New HFC Management Rule: What Indiana Facilities Need to Know for 2026 Compliance

On October 11, 2024, the Units States Environmental Protection Agency (U.S. EPA) finalized the Hydrofluorocarbon (HFC) Management Rule under 40 CFR Part 84, Subpart C. This new rule establishes new nationwide requirements for the management, servicing, leak repair, and disposal of equipment containing HFC refrigerants and substitutes with a global warming potential (GWP) greater than 53.

Importantly, this rule does not replace the existing refrigerant management requirements under 40 CFR 82 for Class I and Class II ozone-depleting substances (ODS).This means that going forward, facilities must comply with the refrigeration requirements under both regulatory programs, each having their own set of requirements and applicability thresholds. Understanding applicability and compliance obligations under the new HFC Management Rule is therefore essential. The leak repair provisions under the new rule, a key compliance milestone, became effective on January 1, 2026. The leak repair provisions as well as additional compliance requirements and their applicability dates will be discussed in this article.

Why HFCs?

HFCs are synthetic, man-made gases originally adopted as replacements for ODS in refrigeration, air conditioning, aerosols, fire suppression, and foam blowing sectors. Common HFCs include R-125, R-134a, and R-23, and blends of HFCs including R-404A, R-410A, and R-407A. Although HFCs do not harm the ozone layer, they are potent greenhouse gases (GHGs) with GWPs hundreds to thousands of times greater than CO₂.

The American Innovation and Manufacturing (AIM) Act of 2020 authorizes the U.S. EPA to address HFCs through three main initiatives:

1. Phasing down production and consumption of listed HFCs,
2. Promulgating rules to minimize releases and maximize reclamation, and
3. Transitioning industries to next-generation technologies through sector-based restrictions.

U.S. EPA already finalized rules under the AIM Act in the first and third categories (the HFC Phase-Down Rule and the Technology Transitions Rule). The new HFC Management Rule implements the AIM Act’s second initiative.

Key Compliance Requirements

The final HFC Management Rule establishes a comprehensive set of requirements under the AIM Act for HFC-containing appliances. One key set of requirements is the leak repair provisions for appliances with a full charge greater than or equal to 15 lbs of HFCs or applicable substitutes. Note that each circuit in a multi-circuit unit is considered to be a unique appliance. Applicability is based on the charge of the individual circuit. Aside from repairing the leak, requirements also include verification testing after the repair and continued monitoring. These requirements do not apply to residential or light commercial systems. The leak repair provisions became effective on January 1, 2026, meaning facilities with subject appliances must currently follow the leak repair requirements.

Another key requirement is the installation of an automatic leak detection system (ALDS). Commercial and industrial appliances with a full charge greater than or equal to 1,500 lbs containing HFCs or applicable substitutes must have an ALDS installed. As of January 1, 2026, all newly installed appliances meeting the charge threshold must have the ALDS installed within 30 days of the appliance installation. All appliances meeting the charge threshold that were installed after January 1, 2017, but before January 1, 2026, must have the ALDS installed by January 1, 2027.

Also included in the new rule is the requirement to submit a chronic leaker report for any appliance with a full charge greater than or equal to 15 lbs containing HFCs or applicable substitutes that leaked 125% or more of its full charge in a calendar year. The chronic leaker report is also a requirement of the existing ODS provisions under 40 CFR 82. Under the HFC Management Rule, more information is required to be included in the report than under the ODS provisions. For subject HFC appliances, the first chronic leaker report for calendar year 2026 is due by March 1, 2027.

The HFC Management Rule also includes requirements for servicing, repair, and disposal, including technician certification requirements, refrigerant handling requirements, and reclamation standards.

Who Is Affected by the HFC Management Rule?

U.S. EPA’s new rule applies to a broad set of entities that own, operate, service, repair, recycle, dispose of, or install equipment containing HFCs or substitutes with a GWP greater than 53. Common HFC substitutes, such as hydrofluoroolefin (HFO)/HFC blends and some HFOs themselves are marketed as “low-GWP” replacements, but still have GWPs well above the 53 threshold. Therefore, even if a facility does not use a traditional HFC, it is essential not to assume the HFC Management Rule does not apply. Facilities must know which refrigerants are being used in their appliances and what their GWPs are in order to determine applicability.

Additionally, since the full charge threshold for the leak repair provisions under the HFC Management Rule is much lower than the existing leak repair provisions under the ODS Rule (15 lbs compared to 50 lbs), the HFC Management Rule will impact entities that were previously unaffected by the ODS provisions. Many larger systems were intentionally built with individual circuits containing full charges with less than 50 lbs, but greater than 15 lbs. Additionally, since HFCs were developed to replace ODS, many of these systems use HFC refrigerants. With this new rule, those systems will become subject to the leak repair provisions.

Industries in Indiana that are likely impacted by this new rule include manufacturing and industrial facilities for their potential industrial refrigeration and cooling processes, food and beverage distribution centers for their warehouse refrigeration/cold storage, data centers for their chilling generators, and any fire suppression system owners if their systems contain HFC-based agents. Because Indiana has a diverse manufacturing sector and significant refrigerated warehousing capacity, many facilities that previously considered themselves outside of U.S. EPA’s refrigerant rules may now be subject to the HFC Management Rule.

What Indiana Facilities Should Do Now

To prepare for compliance and minimize disruptions, facilities should:

1. Evaluate current refrigeration and fire suppression inventory. Identify all appliances containing HFCs or substitutes with a GWP of 53 or greater, and document their charge sizes and equipment type.
2. Review existing refrigerant management program. Because facilities must comply with both 40 CFR 82 and 40 CFR 84, facilities should determine where their current programs under 40 CFR 82 do or don’t meet the new requirements under 40 CFR 84. Namely, facilities should pay attention to their leak thresholds, service practices, disposal procedures, and recordkeeping.
3. Prepare for the 2026 leak repair obligations by training maintenance staff on the new threshold and verification testing requirements.
4. If operating a large commercial refrigeration or industrial process system, begin planning for capital investment and installation of ALDS.
5. Confirm that third-party refrigeration contractors understand the new HFC rules and that they employ certified technicians. One thing to keep in mind is that it is the facility’s responsibility to comply with the HFC Management Rule, not the contractor’s. Facilities should not rely on their contractors to ensure their compliance.

While this is a new federal rule, Indiana Department of Environmental Management (IDEM) inspectors may request documentation proving compliance with the rule during routine inspections. Noncompliance with the HFC Management Rule could result in a violation issued by IDEM.

Trinity’s Refrigerant Management Services

Trinity provides support and guidance to help clients achieve compliance with these regulations. The following lists some of our services related to refrigerant management compliance.

1. Refrigerant Compliance Program and Operating Procedures
2. Compliance Audits and Gap Assessments
3. CoolTracker365™ Implementation
   1. Microsoft Excel®-based tool designed to track compliance with Subpart F and Subpart C
4. Refrigerant Reporting Support
5. Refrigerant Management Training
6. Evaluating Refrigerant Phasedown Exposure

If you have any questions about how the new HFC Management Rule may affect your facility or need assistance managing compliance, please contact Trinity’s Indiana office or call 317.451.8100.