Effective January 1, 2026
Refrigerant management requirements in the United States are governed primarily by Section 608 of the Clean Air Act and the American Innovation and Manufacturing (AIM) Act. Together, these EPA refrigerant regulations are designed to reduce environmental harm by preventing emissions, phasing down high-global warming potential (GWP) hydrofluorocarbons (HFCs) and accelerating the transition to lower-GWP alternatives.
For facility owners and operators, these rules establish obligations related to refrigerant leak rate tracking, 30-day repair timelines, automatic leak detection, technician certification, recordkeeping and long-term refrigerant transition planning. Understanding how Section 608 and the AIM Act apply to your equipment is essential to managing regulatory risk and controlling operational costs.
Key Refrigerant Compliance Changes
Recent updates under the AIM Act expand refrigerant management requirements and increase oversight for many facilities. Several changes have direct operational and financial implications:
- Leak rate tracking now applies to systems with charges as low as 15 pounds of regulated HFC refrigerant
- Automatic leak detection systems are required for certain commercial and industrial refrigeration systems with charges of 1,500 pounds or more
- HFC phasedown milestones reduce allowable production and consumption, influencing refrigerant availability and pricing
- Sector-based GWP limits affect the manufacture and installation of new equipment
These changes bring more equipment into regulatory scope and place greater emphasis on documentation, repair verification and long-term refrigerant planning. Facilities that evaluate these impacts early are better positioned to align maintenance practices with evolving EPA expectations.
Regulatory Framework Overview
Clean Air Act Section 608 (40 CFR Part 82)
Section 608 focuses on preventing emissions of ozone-depleting substances (ODS) and other regulated refrigerants through best management practices for handling, servicing and disposal of refrigeration and air conditioning equipment.
The rule applies broadly to refrigerant-containing appliances and emphasizes leak prevention, recovery and proper disposal. Key objectives include:
- Prohibiting intentional venting of most refrigerants
- Reducing emissions of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs)
- Maximizing refrigerant recovery and recycling
- Ensuring proper end-of-life management of refrigerant-containing equipment
Section 608 forms the foundation of EPA refrigerant leak repair and inspection requirements.
American Innovation and Manufacturing (AIM) Act (40 CFR Part 84)
The AIM Act addresses climate impacts by phasing down the production and consumption of HFCs and regulating substitutes with a GWP greater than 53. Unlike Section 608, the AIM Act applies beyond refrigeration and affects aerosols, foams and fire suppression systems.The AIM Act establishes:
- A national HFC phasedown schedule
- Leak management requirements for certain HFC-containing equipment
- Sector-based GWP restrictions for new systems
- Lower refrigerant charge thresholds for leak tracking
Together, Section 608 and the AIM Act expand the scope of refrigerant compliance for many facilities.
Core Refrigerant Compliance Requirements
Leak Rate Tracking and Repair
Leak rate tracking is a central requirement under both programs. Facilities with systems containing as little as 15 pounds of regulated refrigerant may now fall under federal leak tracking requirements. This expansion affects many smaller systems that were previously outside federal leak management rules, especially in commercial buildings and distributed refrigeration operations.
| Requirement | Section 608 | AIM Act |
| Regulated substances | ODS | HFCs, HFC blends and substitutes with GWP > 53 |
| Leak rate tracking threshold | ≥ 50 lbs. | ≥ 15 lbs. |
If annualized leak rates exceed EPA limits, repair or replacement must occur within 30 days:
- Industrial process refrigeration: 30%
- Commercial refrigeration: 20%
- Comfort cooling: 10%
Verification testing is required to confirm repairs are effective, with both initial and follow-up tests documented.
Automatic Leak Detection Requirements
Under the AIM Act, automatic leak detection systems are required for:
- Commercial or industrial process refrigeration systems
- With refrigerant charges of 1,500 pounds or more
Compliance deadlines include:
- Systems installed after January 1, 2026: Must comply within 30 days of installation
- Systems installed between 2017 and 2026: Must comply by January 1, 2027
Automatic leak detection systems must be calibrated annually. These requirements directly affect large manufacturing facilities, cold storage warehouses and industrial refrigeration operations.
Inspection and Maintenance Requirements
Leak inspections must be conducted by Section 608-certified technicians. Inspection frequency depends on system type and refrigerant charge. In some cases, properly functioning automatic leak detection systems may reduce or eliminate manual inspection requirements. Maintaining consistent inspection schedules helps prevent violations tied to missed repair deadlines.
Venting Prohibition and Technician Certification
Intentional venting of refrigerants during service, maintenance or disposal is prohibited, with limited exceptions. Technicians servicing refrigerant-containing equipment must pass an EPA-approved certification exam and maintain certification records. Technician certification remains a common focus during EPA inspections and enforcement actions.
Recordkeeping and EPA Reporting Requirements
Facilities must maintain detailed records documenting: Equipment refrigerant charges; Service, maintenance, and refrigerant movement; Leak inspections and verification testing; Automatic leak detection system calibration; and Retrofit or retirement plans.
EPA reporting is required in specific circumstances, including repair deadline extensions and significant leak events.
Technology Transition and Refrigerant Phaseouts
Ozone-Depleting Substances (ODS)
ODS refrigerants are classified as Class I (e.g., CFCs, halons) or Class II (HCFCs). Production and import of these substances have been largely phased out under the Montreal Protocol, though recovered and reclaimed refrigerants may still be used to service legacy equipment.
HCFCs such as R-22 are no longer produced or imported but remain in use for servicing existing systems.
HFC Phasedown Under the AIM Act
Under the AIM Act, HFC consumption will be reduced by 85% by 2036 compared to baseline levels. The phasedown occurs in steps, with significant reductions scheduled for 2029 and beyond. This allowance-based system affects manufacturers and importers but drives downstream impacts for equipment owners through availability and cost.
Sector-Based GWP Restrictions
The AIM Act also establishes GWP limits and compliance dates for new products and systems where lower GWP technologies are available. These restrictions apply only to new equipment and do not mandate retrofits of existing systems.
Notable affected sectors include: Comfort cooling and stationary air conditioning, Industrial process refrigeration, Cold storage warehouses, Data centers, and Foam and aerosol products.
Common Refrigerants and Lower-GWP Alternatives
Regulated refrigerants span ODSs, high-GWP HFCs, and emerging substitutes. Industry trends increasingly favor low-GWP options such as carbon dioxide, ammonia, hydrocarbons, and hydrofluoroolefins (HFOs), which support compliance while reducing environmental impact.
Proactive Compliance Is Essential
Refrigerant regulations under Section 608 and the AIM Act represent a significant shift toward emissions prevention and climate focused technology transition. For facility owners and operators, proactive compliance, through effective leak management, robust recordkeeping, and strategic planning for refrigerant transitions, is essential to manage regulatory risk, control costs, and support long-term sustainability goals.
Organizations that understand these requirements and plan ahead are best positioned to navigate the evolving regulatory landscape and successfully transition to the next generation of refrigerant technologies. If you’d like to evaluate your current program or identify potential compliance gaps, contact our team to start the conversation.
