The US Environmental Protection Agency's (EPA) latest refrigerant management rule is set to reshape compliance requirements for thousands of facilities across the United States. Starting January 1, 2026, the EPA will lower the refrigerant threshold from 50 pounds to 15 pounds for systems containing high-global warming potential (GWP) refrigerants, a change that will significantly expand regulatory oversight and bring many previously exempt systems under federal scrutiny.
What's changing?
This regulatory shift means that refrigeration and air conditioning systems that were once below the compliance radar will now be subject to the same stringent leak detection, repair, and reporting requirements that larger systems have faced for years. Facilities in retail, healthcare, education, and commercial real estate sectors will be most heavily impacted.
We're talking about a threshold reduction of 70%. That means rooftop heating, ventilation, and air-conditioning (HVAC) units, small commercial refrigeration systems, and even some process cooling equipment that facilities never had to track before will suddenly require full compliance programs.
Who needs to comply?
If your facility uses common refrigerants like R-410A, R-134a, or other hydrofluorocarbons (HFCs) with a GWP exceeding 53, you'll need to prepare for new federal standards across three key areas:
1. Leak detection rate calculations and repair timelines
Facilities must now calculate annual leak rates for qualifying systems and initiate repairs within specified timeframes when leak thresholds are exceeded. The standard repair timeline is 30 days from the date a leak is discovered, but systems with leak rates exceeding certain percentages may face more aggressive requirements.
2. Refrigerant recordkeeping and reporting
Comprehensive documentation will be mandatory, including refrigerant purchase records, service logs, leak repair records, and disposal documentation. These records must be maintained for a minimum of three years and be readily available for EPA inspection.
3. Technician certification and system documentation
All technicians servicing covered equipment must hold EPA Section 608 or 609 certification. Additionally, facilities must maintain detailed system inventories, including refrigerant type, charge size, and equipment identification.
Impact on your operations
The practical implications of this rule change are substantial. Many facility managers will need to conduct immediate inventories to identify which systems now fall under the 15-pound threshold. For multi-site operators, this could mean adding hundreds of units to compliance-tracking programs.
To do now
Despite any potential federal government disruptions or shutdowns, this rule becomes effective January 1, 2026, and compliance obligations remain in force. Enforcement actions and penalties can be pursued retroactively once normal operations resume (read What a US Government shutdown could mean for EHS compliance).
Immediate actions (Q4 2025)
- Conduct a comprehensive refrigerant system inventory across all facilities.
- Identify all systems containing 15+ pounds of high-GWP refrigerants.
- Review and update maintenance contracts to ensure technician certification requirements.
- Establish or expand recordkeeping systems for tracking refrigerant purchases and service activities.
Before January 1, 2026
- Implement leak-detection protocols for newly covered systems.
- Train facility staff on new reporting requirements.
- Develop standardized procedures for leak rate calculations.
- Schedule baseline system inspections and refrigerant charge verification.
Ongoing compliance
- Conduct quarterly leak inspections on covered equipment.
- Calculate annual leak rates and initiate timely repairs.
- Maintain organized documentation for EPA audits.
- Stay informed on potential future regulatory changes.
This threshold reduction is part of the EPA's broader strategy to phase down HFC production and consumption in alignment with the American Innovation and Manufacturing (AIM) Act. Facilities should anticipate continued regulatory changes in the refrigerant management space, including potential future refrigerant bans and additional compliance requirements.
Don't wait until the January 1, 2026, deadline to address these new requirements.
