EPA refrigerant leak repair rules

Two rules, one structure

EPA runs two leak repair programs with almost the same mechanics:

• 40 CFR 82.157 (Section 608, ozone-depleting substances). Since April 10, 2020 it applies only to appliances with a full charge of 50 lb or more of a class I or class II refrigerant, or a blend containing one. It does not apply to appliances containing only substitute refrigerants. Large R-22 and R-123 systems fall here; see R-22 phase-out.
• 40 CFR 84.106 (AIM Act, HFCs). From January 1, 2026 it applies to appliances with a full charge of 15 lb or more where the refrigerant contains a regulated HFC, or a substitute with a GWP above 53 based on the values in 84.64(b). Two exclusions: appliances containing solely an ODS refrigerant, and “refrigerant-containing appliances used for the residential and light commercial air conditioning and heat pump subsector.”

Under the Part 84 definitions (84.102), “each independent circuit is considered a separate appliance,” so a two-circuit rack or chiller is checked circuit by circuit against the 15 lb threshold. Because the GWP test is above 53, A2L blends such as R-454B (465 on EPA’s 84.64 basis) and R-32 (675) can be covered in commercial applications, while HFOs with an EPA GWP of 1 are not; see the GWP chart.

Part 84 defines comfort cooling broadly: it includes “chillers, commercial split systems, dual-function heat pumps, and packaged roof-top units.” Section 84.106 itself does not draw the line between that and the excluded residential and light commercial subsector. Confirm which side a specific system falls on with EPA guidance before assuming it is exempt.

Leak rate thresholds and deadlines

Repair deadlines can be extended for radiological contamination, conflicting regulations, or parts that are not available. For parts, the extra time runs up to 30 days after delivery, capped at 180 days from the exceedance (270 days with an industrial process shutdown). The owner must document the repair effort and request the extension from EPA within the 30 or 120 day window; under 84.106 the request is signed by an authorized company official. Deadlines are suspended while an appliance is mothballed, meaning evacuated to at least atmospheric pressure and temporarily shut down.

How the leak rate is calculated

The owner or operator must calculate the leak rate every time refrigerant is added, unless the addition follows a retrofit, a new installation, or qualifies as a seasonal variance. Part 84 (84.102) allows two methods, and the same one must be used for all covered appliances at a facility:

• Annualizing method: (pounds added ÷ full charge) ÷ (the shorter of days since the last addition or 365, divided by 365) × 100.
• Rolling average method: pounds added over the previous 365 days (or since the last successful follow-up verification test, if shorter) ÷ full charge × 100.

Example with the annualizing method: a 100 lb comfort cooling chiller needs 10 lb, 73 days after the last addition. (10 ÷ 100) ÷ (73 ÷ 365) = 0.1 ÷ 0.2 = 0.5, a 50% leak rate, over the 10% threshold. The 30-day repair clock starts.

For the first calculation after January 1, 2026 under 84.106, use 365 days as the days since the last addition (annualizing), or count only refrigerant added since January 1, 2026 (rolling average).

Full charge can come from the manufacturer’s figure, a calculation from component and piping volumes, actual measurements of refrigerant added or removed, or an established range with its midpoint used. The method has to be recorded.

What the technician does

Repairs must be done by a certified technician (84.106(c)), meaning one certified under 40 CFR 82.161; see EPA 608 certification. The technician’s part of the job:

• Leak inspection to find the leak location, using methods the technician picks. The definition lists ultrasonic tests, gas-imaging cameras, bubble tests and leak detection devices. Pressure or vacuum decay tests, sight glass checks, receiver levels and charging charts show that a system leaks but not where, so they must be paired with a locating method.
• Inspect all visible and accessible components, except insulated, iced, underground or behind-wall parts, parts more than two meters above a support surface, or parts site personnel judge unsafe.
• Initial verification test after the repair, before adding refrigerant, and a follow-up test within 10 days.
• Paperwork to the owner. After any installation, service, repair or disposal, give the owner the appliance identity and location, the date, the parts worked on, the type of work, your name, and the amount and type of refrigerant added or removed. After leak inspections and verification tests, give the owner documentation of the dates, methods, leak locations and results.

Know what is in the system before topping it off: identify the refrigerant, and recover to the required levels before opening it (refrigerant recovery).

Automatic leak detection (84.108)

40 CFR 84.108 requires automatic leak detection on commercial refrigeration and industrial process refrigeration appliances with a full charge of 1,500 lb or more of an HFC or a substitute with a GWP above 53:

• Installed on or after January 1, 2026: at installation or within 30 days.
• Installed from January 1, 2017 through December 31, 2025: by January 1, 2027.
• Audited and calibrated annually, and required to monitor components inside an enclosed building or structure.
• Systems that sense refrigerant in air must detect 10 ppm and alert the owner at 100 ppm, with sensors near the compressor, evaporator, condenser and other high-risk spots. Systems that monitor appliance conditions must alert at a loss of 50 lb or 10% of the full charge, whichever is less.
• After an alert, the owner calculates the leak rate within 30 days (120 with an industrial process shutdown), or repairs first and then calculates.

These systems are separate from the refrigerant detection systems built into A2L equipment for flammability safety. Under 84.106(g)(4), an appliance continuously monitored by a qualifying automatic leak detection system that is audited or calibrated annually does not need the quarterly or annual leak inspections.

Proposed exclusion for transport refrigeration units

On May 26, 2026, EPA proposed (91 FR 30532) to add road and intermodal container transport refrigeration units to the 84.106(a)(3) exclusions, regardless of charge size. EPA said it “did not intend” to cover these units and that their charge typically ranges from 5 to 15 lb, sometimes more but generally 18 lb or less. Comments closed July 10, 2026.

This is a proposal only. Until EPA publishes a final rule, the regulation text in force has no TRU exclusion, and refrigerated transport appliances of 15 lb or more stay in the 10% category.

Where this fits

Leak repair is one part of the AIM Act emissions rules. Phasedown dates, GWP limits and the reclaimed refrigerant requirement are on AIM Act refrigerant rules; what it means for existing R-410A equipment is on R-410A phase-out.