State-by-State HFC Regulations for Multi-State HVAC Contractors (2026)

The Federal Baseline — What AIM Act (40 CFR Part 84) Requires Everywhere

The American Innovation and Manufacturing (AIM) Act, implemented through 40 CFR Part 84, establishes refrigerant management requirements that apply in every state. As of January 1, 2026, those requirements extend to any appliance containing 15 pounds or more of an HFC refrigerant (or a substitute refrigerant) with a Global Warming Potential greater than 53. Prior to 2026, the threshold was 50 pounds.

Federal requirements that apply to every state (15 lb threshold, effective January 1, 2026):

Leak rate monitoring and calculation — annual leak rate must be tracked per 40 CFR § 84.105
Repair thresholds — 10% for comfort cooling, 20% for commercial refrigeration, 30% for industrial process refrigeration (§ 84.105(b))
30-day repair window — leaks exceeding thresholds must be repaired within 30 days of detection (§ 84.105(c))
Chronic leaker reporting — systems that fail a follow-up verification test must be reported to EPA (§ 84.106(j))
3-year recordkeeping — service records, leak inspections, and repair documentation must be retained
Reclaimed refrigerant requirements — certified reclaimed HFCs must meet AHRI-700 purity standards

These requirements apply uniformly in all 50 states. They are the floor, not the ceiling. Several states have enacted rules that go further — imposing lower charge thresholds, equipment-specific refrigerant prohibitions, annual registration fees, or mandatory leak detection systems that federal law does not require.

Why States Go Beyond the Federal Floor

Several structural factors drive states to act independently of federal HFC rules:

•State climate plans — states with legislated greenhouse gas reduction targets (California, New York, Washington, and others) must reduce HFC emissions to meet their own statutory commitments, independent of federal schedules.
•Narrow preemption under the AIM Act — unlike some federal environmental statutes, the AIM Act does not broadly preempt state regulation. States retain authority to impose stricter requirements on HFC use, equipment prohibitions, and reporting as long as they are not in direct conflict with federal rules.
•Sector-specific programs — California's Refrigerant Management Program was built around commercial refrigeration (supermarket racks, industrial systems) that federal SNAP rules initially addressed at the facility level; the state added its own annual reporting infrastructure years before the federal threshold dropped.
•US Climate Alliance coordination — many of the adopting states are members of the US Climate Alliance and deliberately aligned their rules with California's program or EPA's SNAP Rules 20 and 21, creating a de facto multi-state overlay layer that travels together.

State-by-State Quick Reference Matrix

Currency disclaimer

State HFC regulations change frequently — sometimes on accelerated legislative timelines. The information below reflects publicly available rules as of June 2026. Verify current requirements directly with the relevant state agency before making installation or equipment decisions. Agency URLs are listed in each state's detail section below.

State	Key overlay rules	Applies to	Enforcement agency	Contractor action
California	RMP (≥200 lb reporting); SB 1013 / Title 17 HFC prohibitions; R4 reclaim program	Commercial/industrial refrigeration systems; specific equipment categories	CARB	Annual R3 registration/reporting; California service record format; R4 reclaim chain of custody
New York	Part 494: bulk refrigerant GWP ban (>2,200); equipment phase-out dates; automatic leak detection for large systems	All refrigerant users; large refrigeration operators; equipment manufacturers	NY DEC	Verify refrigerant GWP before sourcing; auto leak detection for systems >1,500 lb; check install-date-driven equipment deadlines
New Jersey	N.J.A.C. 7:27E GHGMRR: registration + annual reporting for ≥50 lb high-GWP systems; A-5583 equipment prohibitions	Refrigeration systems and chillers with ≥50 lb of refrigerant with GWP ≥ 150	NJ DEP	Register systems within 90 days of install; file annual April 1 refrigerant report; verify replacement refrigerant against NJ prohibition list
Washington	WAC 173-443: GWP ≤150 limit on new stationary equipment; refrigerant management program for large systems	New stationary refrigeration and AC equipment; large system operators and contractors	WA DOE (Ecology)	Only spec refrigerants with GWP ≤150 for new/retrofit installs; register large systems; report within 120 days of restriction dates
Connecticut	No state-specific HFC rules adopted as of mid-2026; federal AIM Act floor applies	All systems ≥15 lb (federal)	EPA (federal)	Federal compliance only; monitor CT DEEP for pending rulemaking
Maryland	COMAR 26.11.33: adopts EPA SNAP Rules 20 & 21 prohibitions; HFC supply restrictions from 2024; equipment prohibitions from 2025	Refrigeration, commercial AC, foam products, aerosol propellants in covered end-uses	MD MDE	Verify replacement refrigerant is not on MD prohibition list; confirm equipment was manufactured before prohibition date if using older stock

Detailed State-by-State Breakdown

🌴 California

California has the most comprehensive state-level refrigerant regulatory framework in the country, operated through the California Air Resources Board (CARB). Three distinct programs affect HVAC/R contractors working in the state.

Refrigerant Management Program (RMP) — Title 17 CCR § 95380 et seq.

The California RMP requires businesses that own or operate stationary refrigeration or air conditioning equipment to register their systems and submit annual reports through CARB's Refrigerant Registration and Reporting System (R3). The annual reporting threshold is facilities whose largest system has a full charge capacity of 200 pounds or more. Systems with the largest full charge of 2,000 pounds or more are subject to a higher annual fee tier. Reports are due by March 1 of each year and must include service records: dates leaks were detected, causes, and repair completions.

HFC Prohibitions — SB 1013 (2018) and Cal. Code Regs., tit. 17, §§ 95371 et seq.

California's Cooling Act (SB 1013) and associated CARB regulations, effective January 1, 2019, prohibit the use of specific high-GWP HFCs in new stationary equipment. The prohibitions adopt and in some categories go beyond EPA SNAP Rules 20 and 21. Refrigerants such as R-404A (GWP 3,922) and R-507 (GWP 3,985) are banned for new stationary supermarket systems and cold-storage equipment. The 2020 CARB amendment added GWP limits for additional equipment categories to accelerate the transition to lower-GWP alternatives beyond the initial prohibitions.

R4 Program — Recovery, Recycle, Reclaim, and Reporting

Contractors who recover refrigerant in California must track the entire chain of custody through CARB's R4 program. This means documenting recovery quantities, sending refrigerant to a licensed California reclaimer, and maintaining records that tie refrigerant recovered on-site to a specific appliance, technician, and reclaim facility. This is a more detailed chain-of-custody requirement than federal rules impose.

What a contractor should do differently in California

• Register customer facilities with 200+ lb systems in CARB's R3 system, or confirm the facility owner has done so
• Use California-specific service record formats that capture leak detection date, cause, and repair completion
• Maintain R4 chain-of-custody documentation from recovery through reclaim for every service call
• Verify every replacement refrigerant against California's current prohibition list (SB 1013 / Title 17 CCR)
• Annual facility reports are due March 1 — build this into your customer service calendar

Source: CARB Refrigerant Management Program

🗽 New York

New York's Department of Environmental Conservation (NY DEC) adopted an amended Part 494 regulation that took effect January 9, 2025 (filed December 10, 2024; published December 24, 2024). Part 494 is one of the most aggressive state refrigerant rules in the country, combining bulk refrigerant restrictions, equipment phase-out schedules, and leak detection mandates.

Bulk refrigerant GWP ban

Effective January 9, 2025 (with enforcement delayed to April 9, 2025 for existing stock), the sale and distribution of bulk refrigerants with a GWP100 exceeding 2,200 is prohibited in New York State. R-404A and R-507A — the two most common commercial refrigeration refrigerants — are specifically called out; a further delay on the enforcement of their bulk sale ban extends through December 31, 2025. After that date, sourcing these refrigerants within New York State becomes illegal.

Equipment prohibitions with phase-in dates

Beginning January 1, 2026, new supermarket and cold-storage refrigeration systems with a charge capacity of 50 pounds or more are prohibited from using refrigerants with a GWP20 greater than 580. By January 1, 2027, certain heat pump water heaters face similar restrictions. The most far-reaching deadline is January 1, 2034, when residential and light commercial HVAC equipment and heat pumps will be prohibited from using refrigerants with a GWP20 greater than 10 — a threshold that eliminates all current R-32 and A2L refrigerant alternatives for those categories.

Automatic leak detection

Large refrigeration equipment with a charge exceeding 1,500 pounds requires an automatic leak detection system to be installed. Initial installations were required by June 2025.

What a contractor should do differently in New York

• Do not source R-404A or R-507A through New York distribution after December 31, 2025 — source from other states or use reclaimed refrigerant if available
• Check GWP20 before quoting refrigerant for any supermarket or cold-storage replacement with ≥50 lb charge capacity (limit: 580 GWP20 as of January 1, 2026)
• Install automatic leak detection on any system above 1,500 lb charge if not already present
• Begin planning equipment upgrade pathways for residential/commercial AC customers ahead of the 2034 GWP20 limit

Source: NY DEC HFC Regulations

🌿 New Jersey

New Jersey operates two distinct regulatory tracks for HFCs: equipment prohibitions under statute A-5583 and a monitoring and reporting program under N.J.A.C. 7:27E.

Equipment prohibitions — A-5583 aligned with EPA SNAP Rules 20 and 21

New Jersey enacted A-5583, which mirrors EPA SNAP Rules 20 and 21 prohibitions on specific HFCs in stationary refrigeration and air conditioning end-uses. For example, high-GWP refrigerants in new supermarket refrigeration systems have been prohibited since July 1, 2020. The prohibition covers the same equipment categories as the federal SNAP program.

Greenhouse Gas Monitoring and Reporting Rule — N.J.A.C. 7:27E, Subchapter 2

Enacted in June 2022, New Jersey's GHGMRR imposes registration and annual reporting requirements on facilities with refrigeration systems or chillers that contain 50 pounds or more of a high-GWP refrigerant (defined as GWP ≥ 150 on a 100-year basis). Comfort-cooling air conditioning systems are exempt unless they use a chiller. The requirements include:

Registration: $400 fee for a 5-year registration period; existing systems registered by October 1st of the applicable year; newly installed systems must register within 90 days of installation through NJDEP Online.
Annual reporting: Reports due by April 1 each year, covering refrigerant types and quantities purchased, amounts charged into systems, refrigerant recovered, inventory on hand, and quantities sent for reclamation or destruction.
First reporting year: October 1, 2022 (or installation date for newer systems); subsequent reports cover January 1–December 31 calendar years.

What a contractor should do differently in New Jersey

• For every new installation ≥50 lb of a GWP≥150 refrigerant: notify the facility owner that NJDEP registration is required within 90 days
• Track refrigerant quantities with enough detail to support the April 1 annual report: type purchased, amount charged in, amount recovered, end-of-year inventory
• Verify any replacement refrigerant is not on the A-5583 prohibition list before quoting supermarket or cold-storage work
• Note: standalone AC units are generally exempt unless they use a chiller configuration

Source: NJ DEP GHGMRR Refrigeration

🌲 Washington

Washington State's Department of Ecology adopted Chapter 173-443 WAC (Hydrofluorocarbons), which took effect January 31, 2024. The rule is structured around two main components: use restrictions on new equipment and a refrigerant management program for large existing systems.

GWP limit on new equipment — WAC 173-443 use restrictions

Washington restricts the use of HFCs and other fluorinated gases with a GWP greater than 150 in new stationary refrigeration and air conditioning equipment. This is a more aggressive limit than many federal rules and effectively requires contractors to specify lower-GWP alternatives for all new or retrofit stationary systems in the state. The rule provides specific prohibition tables with end-use categories and applicable dates within WAC 173-443.

Refrigerant management program for large systems

For owners and operators of large stationary refrigeration and air conditioning systems, Chapter 173-443 WAC also establishes a refrigerant management program that includes registration, leak inspection, leak repair, recordkeeping, and reporting requirements — mirroring the structure of California's RMP but with Washington-specific thresholds and timelines. Contractors who charge refrigerant on-site after the system was assembled are not required to fulfill manufacturer registration obligations, but they are subject to service technician practice requirements. Manufacturers and distributors must submit status reports within 120 days of each product restriction effective date.

What a contractor should do differently in Washington

• Default to GWP ≤150 refrigerants for all new or retrofit stationary installations — R-410A (GWP ~2,088) is off the table for new equipment
• Confirm the specific end-use category in WAC 173-443's prohibition tables before specifying any refrigerant
• Register large systems in Washington's program and ensure leak inspection and repair records are maintained per WAC requirements
• Track your HFC end-use classification carefully — the rule distinguishes equipment types

Source: WA DOE Hydrofluorocarbons

⛵ Connecticut

As of mid-2026, Connecticut has not enacted its own state-specific HFC prohibitions or refrigerant management reporting program. Connecticut Department of Energy and Environmental Protection (CT DEEP) has expressed intentions to reduce HFC emissions but rulemaking has not been finalized. Contractors working in Connecticut are currently subject to the federal AIM Act floor only.

Pending rulemaking — watch this space

Connecticut is a member of the Regional Greenhouse Gas Initiative (RGGI) and has broader climate commitments that may accelerate HFC rulemaking. Contractors who service large commercial accounts in Connecticut should monitor CT DEEP for any rulemaking activity, as state rules — if adopted — could take effect with limited lead time.

What a contractor should do differently in Connecticut

• Federal AIM Act compliance (15 lb threshold, leak rates, 30-day repair, chronic leaker reporting) is your current obligation
• Set a quarterly calendar reminder to check CT DEEP's air and climate pages for HFC rulemaking updates
• Consider voluntarily documenting refrigerant GWP on service records now — if Connecticut adopts rules aligned with neighboring states, that data will be required

Source: CT DEEP

🦀 Maryland

The Maryland Department of the Environment (MDE) finalized HFC regulations under COMAR 26.11.33. Maryland's approach is to adopt the substance of EPA's SNAP Rules 20 and 21 as state law, which means the same equipment prohibitions that applied nationally under those federal rules are now independently enforceable by Maryland regardless of federal action.

Equipment prohibitions — COMAR 26.11.33

The rule covers refrigeration, commercial air conditioning, foam products, and aerosol propellants in categories that correspond to the SNAP 20/21 end-use lists. Restrictions on the upstream supply of HFCs took effect in 2024. Prohibitions on the use of certain HFCs in most new air conditioning and refrigeration product categories took effect in 2025. Maryland's rule includes a sell-through provision: products and equipment manufactured before the prohibition date may still be sold and installed, and existing equipment containing banned refrigerants may continue to operate and be serviced. Maryland has estimated that its HFC rules will reduce HFC emissions by approximately 25% by 2030.

What a contractor should do differently in Maryland

• Check the COMAR 26.11.33 prohibition list for any replacement refrigerant before a new installation or equipment specification
• If using equipment from inventory manufactured before the prohibition date, document the manufacture date — Maryland's sell-through provision protects that equipment
• Servicing existing equipment with prohibited refrigerants is generally still permitted under the sell-through rules; only new installations of covered equipment are restricted

Source: MD MDE Air Regulations

What Multi-State Contractors Should Actually Do

The practical challenge for a contractor operating across three or four of these states is that the compliance obligations are genuinely different — not just in degree, but in kind. California wants a chain-of-custody reclaim record. New Jersey wants an April 1 refrigerant inventory report. New York wants you to know the GWP20 of every refrigerant before you install it. Washington wants all new equipment below GWP 150. Managing those requirements from memory or from a one-size-fits-all federal compliance approach is a recipe for gaps.

Build a state-flag matrix in your CRM or tracking system

Tag every customer account with the state(s) where you service their equipment. Link those state tags to a checklist of applicable state obligations: California accounts need R3 registration check + R4 chain of custody; New Jersey accounts with ≥50 lb systems need NJDEP registration; Washington accounts need GWP verification for any new install. When your field tech creates a service order, the state flag surfaces the right checklist automatically.

Verify every replacement refrigerant against the destination state's prohibition list

R-404A is still legal to purchase in most states but cannot be installed in new supermarket equipment in California, New York, New Jersey, or Maryland. R-410A is still serviceable in existing equipment everywhere but cannot go into new stationary equipment in Washington. The rule varies by state, equipment type, and installation date. A quick prohibition check before quoting saves the cost of a callback and potential compliance exposure.

Capture refrigerant type and GWP on every transfer record

The one data field that unlocks cross-state compliance reporting is refrigerant type with GWP value captured at the time of service. California's R4 program needs it. New Jersey's annual report needs it. Washington's use restriction verification needs it. New York's equipment prohibition check needs it. If you capture refrigerant type + GWP on every cylinder transfer and service event, your records can answer any state's audit question without a separate data collection exercise. Tracking software that records this automatically — like RefriTrak — eliminates the manual step and keeps records filterable by state for multi-state accounts.

Assume state rules move faster than federal — run a quarterly regulatory scan

Connecticut has been expected to adopt HFC rules for years and has not yet. New York's 2034 deadline for GWP20 < 10 on residential HVAC was set in 2025 — giving contractors less than a decade to plan equipment transitions for an entire product category. Maryland and New Jersey have aligned their timing to SNAP 20/21 and have added their own layers. Set a quarterly calendar reminder to check state agency pages for new rulemaking and proposed rules before they reach final adoption.

How Software Helps Multi-State Contractors

The core compliance problem for a multi-state HVAC contractor is not understanding the rules — it's consistently applying the right rule to the right job across a field team of technicians who may not know which state-specific form applies to a given system. A refrigerant tracking platform that captures refrigerant type, GWP, charge weight, and service history on every service event creates the data foundation that any state's audit or annual report can draw from.

RefriTrak captures refrigerant type and GWP on every cylinder transfer and service record, organized by customer account and asset. For contractors with accounts in multiple states, those records can be filtered by state to generate the data needed for California's March 1 annual report, New Jersey's April 1 refrigerant inventory, or a Washington DOE audit — without manually reconstructing service histories from paper logs or disconnected spreadsheets.