EPA Leak Repair Rules: Part 82 and Part 84

Both rules use the same structure: calculate the leak rate when refrigerant is added, repair within a deadline if the rate is over the trigger, verify the repair, and keep records. They differ mainly in which equipment they cover. The obligations fall on the appliance owner or operator. Technicians do the leak inspections and verification tests and supply the service records.

Since April 10, 2020, 40 CFR 82.157 applies only to appliances with a full charge of 50 pounds or more of a class I or class II refrigerant, or a blend containing one. In practice that usually means R-22 and older CFC or HCFC equipment. It does not apply to appliances that contain only substitute refrigerants (40 CFR 82.157(a)). EPA's Q&A makes the same point: leak inspections and verification tests under Part 82 are not required for smaller appliances, for appliances below the trigger rate, or for HFC equipment.

The rule groups appliances by use. Commercial refrigeration is retail food and cold storage. Industrial process refrigeration covers equipment tied to industrial processes, plus industrial ice machines, power generation and ice rinks. Comfort cooling is air conditioning for occupied buildings, including chillers, commercial split systems and rooftop units (40 CFR 82.152).

The leak rate is the percentage of the full charge that would be lost over 12 months if the current rate of loss continued (40 CFR 82.152). The owner or operator must calculate it every time refrigerant is added. The exceptions are additions made right after a retrofit, at installation of a new appliance, or as a seasonal variance. The same calculation method must be used for all covered appliances at a facility.

Whoever adds or removes refrigerant must give the owner a service record when the job is done (40 CFR 82.157(b)). The record shows the appliance, the date, the parts serviced, the work done, the technician's name, and the amount and type of refrigerant added (40 CFR 82.157(l)(2)).

The trigger rates are 20 percent for commercial refrigeration, 30 percent for industrial process refrigeration, and 10 percent for comfort cooling and all other appliances with 50 pounds or more (40 CFR 82.157(c)(2)).

Once an addition shows the trigger rate has been exceeded, the owner has 30 days to find and repair the leaks, or 120 days if an industrial process shutdown is needed (40 CFR 82.157(d)). The repair has these steps:

• A certified technician does a leak inspection to find where the leaks are. Methods that only show that a system is leaking, such as standing pressure or vacuum decay tests, sight glass checks or receiver levels, must be paired with one that finds the leak's location (40 CFR 82.152).
• Repairs must bring the leak rate below the trigger, confirmed by the calculation at the next addition.
• An initial verification test is done within the 30-day (or 120-day) window, after the repair and before any refrigerant is added (40 CFR 82.157(e)(1)).
• A follow-up verification test is done within 10 days of the successful initial test, or within 10 days of the appliance reaching normal operating conditions if it was evacuated for the repair (40 CFR 82.157(e)(2)).
• Timelines are paused while an appliance is mothballed, that is, evacuated to at least atmospheric pressure and temporarily shut down. They restart when refrigerant is added again (40 CFR 82.157(d)(3)).

More time to repair is allowed only in set cases: radiological contamination, other federal, state or local rules that make the deadline impossible, or replacement parts that can't be delivered in time. In the parts case, the extension runs to 30 days after delivery, up to 180 days (270 with an industrial process shutdown) from when the leak rate was exceeded. Leaks that significantly contribute to the exceedance and don't need extra time must still be fixed on schedule. The owner documents the repair efforts and requests the extension from EPA within the original 30- or 120-day window (40 CFR 82.157(f)).

Instead of repairing, or when repairs fail, the owner must write a retrofit or retirement plan within 30 days and finish the work within one year of the plan's date (40 CFR 82.157(h)). Owners are automatically allowed 18 months to retire an appliance if its replacement uses an exempt substitute refrigerant. Industrial process refrigeration can get more time for custom-built equipment with a quoted delivery of more than 30 weeks (40 CFR 82.157(i)). An owner can be relieved of the plan by showing within 180 days of the plan's date that the leak rate is now below the trigger, and agreeing in writing to repair all identified leaks.

An appliance that exceeded its trigger rate needs follow-up leak inspections by a certified technician. Commercial and industrial process refrigeration with 500 pounds or more is inspected every three months until it stays below the trigger for four quarters in a row. Smaller commercial and industrial process refrigeration, and comfort cooling and other appliances, are inspected once per calendar year until they stay below the trigger for one year. An annually audited or calibrated automatic leak detection system can replace these inspections (40 CFR 82.157(g)).

Records are kept for at least three years. They include the full charge and how it was determined, service records, leak inspection results, verification test dates and results, retrofit or retirement plans, and extension requests (40 CFR 82.157(l)). Technicians who do leak inspections or verification tests must give the owner documentation of them at the end of the job.

Any appliance with 50 pounds or more that leaks 125 percent or more of its full charge in a calendar year is a chronic leaker. The owner must report it to EPA by March 1 of the following year, describing efforts to find and repair the leaks (40 CFR 82.157(j)).

Under the AIM Act, EPA added leak repair rules for HFC equipment in 40 CFR Part 84, Subpart C. They apply from January 1, 2026. They cover refrigerant-containing appliances with a full charge of 15 pounds or more of an HFC, or of a substitute with a GWP greater than 53 (40 CFR 84.106(a)).

Two groups are excluded: appliances containing only an ozone-depleting refrigerant, which stay under Part 82, and appliances in the residential and light commercial air conditioning and heat pump subsector (40 CFR 84.106(a)(3)). Part 84 does not define that subsector. In the 2024 rule's preamble (89 FR 82717), EPA describes it, using its SNAP program terms, as equipment that cools individual rooms, single-family homes and small commercial buildings. That includes split systems such as ducted and ductless mini-splits, multi-splits and ducted unitary splits, and self-contained units such as PTACs, window units and some rooftop units. It does not include chillers in larger centrally cooled buildings. Comfort cooling outside the subsector, such as chillers and larger commercial systems, is still covered. The trigger rates match Part 82: 20, 30 and 10 percent, with refrigerated transport in the 10 percent group (40 CFR 84.106(c)(2)). The same 30- and 120-day repair deadlines and initial and 10-day follow-up verification tests apply. Repairs and leak inspections must be done by a technician certified under 40 CFR 82.161.

Other details differ. Chronic-leaker reports apply to appliances of 15 pounds or more that leak 125 percent of their charge in a year (40 CFR 84.106(j)). Extension requests go through EPA's electronic reporting platform. Commercial and industrial process refrigeration systems with 1,500 pounds or more must have automatic leak detection: at installation (or within 30 days) for systems installed from January 1, 2026, or by January 1, 2027, for systems installed from 2017 through 2025 (40 CFR 84.108).

On May 26, 2026, EPA proposed exempting road and intermodal container transport refrigeration units from 40 CFR 84.106, whatever their charge (91 FR 30532). Comments closed on July 10, 2026. As of October 27, 2026, EPA had not finalized it: the eCFR text of 84.106 has no such exemption, and EPA's HFC management page still lists it as a proposed rule. Until a final rule is published, those units of 15 pounds or more remain covered.

EPA has not said that the Section 608 test content has changed because of the Part 84 rule. The current test topics for Types II and III still list the allowable leak rates for commercial and industrial process refrigeration and for 'other appliances containing more than 50 pounds', along with leak repair recordkeeping, extensions, leak inspections and chronic-leaker reporting (EPA: Test Topics).

For the test, know the Part 82 numbers: 50 pounds, 20/30/10 percent, 30 days (120 with an industrial process shutdown), and the 125 percent chronic-leaker report. For the job, check which rule applies to the equipment in front of you. An R-22 rooftop unit with 60 pounds falls under Part 82. A 40-pound R-404A walk-in falls under Part 84. A residential R-410A split system falls under neither leak repair rule, though the venting ban and recovery rules still apply.