Navigating HFC Compliance in Washington State: Key Differences Between Federal and State Rules

Environmental Consulting

January 8, 2026

Share it with the world!

Hydrofluorocarbons (HFCs) are potent greenhouse gases used widely in air conditioning, refrigeration, and heat pump systems. While they’ve long played a critical role in modern cooling technologies, their high global warming potentials (GWP) make them significant contributors to climate change. Recognizing this, both the U.S. Environmental Protection Agency (EPA) and the Washington Department of Ecology (Ecology) have implemented rules to dramatically reduce HFC emissions over the next decade.

However, the federal HFC Management Rule under 40 CFR 84 and Washington’s rule under WAC 173‑443 differ in important ways. For companies operating in Washington, understanding these differences is essential for compliance. Operators may be subject to both sets of obligations, each with distinct thresholds, timelines, and reporting requirements.

Below, we’ll break down how the two programs align, where they diverge, and what steps organizations in Washington can take to prepare.

Federal HFC Management Rule: 40 CFR 84, Subpart C

In October 2024, the EPA issued its HFC Refrigerant Management Rule as part of the larger phasedown strategy authorized by the American Innovation and Manufacturing (AIM) Act. This rule modernizes refrigerant management requirements for HFCs and substitutes, expanding oversight similar to the historical stratospheric ozone protection programs for ozone depleting substances (ODS, including chlorofluorocarbons (CFC) and hydrochlorofluorocarbons (HCFC).

EPA’s approach includes the following key components:

Applicability: Covers systems with ≥15 pounds (lb) of HFC refrigerant (or other substitutes with GWP >53).
Leak Rate Calculation: Allows either an annualizing method or a rolling average method to determine the system’s leak rate.
Leak Repair Requirements: Triggered when the calculated leak rate exceeds threshold limits. Repairs, inspections, and verification testing are mandatory within specific timeframes.
Automatic Leak Detection Systems (ALDS): Required for systems with ≥1,500 lb of HFCs or substitutes to be installed by January 1, 2027.
Reporting: Annual submission of a chronic leaker report to the EPA.

Federal compliance began on January 1, 2026 when the leak repair, inspection, and reporting requirements become enforceable.

Washington State HFC Rule: WAC 173-443

Washington has long led the Pacific Northwest in climate policy, and its HFC Management Program is no exception. Adopted in late 2023, the Department of Ecology’s rule takes a more aggressive stance on reducing high‑GWP refrigerant usage and tightening maintenance standards. The rule introduces phased prohibitions, enhanced leak management, and mandatory reporting obligations for larger systems.

Key elements include:

Applicability: Systems with ≥50 lb of refrigerant with GWP ≥150 fall under program requirements.
Leak Rate Calculation: Only the rolling average method is allowed (the federal annualizing method is prohibited).
Leak Repair Requirements: Leaks must be repaired within 14 days of detection — half the federal timeline.
Reporting: Owners must submit annual service and refrigerant‑usage reports for all systems with ≥200 lb of full charge.
Registration: Systems must be registered with Ecology and undergo periodic leak inspections, including monthly inspections for large systems (≥1,500 lb), quarterly inspections for medium systems (200 to ≤ 1,499 lb), and annual inspections for small systems (50 to ≤ 199 lb).
Additional Requirements: Ecology’s rule includes ongoing notification and recordkeeping obligations, including purchase records, service event documentation, and leak notifications to the agency.

Washington’s rule phases in over several years:

January 1, 2024: Leak repair of all detected leaks
January 1, 2024: Monthly leak inspections for large systems (≥1,500 lb)
March 15, 2024: Registration for large systems (≥1,500 lb)
January 1, 2026: Quarterly leak inspections for medium systems (200 to ≤ 1,499 lb)
March 15, 2026: Registration for medium systems (200 to ≤ 1,499 lb)
January 1, 2028: Annual leak inspections for small systems (50 to ≤ 199 lb)
March 15, 2028: Registration for small systems (50 to ≤ 199 lb)

Major Differences Between Federal and Washington Rules

At first glance, the two rules appear similar in purpose, but for regulated entities, the differences have meaningful compliance implications.

Requirement	Federal HFC Rule (40 CFR 84)	Washington HFC Rule (WAC 173-44)
Applicability Threshold	≥15 lb HFC or substitute with GWP > 53	≥50 lb and GWP ≥150a
Leak Rate Calculation	Annualizing or rolling average	Rolling average only
Leak Rate Threshold	Comfort Cooling Appliances: 10% Commercial Refrigeration Appliances: 20% Industrial Process Refrigeration Appliances: 30%	Comfort Cooling Appliances: 8% Commercial Refrigeration Appliances: 16% Industrial Process Refrigeration Appliances: 24%
Leak Notification	Not required	Within 30 days of exceeding the leak rate threshold
Leak Repair Deadline	Within 30 days of exceeding leak rate trigger	Within 14 days of leak detection
Leak Inspection Schedule	Periodic inspections triggered after leak repair	Periodic inspections based on system size
Reporting	Annual "chronic leaker" report	Annual service & refrigerant usage report (≥200 lb)
Registration	Not required	Required for covered systems

_{a. Chlorofluorocarbon (CFC) and hydrofluorocarbon (HCFC) refrigerants covered by the stratospheric ozone protection requirements of 40 CFR 82, Subpart F may also meet the ≥50 lb threshold for compliance with the Washington HFC Rule. Compliance with 40 CFR 82, Subpart F should also be maintained (requirements similar to 40 CFR 84, Subpart C).}

Building a Compliance Strategy for Dual Regulation

Facilities operating in Washington must comply with both federal and state requirements. This dual framework means companies should create an integrated refrigerant management plan that covers both sets of obligations — particularly since inspection intervals, repair timelines, and reporting requirements differ. The following steps can help ensure alignment:

Inventory Systems. Catalog all refrigeration and air‑conditioning systems, noting refrigerant type, GWP, and full charge size.
Determine Applicability. Map which systems fall under the federal threshold (≥15 lb HFC or substitute with GWP >53) versus the state threshold (≥50 lb and GWP ≥150) to avoid missed obligations.
Update Leak Rate Calculation Method, if needed. Shift from annualizing calculations to rolling averages, as required by Washington, and standardize inspection routines to meet both rules.
Revise Repair Procedures. Aim for the stricter 14-day repair timeline where applicable — compliance to the tighter rule will automatically satisfy the longer federal window.
Enhance Reporting Systems. Develop internal tracking to collect annual service and usage data for submission to Ecology, while maintaining records needed for EPA’s “chronic leaker” reports.
Train Staff. Ensure technicians and maintenance teams understand both the state and federal frameworks, from tracking leaks to managing refrigerant inventories.
Identify Key Dates. Flag the upcoming compliance milestones when notification, reporting, and leak inspection requirements begin for different systems.

Trinity Consultants is here to help! If your facility is subject to 40 CFR 84 or Washington’s HFC rule and you need support, please contact Nancy Liang in Trinity’s Seattle office at 425.966.2973.