EPA Refrigerant Compliance Overview

Federal regulations under 40 CFR Part 84, Subpart C require owners and operators of refrigerant-containing appliances to track refrigerant additions, calculate leak rates, repair leaks, and maintain detailed records. These requirements took effect January 1, 2026 under the AIM Act.

This guide summarizes your compliance obligations.

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Who Must Comply

Applicability (§84.106(a))

EPA leak repair requirements apply to refrigerant-containing appliances with:

• Full charge of 15 pounds or more, AND
• Refrigerant containing a regulated substance OR substitute with GWP >53

Exceptions:

• Appliances containing only ozone-depleting substances under 40 CFR Part 82, Subpart A
• Residential and light commercial air conditioning and heat pumps
• Motor vehicle air conditioners (MVACs)

Effective Date: January 1, 2026

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Leak Rate Calculation

When to Calculate (§84.106(b))

You must calculate the leak rate every time refrigerant is added to an appliance, except after:

• New installation
• Retrofit (refrigerant type change)
• Seasonal variance additions

Two Calculation Methods

Method 1: Annualizing Method (§84.106(b)(1))

Formula:

Leak Rate (%) = (Pounds Added / Full Charge) / (Days Since Last Add / 365) × 100

First-time calculation rule: If no prior addition exists after January 1, 2026, use 365 days as the time period.

Service episode grouping: Multiple refrigerant additions during the same service visit are summed together as a single addition for leak rate purposes.

Method 2: Rolling Average Method (§84.106(b)(2))

Formula:

Leak Rate (%) = (Sum of Pounds Added in Past 365 Days / Full Charge) × 100

First-time calculation rule: Only count additions since January 1, 2026.

Method Consistency (§84.106(b)(3))

You must use the same method for all appliances at an operating facility.

Exception: If you purchase or acquire a facility using a different method, you may switch methods only if:

• Appliances are NOT exceeding threshold under EITHER method
• You document the change and retain records

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Leak Rate Thresholds

Applicable Thresholds by Appliance Type (§84.106(c)(2))

What happens when exceeded: Mandatory leak repairs, verification testing, and ongoing inspections required.

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Repair Requirements

Repair Deadlines (§84.106(d))

When an appliance exceeds its applicable leak rate threshold, you must:

1. Conduct leak inspection to identify location(s)
2. Repair all identified leaks within 30 days
3. Bring leak rate below threshold

Extended deadline: 120 days if industrial process shutdown is required.

Mothballing: Deadlines are temporarily suspended when appliance is mothballed (evacuated to atmospheric pressure and shut down). Time resumes when refrigerant is added.

Certified Technician Required

Repairs must be conducted by a technician certified under 40 CFR 82.161.

Verification Testing Required (§84.106(e))

All repairs must be verified by:

1. Initial Verification Test

• Performed within repair deadline (30 or 120 days)
• Demonstrates repairs have held
• Timing:
  • Non-evacuated repairs: After repair, before adding refrigerant
  • Evacuated repairs: Before adding any refrigerant
• Multiple attempts allowed if test fails

2. Follow-Up Verification Test

• Performed within 10 days of:
  • Successful initial test, OR
  • Appliance returning to normal operating conditions
• Multiple attempts allowed if test fails

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Repair Extensions

When Extensions Are Allowed (§84.106(f))

You may request more than 30 days (or 120 days) if one or more of these conditions apply:

1. Radiological Contamination (§84.106(f)(1)(i))

• Appliance in area subject to radiological contamination, OR
• Shutdown would lead to contamination
• Additional time granted to conduct repairs safely

2. Other Regulations (§84.106(f)(1)(ii))

• Federal, state, local, or tribal regulations make 30-day repairs impossible
• Additional time granted to comply with those regulations

3. Parts Unavailable (§84.106(f)(1)(iii))

• Required components not available within 30 days (120 for industrial)
• Additional time: Up to 30 days after delivery
• Maximum total: 180 days from threshold exceedance (270 days for industrial)

Extension Requirements

Partial repairs required: Repairs that identified leaks significantly contributing to exceedance and that don't require additional time must be completed within the initial 30-day period.

EPA notification required: Request extension electronically within 30 days (120 for industrial) of exceeding threshold. Include:

• Facility identification and contact information
• Leak rate and calculation method
• Date threshold exceeded
• Leak locations identified
• Repairs completed to date
• Reason for extension
• Estimated completion date
• Signature from authorized company official

Approval: Considered approved unless EPA notifies you otherwise.

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Ongoing Inspections

After Successful Repairs (§84.106(g))

After successful follow-up verification test, periodic leak inspections are required until you demonstrate (through leak rate calculations) that the appliance hasn't exceeded threshold for the required "clean period."

Inspection Frequency

Inspection Requirements (§84.106(g)(2)-(3))

• Must be conducted by certified technician
• Using methods appropriate for that appliance (ultrasonic, gas-imaging cameras, bubble tests, leak detectors)
• Inspect all visible and accessible components

Exceptions to accessible components:

• Insulated, underground, behind walls, or otherwise inaccessible
• Elevated more than 2 meters above support surface
• Unsafe to inspect

Automatic Leak Detection Exemption (§84.106(g)(4))

Quarterly or annual leak inspections NOT required on appliances (or portions) continuously monitored by automatic leak detection system that is audited or calibrated annually and meets requirements in §84.108.

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Retrofit or Retirement

When Required (§84.106(h))

You must create a retrofit or retirement plan within 30 days if:

1. Appliance leaking above threshold and you intend to retrofit or retire rather than repair, OR
2. You fail to take action to identify or repair leaks, OR
3. Appliance continues to leak above threshold after required repairs and verification tests

Plan Requirements (§84.106(h)(2))

Plan must include (minimum):

• Appliance identification and location
• Current refrigerant type and full charge
• Type and full charge of new refrigerant (if retrofit)
• Itemized conversion procedure (if retrofit)
• Plan for recovered refrigerant disposition
• Plan for appliance disposition (if retired)
• Completion schedule (not to exceed 1 year)

Signature required: Authorized company official must sign and date plan.

Accessibility: Plan must be available at appliance site in paper or electronic format for EPA inspection.

Timeline

Completion: All work must be finished within one year of plan's date.

All leaks must be repaired: As part of any retrofit.

Extensions (§84.106(i))

Request deadline: Within 7 months of discovering threshold exceedance.

Industrial process extensions available for:

• Other regulation conflicts
• Custom-built equipment with delivery time >30 weeks
• Radiological contamination requiring >30 weeks

Approval: Considered approved unless EPA responds within 60 days.

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Chronic Leaker Reporting

EPA Reporting Requirement (§84.106(j))

If an appliance with ≥15 lbs leaks 125% or more of full charge in a calendar year, you must submit a report to EPA.

Deadline: March 1 of the following year.

Report Must Include (§84.106(m)(4))

1. Owner/operator and facility identification
2. Appliance type and refrigerant type
3. Full charge (pounds)
4. Annual percent refrigerant loss
5. Dates and amounts of refrigerant additions
6. Date of last successful follow-up verification test
7. Explanation of cause of losses
8. Description of repair actions taken
9. Whether retrofit/retirement plan developed
10. Signature from authorized company official

Submission: Electronic via EPA's reporting platform.

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Recordkeeping Requirements

Required Records (§84.106(l))

All records must be maintained for 3 years unless otherwise specified.

1. Full Charge Determination (§84.106(l)(1))

Retention: 3 years after appliance is retired

Must document:

• Owner/operator identification
• Appliance location
• Full charge amount
• Method used to determine full charge
• Any revisions and how they were determined
• Date of installation

Full charge determination methods:

1. Equipment manufacturer's determination
2. Calculations based on component sizes, refrigerant density, piping volume
3. Actual measurements of refrigerant added or evacuated
4. Established range (use midpoint as full charge)

2. Service Records (§84.106(l)(2))

For each time appliance is installed, serviced, repaired, or disposed of:

• Identity and location of appliance
• Date of service
• Parts serviced
• Type of service performed
• Name of person performing service
• Amount and type of refrigerant added or removed
• Full charge
• Leak rate and calculation method (except for disposal, retrofit, new installation, or seasonal variance)

3. Method Change Records (§84.106(l)(3))

If changing leak rate calculation method after facility acquisition:

• Date facility was purchased/acquired
• Leak rates under BOTH methods (annualizing AND rolling average)
• Date new method adopted
• New method being used

4. Leak Inspection Records (§84.106(l)(5))

• Date of inspection
• Methods used
• Location of each leak identified
• Certification that all visible and accessible parts were inspected

5. Verification Test Records (§84.106(l)(7))

• Appliance location
• Date(s) of verification tests
• Location(s) of repaired leaks tested
• Type(s) of verification test(s) used
• Results

6. Retrofit/Retirement Plans (§84.106(l)(8))

Maintain plans developed per §84.106(h) for 3 years.

7. Extension Requests (§84.106(l)(9))

Maintain requests submitted to EPA for 3 years.

8. Mothballing Records (§84.106(l)(10))

Document:

• When appliance was mothballed
• When refrigerant was added after mothballing

9. Seasonal Variance Records (§84.106(l)(12))

If excluding additions due to seasonal variance:

• Statement of using seasonal variance flexibility
• Amount added and removed

10. Purged Refrigerant Records (§84.106(l)(11))

If excluding purged refrigerants destroyed from leak rate calculations, maintain records supporting amount claimed as destroyed, including:

• Flow rate, quantity, or concentration in vent stream
• Periods of purge flow
• Facility identification and contact
• Appliance description
• Quantity determination methods
• Control device and destruction efficiency
• Monitoring frequency

Retention: 3 years

11. EPA Report Copies (§84.106(l)(13))

Maintain copies of all reports submitted to EPA and EPA responses for 3 years.

12. Automatic Leak Detection Records (§84.106(l)(6))

If using automatic leak detection:

• System installation records
• Annual audit and calibration records
• Date monitoring system identified each leak
• Leak location

Retention: 3 years

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Automatic Leak Detection Systems

When Required (§84.108(a))

Automatic leak detection systems required for appliances used in industrial process refrigeration OR commercial refrigeration with:

• Full charge ≥1,500 pounds, AND
• Refrigerant with GWP >53

Installation Timeline (§84.108(b))

System Requirements

Installation (§84.108(c)): Per manufacturer instructions.

Annual calibration (§84.108(d)): Systems must be audited and calibrated annually.

Monitoring scope (§84.108(e)): Must monitor components located inside an enclosed building or structure.

System Type Requirements

Refrigerant Sensor Type (§84.108(f)):

• Sensors placed to continuously monitor refrigerant concentrations near compressor, evaporator, condenser, and high-leak potential areas
• Accurately detect 10 parts per million (ppm)
• Alert owner/operator at 100 ppm

Condition Monitoring Type (§84.108(g)):

• System monitors appliance conditions (e.g., pressure)
• Alerts when measurements indicate loss of 50 pounds OR 10% of full charge, whichever is less

Response to Alerts (§84.108(h))

When automatic leak detection system alerts you of a leak, you must:

Option 1: Calculate & Comply

• Calculate leak rate within 30 days (120 for industrial)
• If above threshold, comply with all leak repair provisions in §84.106

Option 2: Preemptive Repair

• Repair identified leak(s) BEFORE adding refrigerant
• Then calculate leak rate within 30 days (120 for industrial)
• If above threshold, comply with all leak repair provisions in §84.106

Partial monitoring: If system only monitors portions of appliance, remainder continues to require manual leak inspections per §84.106(g).

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Special Topics

Seasonal Variance (§84.102 definition)

Removal of refrigerant due to change in ambient conditions from seasonal change, followed by subsequent addition of amount ≤ amount removed, where both occur within one consecutive 12-month period.

Effect: Addition qualifying as seasonal variance does NOT require leak rate calculation.

Recordkeeping: Must document you're using seasonal variance flexibility and the amounts added/removed.

Purged Refrigerant Exclusion (§84.106(k))

Purged refrigerant destroyed at 98% or greater efficiency will NOT count toward leak rate.

Use case: Industrial process systems that intentionally purge refrigerant.

EPA notification required: Within 60 days after first using exclusion at a facility.

Records required: Monitoring strategy demonstrating amount destroyed not greater than actually purged and 98%+ efficiency met (see recordkeeping section).

Mothballing (§84.102 definition)

Evacuating refrigerant from appliance to at least atmospheric pressure and temporarily shutting down.

Effect: Repair deadlines, inspection requirements, and retrofit/retirement timelines are suspended while mothballed. Time resumes when refrigerant is added.

Recordkeeping: Document when mothballed and when refrigerant added after mothballing.

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Sale of Recovered Refrigerant

Prohibition (§84.104(a))

Effective January 1, 2026, you may NOT sell, distribute, or transfer recovered regulated substances used as refrigerant in stationary equipment, UNLESS:

Exception 1: Recovered refrigerant has been:

• Reclaimed by EPA-certified reclaimer under 40 CFR 82.164, AND
• Reprocessed to specifications in appendix A to 40 CFR part 82, subpart F, AND
• Verified to meet specifications using prescribed analytical methodology

Exception 2: Sold solely for purposes of being reclaimed or destroyed.

Note: End users recovering refrigerant for their own use are not affected, but cannot sell/transfer without meeting these requirements.

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Related Resources

• Understanding EPA Compliance Thresholds - Detailed threshold explanations
• Recording Refrigerant Transfers Step-by-Step - How transfers affect compliance
• Understanding Circuit Transfers and EPA Tracking - Transfer types and leak rate impacts

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Regulatory References

Primary Regulation: 40 CFR Part 84, Subpart C - Management of Regulated Substances
Effective Date: January 1, 2026
Authority: AIM Act, 42 U.S.C. § 7675(h)
Related: 40 CFR Part 82, Subpart F (ozone-depleting substances - being phased out)

Official Source: Electronic Code of Federal Regulations (eCFR)

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Disclaimer: This guide summarizes federal EPA requirements. Your state may have additional refrigerant compliance requirements. RefriTrak helps you track and document federal requirements; consult with legal counsel regarding complete regulatory obligations.