Facilities that own, service, or operate refrigeration or air conditioning equipment are now subject to a substantially expanded set of federal requirements under EPA’s Hydrofluorocarbon (HFC) Management Rule. Finalized on October 11, 2024, the rule establishes an Emissions Reduction and Reclamation (ER&R) program at 40 CFR Part 84, Subpart C. Leak repair, leak rate monitoring, and reclamation standards took effect January 1, 2026, and additional deadlines are approaching in 2027 including that existing commercial and industrial systems with a full refrigerant charge of 1,500 pounds or greater must install and use an automatic leak detection system by January 1, 2027.
The rule applies to appliances containing HFCs or HFC substitutes with a global warming potential (GWP) greater than 53 and a full refrigerant charge of 15 pounds or more, excluding most residential and light commercial air conditioning and heat pump equipment. That 15-pound threshold is dramatically lower than the 50-pound threshold that has applied under the legacy ozone-depleting substance (ODS) regulations at 40 CFR Part 82, meaning many facilities that were never previously subject to federal refrigerant management requirements — including office buildings, warehouses, data centers, multifamily housing, and small grocery and retail operations — may now be in scope.
Leak Rate Thresholds and Repair Deadlines
Owners must calculate an appliance’s annual leak rate each time refrigerant is added. If the calculated rate exceeds the applicable threshold — 10% for comfort cooling, refrigerated transport, and other covered appliances, 20% for commercial refrigeration, and 30% for industrial process refrigeration — the owner must identify and repair the leak within 30 days, or 120 days if an industrial process shutdown is required.
Verification Testing
Repairs must be confirmed with two tests: an initial verification test within the repair window and a follow-up test within 10 days of the initial test (or once the appliance returns to normal operating conditions). Testing must be performed and documented by a certified technician.
Retrofit or Retirement Plans
If an owner cannot complete a verified repair, or elects to retrofit or retire the appliance instead, a written plan is required within 30 days of the triggering leak. The plan must identify the appliance and refrigerant, describe the retrofit or retirement approach, address recovered refrigerant handling, and include a completion schedule not to exceed one year.
Ongoing Leak Inspections
Following a repair, appliances are subject to follow-up inspections: once every 3 months for systems of 500 pounds or more (until four consecutive compliant quarters), and annually for systems between 15 and 499 pounds and for comfort cooling and other appliances (until one year of compliance is demonstrated). These inspections are waived for appliances equipped with a continuously operating, annually calibrated automatic leak detection system.
Automatic Leak Detection Systems
Industrial process refrigeration and commercial refrigeration systems with a full charge of 1,500 pounds or more must be equipped with automatic leak detection (ALD) systems — required for new systems beginning January 1, 2026, and for existing systems beginning January 1, 2027.
Reclaimed Refrigerant Standards
For supermarket systems, refrigerated transport, and automatic commercial ice makers, servicing must transition to reclaimed-only refrigerant entirely by January 1, 2029.
Fire Suppression Equipment
Beginning January 1, 2026, EPA prohibits venting of regulated substances from fire suppression equipment and requires owners and operators to properly maintain systems to prevent releases. Fire suppression systems using covered HFCs must use recycled refrigerant for servicing and/or repair of existing fire suppression equipment, and refrigerant must be recovered before equipment is disposed of. Finally, employers must provide fire suppression technicians with one-time training on emissions-reduction practices, and regulated substances must be recovered from equipment before disposal, unless the equipment is sent intact to an authorized facility (manufacturer, distributor, or recycler) capable of recovering the substance.
Disposable Cylinders
Effective January 1, 2028, a person who uses a disposable cylinder containing a regulated substance in the course of servicing refrigerant-containing equipment or fire suppression equipment, and who does not intend to reuse that cylinder, must arrange for the cylinder’s heel to be removed (processed) rather than discarded with the substance still inside. The cylinder must be sent on to a certified reclaimer or a fire suppressant recycler.
Recordkeeping
Owners and reclaimers must retain records — including appliance specifications, service history, leak rate calculations, inspection results, verification test results, and any retrofit or retirement plans — for a minimum of three years.
Key Compliance Dates at a Glance
- January 1, 2026 — Leak repair, leak rate calculation, and reclamation standard/labeling/recordkeeping requirements take effect; automatic leak detection required for new qualifying systems.
- June 1, 2026 — Deadline for required HFC-handling training for fire suppression technicians. Newly hired fire suppression technicians must be trained within 30 days of hiring.
- January 1, 2027 — Automatic leak detection required for existing qualifying systems
- February 14, 2027 — First annual reclaimed-HFC report due to EPA from reclaimers, distributors and wholesalers. Reports will be due annually by February 14 of each year.
- January 1, 2028 — Disposable cylinders containing regulated substances (used in refrigerant or fire suppression servicing and not being reused) must be sent for heel removal/further processing.
- January 1, 2029 — Reclaimed-only servicing required for supermarket systems, refrigerated transport, and automatic commercial ice makers.
- January 1, 2030 — Initial installation of new fire suppression equipment must use recycled HFCs.
What This Means for Facility Owners and Operators
For many organizations, the most significant change is scope: the 15-pound applicability threshold brings a much wider range of equipment — and facility types — under federal refrigerant management requirements for the first time. Facility owners should not assume that because they were previously exempt under the ODS program, they remain exempt under the HFC Management Rule. Because leak rate calculations are now required every time refrigerant is added, facilities need reliable systems for tracking refrigerant additions, calculating leak rates accurately, and triggering repair or retrofit/retirement workflows before deadlines are missed. Facilities operating large refrigeration systems should also confirm their automatic leak detection installation, timelines, and calibration schedules are on track ahead of the January 1, 2027 deadline for existing equipment.
Recommended Actions
- Inventory all refrigeration, air conditioning, and fire suppression equipment to confirm whether it falls under the 15-pound/GWP-53 applicability threshold.
- Confirm leak rate calculation procedures are in place and are triggered every time refrigerant is added to a covered appliance.
- Review automatic leak detection installation and calibration schedules for systems of 1,500 pounds or more, particularly ahead of the January 1, 2027 deadline for existing systems.
- Update recordkeeping systems to retain the required leak rate, inspection, verification test, and retrofit/retirement plan documentation for at least three years.
How Trinity Can Help
Trinity Consultants helps facility owners and operators navigate refrigerant management compliance under both the legacy ODS program and the new HFC Management Rule, including refrigerant management services covering applicability determinations, leak rate tracking and recordkeeping system design, retrofit and retirement plan development, and support preparing for EPA inspections.
Call to Action
With core provisions of the HFC Management Rule already in effect and additional deadlines approaching in 2027 and 2029, now is the time to confirm your facility’s compliance status. If your operations involve refrigeration, air conditioning, or fire suppression equipment, we encourage you to reach out early to evaluate your obligations under this rule.
If you would like to discuss how the HFC Management Rule may affect your facility, please email Michael Brown in Trinity’s Albuquerque Office or call 505.266.6611.
