDF copy for your internal compliance records.

After you submit to the EPA, you record your CDX confirmation ID back in RefriTrak to complete the audit trail — from leak detection through reporting and confirmation.

Repair Extension Requests — Deadlines Computed, Leaks Categorized

Sometimes repairs can't be completed within the standard 30-day window (or 120 days for industrial process refrigeration). Section 84.106(f) allows you to request an extension, but only for specific reasons, and the paperwork requires careful deadline math and leak-by-leak documentation.

RefriTrak's new Repair Extension Request feature walks you through the process. You select from the four EPA-recognized extension reasons under §84.106(f)(1) — the system provides guidance on each so you choose correctly. RefriTrak then auto-computes every relevant deadline: when the original repair period expires, when the extension would expire (up to 180 or 270 days depending on equipment type), and when your request must be submitted.

Like the chronic leaker report, the extension request includes digital signature capture and generates an EPA-ready Excel file using the official HAWK template (form 3520-38). You can also save drafts as you work — no need to complete everything in one sitting.

Reports Hub — All Your Compliance Documents in One Place

RefriTrak's Reports page includes two sections:

Built for EPA's HAWK Portal — Not Just Close Enough

This is the detail that matters most. RefriTrak doesn't generate generic spreadsheets that look similar to EPA forms. The Excel files we produce use the exact official EPA HAWK templates — form 3520-36 for chronic leaker reports, form 3520-38 for repair extensions. Every dropdown value, every field format, every validation requirement matches what the CDX system expects.

That means no reformatting, no copy-pasting between documents, and no rejected submissions because a dropdown value didn't match EPA's list. You download the file from RefriTrak and upload it to HAWK. The workflow also includes built-in guidance for the CDX submission process itself, so even if it's your first time filing through the EPA's portal, you'll know exactly what to do.

How EPA Compliance Document Generation Works

Refrigerant Compliance Without a Dedicated Compliance Team

The AIM Act raised the bar for refrigerant management documentation. These aren't optional reports — they're legal obligations with deadlines and specific formatting requirements. But most HVAC contractors don't have a dedicated compliance team. They have technicians in the field and an office manager juggling everything else.

RefriTrak bridges that gap. Your refrigerant tracking data — every transfer, inspection, and repair — feeds directly into the documents the EPA requires. You stay focused on your customers while staying fully compliant. If you're still evaluating compliance software, our comparison of refrigerant compliance tools for 2026 covers what to look for.