Starting January 1, 2026, the EPA lowered the refrigerant compliance threshold from 50 pounds to 15 pounds for systems containing high-GWP refrigerants. That is a 70% reduction in the tracking threshold, according to BSI Group analysis.
For multi-site operators, the impact is immediate. Rooftop HVAC units, small commercial refrigeration systems, and process cooling equipment that facilities never had to track before now require full compliance programs.
What Changed
The previous 50-pound threshold meant most standard rooftop units flew under the radar. At 15 pounds, a typical 5-ton RTU is now in scope. For a 200-location retail chain, that could mean adding hundreds of units to compliance tracking, according to Fexa's regulatory guide.
Additionally, the EPA now requires automatic leak detection systems in facility refrigeration systems with 1,500 pounds or more of refrigerant with a GWP greater than 53. Existing systems installed between 2017 and 2025 must retrofit by January 1, 2027, per Yorke Engineering analysis.
Leak Rate Standards
Annual leak rate thresholds are set at:
- 30% for industrial process refrigeration
- 20% for commercial refrigeration
- 10% for comfort cooling
These rates are now actively enforced, not advisory.
What to Do This Month
- Audit every refrigerant-containing unit across all locations. Any system with 15+ pounds of high-GWP refrigerant is now in scope.
- Verify technician certifications. All techs servicing covered equipment must hold EPA Section 608 or 609 certification.
- Build a refrigerant inventory system if you don't have one. Track type, charge size, and equipment ID for every unit.
- Check your leak detection requirements. If any location has 1,500+ pounds of total refrigerant, automatic leak detection is mandatory.
- Review vendor contracts. Make sure your HVAC and refrigeration providers understand the new thresholds and documentation requirements.