Is Your Chiller Covered? The 2026 Leak-Repair Rule, Refrigerant by Refrigerant

When EPA's preamble put rooftop units, split systems and heat pumps on commercial buildings inside the exempt residential and light commercial subsector, it drew one line the other way: "the exemption does not apply to a chiller" (89 FR 82718). If you service comfort cooling under the 2026 rule, chillers are most of what's left.

But "it's a chiller" doesn't settle it. The leak-repair section asks about the refrigerant before it asks about the equipment, and the refrigerants going into chillers right now land on both sides of the line. Two chillers in the same mechanical room can carry completely different paperwork.

The Test, in the Order the Rule Applies It

40 CFR 84.106(a) reaches a refrigerant-containing appliance with a full charge of 15 pounds or more where the refrigerant contains a regulated substance or a substitute with a global warming potential above 53. Then (a)(3) takes two groups back out.

Answer those three and you know whether the chiller has a § 84.106 leak-repair file. Everything after that — the threshold, the clocks — depends on what kind of chiller it is.

Chiller Refrigerants, One by One

Where the numbers come from. Compositions: EPA's SNAP listing notices — R-513A (80 FR 42053, 2015), R-514A (81 FR 32241, 2016), R-515B (85 FR 79863, 2020) — and, for R-454B, the 2020 SNAP proposal that described it (85 FR 35874). GWPs are computed the way § 84.64(b) prescribes for a blend — each part's value times its share — from appendix A for the HFCs (HFC-32 675, HFC-125 3,500, HFC-134a 1,430, HFC-227ea 3,220) and table 1 for everything else (HFO-1234yf and HFO-1234ze(E) 1, HCFO-1233zd(E) 4, HFO-1336mzz(Z) 2, trans-1,2-dichloroethylene — HCO-1130(E) — 5, ammonia and CO2 1). HCFC-123 and HCFC-22 are class II controlled substances (40 CFR part 82, subpart A, appendix B); HCFO-1233zd(E) is not on that list.

Three things in that table surprise people:

• A mostly-HFO blend can still be covered. R-515B is 91.1% HFO-1234ze(E), but its 8.9% HFC-227ea is a listed HFC, so (a)(1) reaches it at a GWP of 287. The GWP-above-53 test only matters when a refrigerant contains no listed HFC at all.
• Low-GWP isn't the same as uncovered. R-32, R-454B and R-513A are all under 700, and all three are inside § 84.106.
• Some chillers sit outside both rules. An R-1234ze(E), R-1233zd(E) or R-514A chiller has no listed HFC and a table 1 GWP far under 53, so § 84.106 doesn't reach it, and none of those is a class I or class II refrigerant, so § 82.157 doesn't either.

Covered Chillers: Which Threshold, Which Clocks

Once a chiller is in, its category sets the numbers.

• Comfort-cooling chillers: 10%. § 84.102 names chillers among comfort-cooling appliances, and comfort cooling's leak rate is 10% (§ 84.106(c)(2)(iii)). More on the categories in our threshold post.
• Refrigeration chillers: 20%. A chiller serving retail food or cold storage refrigeration is commercial refrigeration (§ 84.102), with a 20% leak rate ((c)(2)(i)).
• Process chillers: 30%. An appliance that uses 50 percent or more of its operating capacity for industrial process refrigeration is industrial process refrigeration (§ 84.102), with a 30% leak rate ((c)(2)(ii)) and 120 days instead of 30 to repair and pass the initial verification test when an industrial process shutdown is required ((d), (e)(1)).
• After an exceedance. A comfort-cooling chiller gets leak inspections once a year after its successful follow-up verification test, until it hasn't leaked in excess of its rate for a year ((g)(1)(iii)); a commercial refrigeration or industrial process chiller of 500 pounds or more gets them every three months until it hasn't for four quarters in a row ((g)(1)(i)), a smaller one once a year ((g)(1)(ii)). The inspection-frequency post walks through both.
• Automatic leak detection applies to industrial process and commercial refrigeration appliances of 1,500 pounds or more (§ 84.108(a)) — not to comfort-cooling chillers. A process chiller that size installed since January 1, 2017 needs it: at installation or within 30 days if installed from 2026, and by January 1, 2027 if installed from 2017 through 2025 (§ 84.108(b)).
• Records. By January 1, 2026 — or at installation for a newer chiller — the owner or operator determines the full charge and keeps the appliance file: who owns or operates it, where it is, the full charge and how it was determined (with the range, its midpoint and how the range was set, if the figure comes from an established range), any revisions, and the installation date, until three years after the chiller is retired (§ 84.106(l)(1)). Every installation, service, repair and disposal gets a service record ((l)(2)). If you're still settling the number, start with what "full charge" means.
• Chronic leaks. A covered chiller that leaks 125% or more of its full charge in a calendar year is reported to EPA by March 1 of the following year ((j)).

R-123 and R-22 Chillers: Still Part 82

A chiller running solely on R-123 or R-22 is outside § 84.106 at any size ((a)(3)(i)). That doesn't make it unregulated. Section 82.157 applies to appliances with a full charge of 50 pounds or more of a class I or class II refrigerant (§ 82.157(a)), with the same 10% comfort-cooling and 30% industrial process rates ((c)(2)) and its own March 1 chronic-leak report, sent to 608reports@epa.gov ((j), (m)).

And R-123 has a supply rule of its own: today, HCFC-123 that isn't used, recovered and recycled may be used as a refrigerant only in equipment manufactured before January 1, 2020 (§ 82.15(g)(5)(i), (iii)).

Your Next Chiller Decides

The Technology Transitions rule has turned new comfort-cooling chillers away from R-134a and R-410A. Since January 1, 2025, no stand-alone chiller for comfort cooling using a regulated substance, or a blend containing one, with a GWP of 700 or more may be manufactured or imported (§ 84.54(a)(10)(i)), and no field-assembled comfort-cooling chiller system using such a refrigerant may be installed ((c)(3); "system" and "install" are defined in § 84.52). Industrial process chillers with fluid leaving above −30 °C (−22 °F) followed on January 1, 2026, and those leaving between −50 °C and −30 °C follow on January 1, 2028 ((a)(10)(iii)–(iv); (c)(5)–(6)); chillers with a charge capacity of 100 pounds or less used in semiconductor manufacturing get until January 1, 2030 ((a)(10)(v); (c)(5)(ii), (c)(6)(ii)).

R-134a (1,430) and R-410A (2,088) are both over that line. The options under it split cleanly:

So the refrigerant on a new chiller's nameplate also decides whether it carries a leak-repair file at all: one on R-513A gets the full § 84.106 workflow at 15 pounds or more, one on R-1233zd(E) gets none under either rule.

Retrofits Can Move a Chiller Across the Line

• R-134a to R-513A keeps the chiller covered. The charge added immediately after the retrofit needs no leak-rate calculation (§ 84.106(b)); the full charge is whatever the chiller needs on its new refrigerant (§ 84.102), so the revision goes into the appliance file with how and when it was determined ((l)(1)(v)).
• R-123 to R-514A is a retrofit EPA's SNAP program lists as acceptable for centrifugal and positive-displacement chillers (81 FR 32241; still listed on EPA's SNAP chiller pages as of March 2026). Afterward the chiller holds no class I or class II refrigerant, so § 82.157 stops applying, and no listed HFC, with a GWP far under 53, so § 84.106 doesn't start.

Whichever side a chiller lands on, the starting point is the same: know what's on the nameplate and how much it holds. The rest of the year's work follows from those two lines.

Keep Going

• Which systems are exempt — rooftop units, splits and heat pumps
• Rooftop units and the 15-lb rule
• The 15-lb rule, start to finish
• The chronic-leaker rule
• Leak rate calculator, any refrigerant · R-134a leak rate calculator