- Federal rules (Clean Air Act Section 608 and the AIM Act) govern who can handle refrigerant, how it is recovered, and, for larger systems, how leaks must be tracked and repaired.
- Since January 1, 2026, federal leak-repair requirements apply to appliances holding 15 lb or more of HFC refrigerant, with trigger leak rates of 10% (comfort cooling), 20% (commercial refrigeration), and 30% (industrial process refrigeration).
- California layers its own rules on top, including the CARB Refrigerant Management Program for larger systems using high-GWP refrigerants.
- Regulations and enforcement priorities for equipment transitions (such as R-410A) are in flux. Verify current status before major purchases.
- Owners are responsible for records. Keep dated service logs showing refrigerant added, leaks found, and repairs verified.
The regulatory layers
| Layer | What it covers | Who it mostly affects |
|---|---|---|
| Clean Air Act Section 608 | Technician certification, no venting, recovery and reclaim requirements, historic leak-repair rules for ozone-depleting refrigerants | Every contractor handling refrigerant; owners of systems with ODS refrigerants (e.g. R-22) |
| AIM Act (HFC phasedown) | Phases down production and consumption of HFCs; sets restrictions on high-GWP refrigerants in new equipment; emissions reduction and reclamation (ER&R) requirements including leak repair | Equipment manufacturers, installers, and owners of larger HFC systems |
| California (CARB and local) | Refrigerant Management Program, limits on high-GWP refrigerants in new stationary equipment, registration and reporting for larger systems | Owners and operators of systems above CARB size thresholds; supermarkets, cold storage, large buildings |
| Codes and standards | Mechanical code, ASHRAE safety standards on refrigerant classes and charge limits, UL equipment standards | Designers, installers, inspectors |
Refrigerant rules have changed repeatedly and some provisions are under federal reconsideration. This guide is a practical overview, not legal advice. Confirm current requirements with EPA, CARB, or your contractor before making compliance-driven decisions.
Handling rules every owner should know
- Only EPA-certified technicians may buy or handle most regulated refrigerants. Ask to see certification.
- Venting refrigerant to the atmosphere is prohibited. Systems must be evacuated with recovery equipment.
- Recovered refrigerant is reclaimed or reused according to rules. Contaminated refrigerant must be reclaimed by an EPA-certified reclaimer.
- Disposal of equipment (including walk-ins, reach-ins, and ice machines) must follow recovery requirements.
- Records of refrigerant purchased, added, and recovered must be kept by the technician and, for covered systems, by the owner.
Leak-repair requirements under the AIM Act
EPA's Emissions Reduction and Reclamation (ER&R) rule, published in October 2024, extends leak-repair obligations to appliances containing 15 lb or more of HFC refrigerant (or a substitute with GWP above 53). Compliance began January 1, 2026. Previously, the Section 608 leak-repair rule applied to appliances with 50 lb or more of ozone-depleting refrigerant.
| Appliance category | Leak-rate trigger (annualized) |
|---|---|
| Comfort cooling (e.g. chillers, large HVAC) | 10% |
| Commercial refrigeration (e.g. supermarket racks, large walk-ins) | 20% |
| Industrial process refrigeration | 30% |
- Calculate the leak rate each time refrigerant is added to a covered appliance.
- Repair leaks that put the appliance above the trigger within 30 days (longer in limited circumstances), and verify the repair with initial and follow-up tests.
- Retrofit or retire plan: if repairs are not made or the appliance keeps leaking above the threshold, a plan is required within 30 days, with work generally completed within one year.
- Chronic leakers: appliances with 15 lb or more that leak 125% or more of the full charge in a calendar year require a report to EPA.
- Records must be kept for at least five years.
Residential and light-commercial air-conditioning and heat-pump appliances are excluded from the leak-repair provisions. Small reach-ins and self-contained units fall below the charge threshold, while rack systems and large chillers are the main exposure.
California additions
California's Air Resources Board (CARB) runs a Refrigerant Management Program (RMP) for stationary systems with larger refrigerant charges of high-GWP refrigerants. Covered facilities generally must register, perform leak inspections at intervals tied to charge size, repair leaks promptly, and keep records. Supermarkets, cold storage, and large commercial HVAC are typical targets. California also restricts high-GWP refrigerants in new stationary equipment categories under its own HFC regulations.
Because California's thresholds and schedules differ from federal ones, a system can be subject to California requirements even when it falls below federal ones. If you manage a facility with significant refrigerant charge, ask your contractor to identify your total charge per system and which programs apply.
Refrigerant transitions and what they mean for equipment
| Refrigerant | Status / direction | Planning note |
|---|---|---|
| R-22 | Production ended in 2020; only reclaimed or stockpiled supply remains | Repairs get more expensive each year; plan replacement for aging R-22 systems |
| R-410A | Widespread in current rooftops and splits; being replaced in new equipment by lower-GWP options. Federal installation cutoffs have been reconsidered, so confirm current status | Existing R-410A systems can continue to be serviced; new-equipment choices may shift to R-454B or R-32 |
| R-404A / R-507A | Common in older commercial refrigeration; high GWP and restricted in new systems | Retrofits often use R-448A / R-449A; leaks are costly |
| R-454B, R-32 (A2L) | Lower-GWP, mildly flammable (A2L class) | Require A2L-rated components, updated safety practices, and technician training |
| R-290 (propane), CO2 (R-744) | Natural refrigerants increasingly used in self-contained units and some rack systems | R-290 limited by charge size in current standards; CO2 systems operate at high pressure and need trained service |
Records that protect you
- Equipment list with refrigerant type and nameplate charge.
- Service logs: date, technician, refrigerant added or recovered (pounds), reason, and leak location if found.
- Leak-rate calculations where applicable.
- Repair verification results.
- Disposal and recovery records for retired equipment.
Because the DaVinci Portal logs each visit against the specific asset, refrigerant additions and findings stay attached to the equipment; see DaVinci Portal.
Planning for owners
- Inventory refrigerant type and charge on every system.
- Flag systems with R-22 or high-GWP refrigerants and a history of leaks.
- Ask your contractor to calculate leak rates for covered systems each time refrigerant is added.
- Budget for replacement of aging high-GWP systems rather than repeated top-offs.
- When replacing equipment, discuss refrigerant choice, availability, and technician training for A2L options.
Frequently asked questions
Do I need to track refrigerant in my small restaurant?
Most small reach-ins and self-contained units are below the 15 lb threshold for federal leak-repair rules, but your contractor should still document refrigerant added. Larger walk-in condensing units, racks, and rooftop systems may be covered.
Can I top off a system that is low on refrigerant?
A system that is low has a leak. Refrigerant should not simply be added without finding and repairing the leak, and for covered systems the leak rate must be calculated and records kept.
Is R-410A being banned?
Federal and state rules are limiting R-410A in new equipment, but existing systems can continue to be serviced. Federal timing has been under reconsideration, so confirm current status before purchasing.
What is an A2L refrigerant?
A class of lower-GWP refrigerants (such as R-32 and R-454B) that are mildly flammable. They require compatible equipment and safe-handling practices.
Have a site this applies to?
Davinci Mechanical is the commercial and union division of Scottish Tom's Heating & Air. Send us the equipment list or the problem and we'll tell you what we'd check first.