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New EPA Refrigerant Regulations Under 40 CFR Part 84 Subpart C: Implications for the Refrigerant Industry

June 02, 2025

On December 10, 2024, the U.S. Environmental Protection Agency (EPA) implemented updates to its refrigerant management rules under 40 Code of Federal Regulations (CFR) Part 84 Subpart C. These updated regulations impose stricter limits on the use of reclaimed refrigerants and set lower compliance thresholds. The rule becomes fully effective on January 1, 2026, but businesses should begin preparing now to meet these standards.

Key Updates Under the New EPA Refrigerant Regulations

Effective January 1, 2026, the new regulations under 40 CFR Part 84 Subpart C introduce several key changes. Below are the most significant updates:

1. Lower Refrigerant Thresholds: The new rule sets lower thresholds for refrigerant amounts in stationary refrigeration systems that trigger regulatory requirements. Facilities that contain 15 pounds or more of refrigerants with a Global Warming Potential (GWP) greater than 53 will now be subject to the updated regulations. This makes the EPA’s regulations stricter than California’s current threshold, which remains at 50 pounds.
   • Many commonly used hydrofluorocarbons (HFC) refrigerants – such as R-134a (GWP 1430), R-404A (GWP 3922), and R-410A (GWP 2088) – fall into the category of refrigerants with a GWP higher than 53. With the new thresholds, businesses using these refrigerants may now find themselves subject to the federal rules, even if they previously did not meet the threshold.
2. Starting in 2025, restrictions will be placed on the use of HFCs with higher global warming potentials (GWPs) in new aerosols, foams, and refrigeration, air conditioning, and heat pump equipment.
3. Beginning in 2026, there will be new requirements for fire suppression systems, including required training, recycling, and reporting requirements.
4. Updated Leak Detection Requirements: As of January 2026, the EPA will require automatic leak detection systems in facilities with more than 1,500 pounds of refrigerant, if that refrigerant also has a GWP greater than 53. This is a lower threshold compared to the 2,000 pounds limit set by the California Air Resources Board (CARB) for systems using refrigerants with a GWP greater than 150. The new leak detection requirements mean that more facilities will need to install and maintain leak detection systems, adding a layer of compliance responsibility for a larger number of refrigerant-containing facilities.
5. Updated Leak Rate Determination and Repair Requirements: As of January 2026, any time refrigerant is added to an appliance – except in cases of retrofits, new appliance installations, or seasonal variances – the equipment is required to undergo a leak rate check. The leak rate can be calculated by an annualized or rolling average method. If the leak rate is over 20% for commercial refrigeration appliances, 30% for industrial process refrigeration requirements, or 10% for comfort cooling, transport, or other types of appliances not covered by the other two types, then:
   • The facility must identify and repair the leak within 30 or 120 days of detection;
   • The equipment must undergo a verification test within 30 or 120 days to indicate the repairs were successful;
   • The facility must conduct a follow-up verification test within 10 days of the initial test; and
   • Follow-up leak inspections must be conducted as follows:
     • Every 3 months for units containing more than 500 pounds of refrigerant; or
     • Annually for units with 15 to 500 pounds of refrigerant; and
     • Inspections will continue until the leak rate no longer exceeds the threshold.

Alternative options, such as retrofitting or replacing leaking equipment, are also available. Equipment with leak rates over 125% of capacity are still required to report to the EPA by March 1^st of each year.

Additionally, refrigeration appliances are required to maintain records, including equipment information, date of installation, full charge, service, and repair records and other information, until 3 years after the appliance is retired. Furthermore, reporting is required for extensions to complete repairs, retire equipment, and when excluding purged refrigerants from annual leak rate calculations.

6. Reclamation Standard: Effective January 1, 2026, no refrigerant can be sold, identified, or reported as reclaimed if it contains more than 15% virgin-regulated substance by weight. Virgin-regulated substance refers to any refrigerant that has never been used in equipment (i.e., new, unused refrigerant). This threshold significantly reduces the amount of virgin refrigerant that can be included in reclaimed products, encouraging the use of recycled materials.

What These Changes Mean for CARB-Registered Refrigerants

The updated EPA regulations will affect registered refrigerants. Specifically, those with refrigerants that exceed the 15 pounds threshold or GWP limits may need to be carefully tracked and reported.

Reclaimed refrigerants must meet the new standard for virgin refrigerant content, which could affect how refrigerants are processed and resold.

For CARB-registered refrigerants, the new EPA rule creates a situation where the federal standard is stricter in terms of refrigerant quantities and leak detection thresholds. Companies will be expected to comply with both State and federal requirements, particularly in systems with small-to-medium refrigerant amounts. A leak detection system will be required for applicable refrigeration units. For units installed in 2026, the system must be operational upon installation; for existing units, the requirement takes effect by January 1, 2027, in accordance with 40 CFR 84.108(b). This introduces a new compliance benchmark that companies will need to plan for in advance.

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Yorke Engineering specializes in refrigerant management reporting and regulatory analysis, helping businesses navigate these evolving requirements. Whether it’s assistance with compliance strategies, regulatory analysis, or detailed reporting for EPA and CARB standards, our team is here to provide expert guidance and ensure businesses meet regulatory obligations efficiently.

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