As of January 1, 2026, refrigerant regulations in the United States have undergone YET ANOTHER big shift. Per Subsection H of the American Innovation and Manufacturing (AIM) Act, which was passed by Congress and signed into law in December 2020, the Environmental Protection Agency (EPA) has officially expanded leak repair and recordkeeping requirements to a much broader range of equipment.

​The most critical change for facility managers and HVAC technicians is the new 15-pound threshold, which effectively replaces the long-standing 50-pound limit for many systems.

​What is the 15-Pound Rule?

​For years, EPA Section 608 focused primarily on “large” appliances containing 50 or more pounds of ozone-depleting substances, like R-12 and R-22. However, the new regulations target hydrofluorocarbons (HFCs) and their substitutes with a Global Warming Potential (GWP) greater than 53. That includes R-410A and most A2L refrigerants, including R-32 and R-454B.

​If a system contains 15 pounds or more of these refrigerants, it is now subject to federal leak repair, inspection, and reporting mandates. This includes:

• ​Comfort Cooling: Standard office and commercial HVAC systems.
• ​Commercial Refrigeration: Walk-in coolers, reach-in freezers, and supermarket racks.
• ​Industrial Process Refrigeration (IPR): Systems used in manufacturing and cold storage.

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Key Requirements Under the New Rule

​Compliance is no longer just about fixing a leak; it is about rigorous documentation. According to the EPA’s official regulatory updates, facility owners and operators must now adhere to the following:

1. Mandatory Leak Rate Calculations: Every time refrigerant is added to a system (above 15 lbs), a leak rate must be calculated and recorded.

2. Strict Repair Timelines: If a system exceeds the allowable leak rate (e.g., 20% for commercial refrigeration or 10% for comfort cooling), owners generally have 30 days to conduct a verified repair.

3. Chronic Leak Reporting: A new and vital requirement is the reporting of “chronically leaking” appliances. If a system leaks 125% or more of its full charge in a single calendar year, it must be reported to the EPA by March 1 of the following year.

4. Automatic Leak Detection (ALD): For massive systems containing 1,500 pounds or more, the EPA now mandates the installation of automatic leak detection systems to catch emissions in real-time.

​Using Technology to Stay Compliant

​The complexity of these new rules makes manual paper logs nearly obsolete. A digital solution with the app FMHero was developed to fill the gap for facility teams; so many of them are currently unprepared for the sheer volume of data tracking required.

​FMHero’s specialized platform helps contractors and owners automate these new requirements by:

• ​Auto-calculating leak rates based on refrigerant additions.
• Flagging chronic leakers before they hit the 125% reporting threshold.
• ​Storing 3 years of records in an “audit-ready” digital format, as required by law.

​Why This Matters Now

​The drop from 50 pounds to 15 pounds isn't just a minor adjustment—it’s a huge expansion in the sheer amount of equipment with those leak rate regulations, 70%! Small to medium-sized businesses that were previously exempt now face the same federal scrutiny as industrial plants.

​To avoid steep fines and ensure environmental compliance, facility managers should immediately conduct an inventory of all equipment between 15 and 50 pounds and implement a digital tracking system to manage the 2026 requirements.

While the EPA does not have a history of fining individual techs, it does have a history of fines levied against businesses. While the recordkeeping may be an annoyance to us technicians, it can be costly to customers in the future.

I just want to make it clear that I have no part in the laws passed by Congress nor the EPA regulations. I am simply passing on information. 

Have a great day and never stop learning.

—Ty Branaman

References

Code of Federal Regulations (eCFR) – Title 40, Section 84.106 (Leak Repair) – https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.106

FMHero – Refrigerant Management Platform https://www.fmhero.com/

Library of Congress – S.2754 – 116th Congress (2019-2020): American Innovation and Manufacturing Act of 2019 – https://www.congress.gov/bill/116th-congress/senate-bill/2754/text