LeakLedgerPart 84 guide
Chronically Leaking Appliance Reports: What's Due March 1, 2027
Part 84 adds an annual report for appliances that keep leaking. Any appliance with 15 lb or more of refrigerant that loses 125% or more of its full charge in a calendar year must be reported to EPA by March 1 of the following year (40 CFR 84.106(j)). Because the leak repair rule started January 1, 2026, the first reports are due March 1, 2027.
The 125% test
The trigger is simple to state: refrigerant lost during one calendar year, measured against the appliance's full charge. If a 220 lb rack takes 275 lb or more of top-offs between January 1 and December 31, it has lost at least 125% of its charge and is reportable.
2026 additions: 60 + 85 + 70 + 75 = 290 lb → 131.8% of full charge → report due March 1, 2027
The rule doesn't spell out how to measure "leak" beyond the leak rate provisions; in practice the pounds of refrigerant added to replace losses during the year are the evidence. Purged refrigerant that is destroyed at 98% efficiency or better isn't counted toward leak rates (§84.106(k)).
Which appliances count
Every appliance subject to the leak repair rule: a full charge of 15 lb or more of an HFC or a substitute with GWP above 53, other than residential and light commercial A/C and ODS-only systems (§84.106(a)). That includes commercial refrigeration, industrial process refrigeration, comfort cooling and other appliances — not only the large racks. A 30 lb walk-in that took 40 lb over the year qualifies.
What the report must contain
The owner or operator submits it electronically through EPA's reporting platform, with (§84.106(m)(4)):
- Owner or operator, facility name and address, and the appliance ID or description
- Appliance type — comfort cooling or other, industrial process refrigeration, or commercial refrigeration
- Refrigerant type
- Full charge (pounds)
- Annual percent refrigerant loss
- Dates of refrigerant additions
- Amounts of refrigerant added
- Date of the last successful follow-up verification test
- Explanation of the cause of the losses
- Description of the repairs taken
- Whether a retrofit or retirement plan has been developed, and the anticipated date
- A signed statement from an authorized company official
Almost every line comes from service records — the dates and pounds your technicians recorded, the tests they performed, the repairs they made. Owners will ask their contractor for it.
Part 84 vs the old Section 608 version
Section 608 has had a similar 125% report for ozone-depleting refrigerants in appliances of 50 lb or more. Much of what you'll find online describes that version. Under Part 84 the floor is 15 lb and the refrigerants are HFCs and other high-GWP substitutes, so many more systems can land on the list. More: Part 84 vs Section 608.
How to catch it before December
- Track year-to-date pounds per appliance, not just per job. A rack that has taken 90% of its charge by September will probably cross 125%.
- Get the full charge right. The percentage is only as good as the denominator. §84.102 allows the manufacturer's figure, a calculation, a measurement or an established range.
- Merge equipment names. "Rack A" and "RACK-A LT" on different invoices split the total and hide a chronic leaker.
- Document cause and repairs as you go — the report asks for both.
LeakLedger shows the calendar-year total as a percentage of full charge on every appliance and flags 125% with the March 1 due date. Try it on one appliance with the calculator.
Do this math for every appliance automatically
LeakLedger reads the service records you already keep, calculates every leak rate with the arithmetic shown, tracks each Part 84 deadline, and builds a branded report for each customer. $149/month, 14-day free trial.
This guide summarizes 40 CFR 84.102, 84.106 and 84.108 as published in the eCFR. It is not legal advice; where the rule is unclear we say so. Read the rule: 40 CFR Part 84, Subpart C.