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.
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)
An appliance falls under §84.106 if both are true:
Most common commercial refrigerants clear the GWP-53 bar easily:
| Refrigerant | GWP | Covered at 15+ lbs? |
|---|---|---|
| R-404A | 3,922 | Yes |
| R-410A | 2,088 | Yes |
| R-134a | 1,430 | Yes |
| R-407C | 1,774 | Yes |
| R-448A / R-449A | 1,387 / 1,397 | Yes |
| R-32 | 675 | Yes |
| R-454B | 466 | Yes |
| R-717 (ammonia), R-744 (CO₂), R-290 (propane) | 1–3.3 | No — 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.
Every time refrigerant is added, calculate the leak rate (annualizing or rolling-average method — one method per facility). §84.106(b)
Over the trigger rate (10/20/30% by category)? Repair within 30 days, verify, then follow-up within 10 days. §84.106(c)–(f)
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)
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.
| Date | What | Cite |
|---|---|---|
| Jan 1, 2026 | §84.106 takes effect; determine full charge of all 15+ lb appliances | §84.106(a)(4),(l)(1) |
| Jan 1, 2027 | Automatic leak detection required on 1,500+ lb systems installed 2017–2025 | §84.108(b)(2) |
| Mar 1, 2027 | First chronic-leaker reports due (for 2026 calendar year) | §84.106(j) |
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