Are You in the Know on the Refrigerant Rules?

On January 1, 2026 facilities with refrigeration appliances, including air conditioners, refrigerators, chillers, and freezers, with a full charge of 15 pounds or more of refrigerant may be subject to new leak repair requirements under 40 CFR Part 84, Subpart C (Management of Regulated Substances). Limitations on types of refrigerants that may be used in new installations, existing system rebuild restrictions, and new labeling requirements will be rolling out in the coming years under 40 CFR Part 84, Subpart B (Restrictions on the Use of Hydrofluorocarbons). Additionally, fire suppression equipment containing refrigerants will be subject to new regulations.

What does it mean?

Refrigeration appliances that have a full charge of 15 pounds or more and contain a regulated substance or a substitute for a regulated substance with a global warming potential (GWP) great than 53 will be subject to leak repair provisions. Regulated substances and substitutes with a GWP of over 53 include hydrofluorocarbons (HFC) like R-134a and blends of HFCs like R-410A or R-407C.

Facilities will need to identify, inventory, and categorize existing appliances. Certified technicians will be needed to conduct repairs and maintenance on regulated appliances.

Appliances with 15 pounds or more refrigerant at facilities will be subject to:

• Leak rate calculations and tracking, including chronic leak determinations,
• Leak repair timelines,
• Initial verification testing and follow-up testing after leaks,
• Routine leak inspections,
• Retrofit and retirement planning, and
• Recordkeeping and reporting.

Prior to January 1, 2026, facilities will need to review plans for new installations based on the type of refrigerant and purpose of the appliance. Installation deadlines are in place for new light commercial air-conditioning and heat pump systems, comfort cooling systems, cold storage warehouse systems, industrial process refrigeration systems, and chillers. Appliance rebuilds will need to be scrutinized for potentially triggering being classified as a new installation and face limits on type of refrigerant used.

Starting January 1, 2026 facilities will need to utilize trained fire suppression technicians for installations, maintenance, repairs, and disposal of fire suppression equipment that contain refrigerant. Prohibitions on venting or release of refrigerants, system testing and documentation requirements, and recycling and recovery equipment standards will also go into effect on January 1, 2026.

What’s Next?

Do you need support understanding compliance requirements, updating your refrigerant management program, or preparing training? ALL4 provides support for refrigerant management and compliance, including:

• Inventory development,
• Leak rate tracking and chronic leak reporting,
• Retrofit and retirement plan development,
• Project planning and purchasing guidance for future installations and rebuilds,
• Refrigerant Management Plans,
• Employee awareness training, and
• Refrigerant program compliance assessments.

If you have questions about how Part 84, Subpart B or Subpart C could affect your facility compliance, or what your next steps should be, please reach out to me at mdabrowski@all4inc.com. ALL4 continues to monitor all updates published by the U.S. Environmental Protection Agency (EPA) on this topic, and we are here to answer your questions and assist your facility with any aspects of environmental compliance.