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The rule, explained

The AIM Act 15-lb rule, in plain English

As of January 1, 2026, the EPA's leak-repair, inspection, and recordkeeping rules apply to any refrigerant-containing appliance with a full charge of 15 pounds or more of a high-GWP refrigerant — a roughly ten-fold expansion of who must comply. Here is exactly what that means, straight from 40 CFR §84.106.

What actually changed

The AIM Act (American Innovation and Manufacturing Act of 2020) directed the EPA to phase down HFC refrigerants. Its "Emissions Reduction and Reclamation" rule added Subpart C to 40 CFR Part 84. The headline for shops: the leak-repair regime that used to apply only to systems with 50+ pounds of ozone-depleting refrigerant now applies to systems with just 15+ pounds of a substitute refrigerant (like the HFCs in nearly all modern commercial equipment). §84.106(a)

Why it matters: a huge population of everyday equipment — supermarket racks, restaurant walk-ins, cold-storage rooms, rooftop units — crossed from "unregulated" to "federally tracked" overnight. Most owners have no records in place.

Is my equipment covered? The two-part test

An appliance falls under §84.106 if both are true:

  1. Full charge ≥ 15 lbs. The "full charge" is the amount of refrigerant the appliance holds in normal operation, by the manufacturer's spec, calculation, measurement, or an established range. §84.106(a); §84.102 "full charge"
  2. The refrigerant is a regulated HFC, or a substitute with a Global Warming Potential over 53 (using the values in table 1 of §84.64(b)). §84.106(a)(1)–(2)

Most common commercial refrigerants clear the GWP-53 bar easily:

RefrigerantGWPCovered at 15+ lbs?
R-404A3,922Yes
R-410A2,088Yes
R-134a1,430Yes
R-407C1,774Yes
R-448A / R-449A1,387 / 1,397Yes
R-32675Yes
R-454B466Yes
R-717 (ammonia), R-744 (CO₂), R-290 (propane)1–3.3No — GWP under 53

GWP basis: table 1 to §84.64(b) and appendix A to Part 84.

Use the free leak-rate calculator → to check a specific appliance in seconds.

The four obligations it creates

1 · Calculate the leak rate

Every time refrigerant is added, calculate the leak rate (annualizing or rolling-average method — one method per facility). §84.106(b)

2 · Repair on the clock

Over the trigger rate (10/20/30% by category)? Repair within 30 days, verify, then follow-up within 10 days. §84.106(c)–(f)

3 · Inspect & report

Post-repair inspections (quarterly or annual), and a chronic-leaker report to the EPA if you lose 125%+ of charge in a year. §84.106(g),(j)

4 · Keep the records

Full charge, every addition, every calculation, tests, and plans — kept at least three years. §84.106(l)

The repair-deadline guide walks through obligation 2 in detail, and the recordkeeping guide covers obligation 4.

What's excluded

Key dates

DateWhatCite
Jan 1, 2026§84.106 takes effect; determine full charge of all 15+ lb appliances§84.106(a)(4),(l)(1)
Jan 1, 2027Automatic leak detection required on 1,500+ lb systems installed 2017–2025§84.108(b)(2)
Mar 1, 2027First chronic-leaker reports due (for 2026 calendar year)§84.106(j)

What to do now

  1. Inventory every commercial appliance with 15+ lbs of a covered refrigerant, and record its full charge. That inventory is itself a required record as of January 1, 2026.
  2. Calculate the leak rate on every future refrigerant addition — the calculator does the exact math.
  3. Track the clocks so a 30-day repair window never slips.
  4. Keep everything for three years in a form you can hand an auditor.
LeakClock does 1–4 automatically. Techs scan a tag and weigh the cylinder; the app calculates the rate, starts the clock, and the office prints the audit binder. Start a 14-day free trial →

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