The Day-One Appliance File: What § 84.106(l)(1) Requires the Moment a 15-lb System Goes In

The unit is set, the line set is brazed, the charge is weighed in, and the customer is signing the ticket. Somewhere in the next hour a question comes up that nobody used to ask on install day: what does the EPA want on file for this thing, right now?

For a covered appliance — 15 pounds or more of an HFC or another regulated refrigerant — the answer is not "nothing until it leaks." Under 40 CFR § 84.106, two records come into existence the day the system is commissioned. One belongs to the owner and lives until three years after the appliance is retired. The other is the install event itself, and if you are the contractor who did the work, the rule puts the duty to produce it on you.

What the rule does not ask for on day one is a leak-rate calculation. That matters, because the same paragraph that excludes the install charge from the math also decides what the file has to say about it.

Who This Applies To

Coverage is decided by the appliance, not by the job. § 84.106(a) applies to refrigerant-containing appliances "with a full charge of 15 or more pounds of refrigerant" where the refrigerant is a regulated substance (the HFCs) or a substitute with a global warming potential greater than 53. Two carve-outs: appliances running solely on an ozone-depleting refrigerant such as R-22 (those are governed by the older Section 608 rule in 40 CFR part 82, not by Subpart C), and appliances "used for the residential and light commercial air conditioning and heat pump subsector." The section has applied since January 1, 2026.

So a 20-pound R-410A packaged unit on a restaurant roof is in. A 60-pound R-134a chiller serving an office building is in. A residential split system is out, whatever its charge. The 15-pound rule post walks the applicability line; the rooftop-unit post covers the dual-circuit wrinkle, because § 84.102 counts "each independent circuit" of a multi-circuit device as its own appliance.

If the new system is covered, read on. Both records below exist for it as of the day it is installed.

Record One: The Appliance File — (l)(1)

The appliance file is the record most contractors know exists and few have seen written out. Paragraph (l)(1) sets both the deadline and the contents:

Three things in that text decide what "day one" means.

"Upon installation." For equipment already in service the deadline was January 1, 2026. For anything installed on or after that date, the deadline is the installation itself. There is no thirty-day window and no "by the first service call." The file is due when the appliance is.

"Determine the full charge." This is an act, not a lookup. § 84.102 defines full charge with four permitted determination methods — the manufacturer's figure, a calculation from components and piping, actual measurement, or an established range using its midpoint — and (l)(1)(iii) makes the method part of the record. The full-charge post covers which method fits which equipment; the day-one point is that install day is the one time in an appliance's life when method 3, actual measurement, is sitting on your scale. You just weighed the charge in. Write it down with the method beside it, and the hardest field in the file is done before you leave the roof.

"The date of installation." Field (vi) has no qualifier. The rule does not say "if known," and for a system you are installing today there is no reason it should. This is also the date that anchors the rest of the appliance's life under the rule: it is the start of the file's clock, and it is the one date an inspector can check against the invoice.

The remaining fields are the owner's identity, the address, and, if the range method was used, the range, its midpoint, and how the range was derived. Field (v), revisions to the full charge with dates and methods, is empty on day one and stays empty until someone changes the number — which, as the full-charge post explains, is itself a compliance event, not an edit.

One thing the file does not list, and should carry anyway

The § 84.102 appliance category — comfort cooling, commercial refrigeration, or industrial process refrigeration — is not among the six (l)(1) fields. But it is the fact that sets the leak-rate threshold (10, 20, or 30 percent) every future calculation on this appliance is judged against, and the category post shows how often it is misfiled. Install day is when the use is clearest: you know what the unit serves. Record the category and the reason with the file. The rule does not require it; the next three years of arithmetic depend on it.

Record Two: The Install Event — (l)(2)

The second record is the one contractors underestimate, because they think of (l)(2) as the service record. It is broader than that. Paragraph (l)(2) requires a record "for each time a refrigerant-containing appliance with a full charge of 15 or more pounds is installed, serviced, repaired, or disposed of." Installation is the first trigger on the list.

On install day, seven of the eight fields are ordinary ticket data: which appliance, where, the date, what was installed, what kind of work, who did it, and the full charge. Field (vi) is the initial charge — the amount and type of refrigerant that went in. Field (viii) is where install day differs from every other day in the appliance's life: the leak-rate field is "not applicable when … installing a new refrigerant-containing appliance." The record still exists. The leak rate on it is blank by rule.

The service-ticket teardown goes through these fields for a repair call. The install version is the same form with a different reason for the blank in field (viii).

The Handoff Is Yours — (l)(4)

If you are installing equipment you do not own, one more paragraph applies to you directly. § 84.106(l)(4):

Paragraph (b) says the same thing from the other direction: persons adding or removing refrigerant "must, upon conclusion of that installation, service, repair, or disposal, provide the owner or operator with documentation that meets the applicable requirements of paragraph (l)(2)." The owner keeps the file; the installer has to deliver its first page. The handoff post covers what that duty does and does not make you responsible for. The short version for install day: the ticket you leave behind is a federal record, and it needs fields (i) through (vi) on it — appliance, location, date, parts, type of work, your name, and the amount and type of refrigerant charged.

What Is Not Due on Day One: A Leak Rate

This is the part worth getting exactly right, because the corpus of half-remembered rules has an "initial leak inspection" in it that the regulation does not.

§ 84.106(b) requires the owner or operator to "calculate the leak rate every time refrigerant is added to an appliance unless the addition is made immediately following a retrofit, installation of a new refrigerant-containing appliance, or qualifies as a seasonal variance." The initial charge is refrigerant added; it is also expressly excluded from the calculation. There is no leak-rate number to produce on install day, no threshold to compare it against, no 30-day repair clock, and no inspection duty triggered by the installation itself. The rule's leak inspections under paragraph (g) apply to an appliance that has exceeded its leak rate and run from the date of a successful follow-up verification test; they are not a commissioning step.

So the install charge is recorded — field (vi) of the (l)(2) record, with the leak-rate field marked not applicable — and the math starts with the first addition after it.

The clock question the record has to survive

Here is where the installation date earns its place in the file. When that first post-install addition happens, the annualizing method in § 84.102 runs four steps, and Step 2 is the one that depends on history:

Take a 60-pound comfort-cooling chiller commissioned September 8 that needs four pounds on December 7, ninety days later. Step 1 is the same either way: 4 ÷ 60 = 0.0667. Step 2 depends on what counts as "the last day refrigerant was added." If the install charge does not start the clock — treated the way the rule treats it for the calculation itself, as an addition outside the math — the appliance has no prior counted addition and Step 2 uses 365 days: the result is 6.7%, under the 10% comfort-cooling threshold. If the install charge does start the clock, Step 2 uses 90 days and the same four pounds annualize to 27.0% — over the threshold, 30-day repair clock running.

The rule text does not say which. Paragraph (b)(1) provides a first-calculation substitution — an appliance calculating "for the first time after January 1, 2026" uses 365 days as the number of days since the last addition — and the final-rule preamble ties that relief to missing history: at 89 FR 82724 EPA says the substitution "is only allowed when previous records are absent," and that after "the first calculation of an appliance's leak rate, the owner or operator must use the shorter number of days since refrigerant is added or 365 days for subsequent leak rate calculations." Neither passage says how any of that applies to a system installed after the rule took effect, whose initial charge is documented in the file but excluded from the calculation. We are not going to tell you the answer the regulation has not given. We will tell you what Ref LeakLog does: it takes the second reading. The install charge is logged as a new-installation event with no leak rate, and the first counted addition after it annualizes over the days since the install — the conservative of the two numbers, and the one an inspector can never say you understated. And we will tell you the one thing that is true under either reading: the file that makes both numbers computable is the one that records the installation date and the initial charge on day one. A record that carries "installed Sept 8, 2026, 60.0 lb R-134a, method 3, actual measurement" answers whichever question an inspector asks. A record that says "installed sometime this fall" answers neither.

One More Clock, for the Big Installs Only

If the new appliance is commercial refrigeration or industrial process refrigeration with a full charge of 1,500 pounds or more — a supermarket rack, a cold-storage system, a process chiller — § 84.108(b)(1) requires an automatic leak detection system "upon installation of the refrigerant-containing appliance or within 30 days of installation." Comfort cooling is not in that paragraph, and neither is anything under 1,500 pounds. For the 15-to-1,500-pound population most contractors install, it does not apply; for the one that does, the 30 days start on the same installation date the (l)(1) file records.

The Day-One Checklist

Everything above reduces to a short list. Before the truck leaves:

1. Decide coverage per circuit. Full charge of 15 pounds or more, regulated refrigerant or a substitute over GWP 53, not residential or light-commercial AC. Each independent circuit is its own appliance.
2. Determine the full charge and name the method. You weighed it in; method 3 is on your scale. If you used the nameplate, say method 1. Range method: record the range, the midpoint, and the basis.
3. Record the installation date. Field (l)(1)(vi). No qualifier, no estimate.
4. Write the category down, with the reason. Not an (l)(1) field. Sets the threshold for the next three years.
5. Create the install record. (l)(2) fields (i)–(vii), initial charge in (vi), leak rate marked not applicable under (viii).
6. Hand the record to the owner. (l)(4) and (b): fields (i)–(vi), on the ticket, at the conclusion of the work.
7. Set the ALD clock if it is a 1,500-pound-plus commercial or process system. Thirty days from installation.

Every item on that list is a record you can keep in electronic or paper form under the (l) chapeau, and every one of them is due on the day the system starts running. The free refrigerant tracking spreadsheet has an appliance-file sheet built around the (l)(1) fields if you want to start on paper; the refrigerant log guide covers the (l)(2) record in full.