Most facility managers have heard something about refrigerants being phased out, usually in vague terms — "R-22 is gone," "the new stuff is flammable," "my HVAC guy mentioned something about 2026." The regulations behind it are real, they're actively changing, and one part of them already applies to a lot of commercial refrigeration and HVAC equipment right now. Here's the practical version.
The short version of what's happening
The AIM Act directs the EPA to phase down HFC refrigerants — the ones most commercial RTUs, walk-ins, and reach-ins currently run on — by 85% by 2036. That phasedown is already underway. Separately, EPA's Technology Transitions Rule sets maximum global warming potential (GWP) limits for refrigerants in new equipment, with different compliance dates depending on the type of equipment and industry sector. EPA has revised some of those sector-specific dates since the rule was first finalized, and further changes are possible — which is exactly why "what's the deadline" is the wrong question to lead with.
What's actually in effect right now
As of January 1, 2026, EPA's leak detection and repair requirements apply to owners and operators of equipment with a refrigerant charge of 15 pounds or more. That threshold covers a lot of commercial equipment — larger RTUs, walk-in refrigeration systems, and rack systems in particular. In practice, that means:
- Documented, periodic leak inspections on qualifying equipment
- Timely repair of leaks once identified, on a defined schedule
- Recordkeeping that can be produced if requested — not just "we probably checked it"
This is the part that's actionable today, independent of any future equipment replacement decision. If nobody has confirmed which of your units cross the 15-pound threshold, that's worth finding out before it becomes a compliance gap.
What's coming, and why the dates keep moving
New-equipment GWP limits are being phased in for retail refrigeration, cold storage, and other sectors over the next several years. EPA proposed and then finalized changes to several of these dates during 2025 and 2026 — some deadlines were extended, some thresholds were relaxed for a period before tightening again later in the decade. Manufacturers are already shifting new equipment toward lower-GWP options, most commonly A2L refrigerants like R-454B and R-32, and that shift will keep happening regardless of exactly where a given compliance date lands.
For a facility manager, the practical implication isn't "panic-replace everything before a specific date." It's this: when a unit is up for replacement anyway, the refrigerant type and GWP limit that applies to your equipment category and site should be part of that conversation — not an afterthought discovered after the equipment is already ordered.
What existing equipment owners don't need to worry about
Working systems on older refrigerants like R-410A don't need to be replaced just because they're not the newest refrigerant type. Servicing existing equipment with its current refrigerant remains allowed. The compliance requirements are aimed at leak management on qualifying equipment now, and at what refrigerant goes into new installations going forward — not at forcing early replacement of equipment that's working fine.
A reasonable way to handle this
- Get a straight answer on which of your units have a refrigerant charge at or above the 15-pound leak-detection threshold
- Make sure leak inspections and any repairs are actually being documented, not just performed
- When a unit is genuinely due for replacement, ask what refrigerant the new equipment will use and whether that fits your equipment category's current requirements
- Don't take a single deadline as fixed — these rules have changed more than once and may change again
We handle leak inspection documentation and refrigerant guidance as part of standard refrigeration service and maintenance plans for our Orange County commercial accounts. This is general information, not legal advice — for anything site-specific, confirm current requirements for your equipment and sector before making a decision.