LeakLedgerPart 84 guide
40 CFR Part 84 Subpart C Leak Repair: The Complete Guide for Refrigeration Contractors
Since January 1, 2026, EPA's leak repair rule for HFC refrigeration and air-conditioning systems lives in 40 CFR Part 84, Subpart C. If you service supermarket racks, walk-ins, cold storage or commercial HVAC, most of the systems you touch are covered — and the records your technicians create are what owners rely on to comply. This guide walks through the whole rule in the order it plays out in the field.
1. Which appliances are covered
The leak repair requirements apply to appliances with a full charge of 15 pounds or more of refrigerant that contains a regulated substance (an HFC listed under the AIM Act) or a substitute with a global warming potential above 53 (§84.106(a)). In practice that includes the common HFC and HFC-blend refrigerants in commercial refrigeration — R-404A, R-507A, R-448A, R-449A, R-134a — and in commercial air conditioning, such as R-410A.
Two groups are excluded (§84.106(a)(3)): appliances that contain only an ozone-depleting refrigerant such as R-22, which stay under the older Section 608 rules, and appliances in the residential and light commercial air conditioning and heat pump subsector. The rule doesn't define that subsector, so borderline commercial A/C deserves a second look. Low-GWP refrigerants such as CO₂ (R-744) and propane (R-290) fall below the GWP threshold. More detail: Does the 15-lb rule apply to my equipment?
2. Calculating the leak rate
The owner or operator must calculate the leak rate every time refrigerant is added, except an addition right after a retrofit or a new installation, or one that qualifies as a seasonal variance (§84.106(b)). Whoever adds or removes refrigerant must give the owner documentation of the service when they finish.
Leak rate is the share of the full charge that would be lost over 12 months at the current rate of loss. §84.102 allows two methods, and the same one must be used for all covered appliances at a facility:
- Annualizing: pounds added ÷ full charge, scaled to a year by the days since the last addition (365 at most).
- Rolling average: pounds added over the previous 365 days — or since the last successful follow-up verification test, if that's shorter — ÷ full charge.
For the first calculation after January 1, 2026, the annualizing method uses 365 days and the rolling method counts additions since January 1, 2026 (§84.106(b)(1)–(2)). Worked examples: Annualizing vs rolling average, or run the numbers in the leak rate calculator.
3. Leak rate thresholds
| Appliance type | Threshold | Citation |
|---|---|---|
| Commercial refrigeration | 20% | §84.106(c)(2)(i) |
| Industrial process refrigeration | 30% | §84.106(c)(2)(ii) |
| Comfort cooling, refrigerated transport and other appliances | 10% | §84.106(c)(2)(iii) |
A leak rate over the threshold triggers the repair requirements — unless the owner chooses to retrofit or retire the appliance instead (§84.106(c)(1)).
4. The 30-day repair clock and verification tests
Leaks must be identified and repaired within 30 days of the refrigerant addition that showed the appliance over the threshold, or 120 days if an industrial process shutdown is required (§84.106(d)). A certified technician performs a leak inspection to find the leaks, and the repair must bring the leak rate below the threshold.
Every repaired leak needs two tests (§84.106(e)):
- an initial verification test within the same 30 days, showing the repair held; and
- a follow-up verification test within 10 days of a successful initial test (or of the system reaching normal operating conditions, if it was evacuated).
Extensions are possible only in narrow cases — such as parts that can't be delivered in time — and must be requested from EPA within the 30 days (§84.106(f)). Mothballing an appliance pauses the clock. Details: The 30-day repair clock.
5. Leak inspections after an exceedance
After a successful follow-up verification test, an appliance that exceeded its threshold needs periodic leak inspections (§84.106(g)): every three months for commercial and industrial process refrigeration with a full charge of 500 lb or more, until four quarters in a row stay under the threshold; once a year for smaller commercial and IPR appliances and for comfort cooling and other appliances, until a year stays under it. Areas continuously monitored by an automatic leak detection system that is audited or calibrated annually don't need these inspections.
6. Retrofit or retirement plans
A written plan is due within 30 days if the owner decides to retrofit or retire instead of repairing, does nothing to find or fix the leaks, or the appliance still leaks above the threshold after the required repairs and tests (§84.106(h)(1)). The work must be finished within one year of the plan. See Retrofit or retirement plans.
7. Chronic-leak reports
If an appliance with 15 lb or more of refrigerant leaks 125% or more of its full charge in a calendar year, the owner or operator must report it to EPA by March 1 of the next year (§84.106(j)). Leaks during 2026 lead to the first reports, due March 1, 2027. See What's due March 1, 2027.
8. Automatic leak detection
Commercial refrigeration and industrial process refrigeration appliances with a full charge of 1,500 lb or more need an automatic leak detection system: at installation for appliances installed from 2026, and by January 1, 2027 for those installed from 2017 through 2025 (§84.108). See Automatic leak detection for 1,500 lb systems.
9. Records, and what contractors must hand over
Owners and operators keep the required records for at least three years (§84.106(l)). When someone other than the owner does the installation, service, repair or disposal, that contractor must give the owner a record of it: the appliance, the date, the parts serviced, what was done, who did it, and the amount and type of refrigerant (§84.106(l)(4)). Technicians who perform leak inspections must document them too (§84.106(l)(5)). See What to hand your customer.
10. Key dates
- Leak repair requirements applyJan 1, 2026
- Automatic leak detection for 1,500 lb+ systems installed 2017–2025Jan 1, 2027
- First chronic-leak reports (2026 leaks)Mar 1, 2027
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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.