Is Your Rooftop Unit Covered? What EPA Says About Packaged RTUs, Commercial Splits, and Heat Pumps

No piece of equipment shows up on a small commercial contractor's schedule more often than the packaged rooftop unit. The strip mall has six of them. The dental office has two. The restaurant has one over the dining room and a walk-in below it in the kitchen. If your shop runs commercial maintenance agreements, RTUs are the book of business.

So it matters what EPA actually said about them. Subpart C's definition of comfort cooling names packaged rooftop units, and plenty of the industry — this blog included — read that as coverage. It isn't. In the preamble to the 2024 rule, EPA placed packaged rooftop units in the residential and light commercial air-conditioning subsector that § 84.106 exempts, whatever their charge.

The Test, Applied to a Roof

§ 84.106(a) makes the leak-repair rules apply to "refrigerant-containing appliances with a full charge of 15 or more pounds of refrigerant" where the refrigerant contains a regulated substance or is a substitute "that has a global warming potential greater than 53." Then paragraph (a)(3) takes two groups back out:

For rooftop equipment, (ii) is the question that decides almost everything — and the rule text doesn't define the subsector. EPA described it in the preamble, using its SNAP program's terminology rather than a regulatory definition.

What EPA Said About Rooftop Units

EPA said it is using the terminology of its SNAP program for the subsector, and that "the exemption applies to the categories of refrigerant-containing appliances used at these premises" (89 FR 82717–82718). The test is the kind of appliance — framed, in EPA's words, around equipment that cools "individual rooms, single-family homes, and small commercial buildings" (89 FR 82717). Here is how EPA described those categories:

• The SNAP end-use "includes equipment that cools enclosed spaces in households and commercial premises (excluding chillers)," and the list includes "packaged rooftop units" alongside central air conditioners, mini- and multi-splits, PTACs, and heat pumps (89 FR 82718).
• "An air conditioning appliance at a light commercial building would most likely be a rooftop AC unit, which is one type of light commercial air conditioning" (89 FR 82718). In the same passage EPA names single packaged units and split-system central air conditioners and heat pumps as exempt.
• Commenters asked EPA to draw the line at 65,000 Btu/h; EPA declined (89 FR 82718). One asked EPA to apply leak repair "to light commercial rooftop systems with a charge size greater than five pounds"; EPA declined that too, because "similar concerns would arise from making appliances commonly used in light commercial air conditioning (e.g., central air conditioners, rooftop AC units, etc.) adhere to the leak repair requirements" (89 FR 82719).
• The rooftop-unit description EPA cites notes that RTUs "can also be set up in an array to provide cooling or heating throughout a larger commercial establishment such as a department store or supermarket" — and EPA didn't say whether those arrays are in the subsector or not.

What EPA did place outside it: "a chiller" (89 FR 82718). The difference it points to is that rooftop units, splits, and heat pumps condition the air directly, while a chiller cools water that is then used to condition the air.

So for an HFC rooftop unit, the nameplate charge isn't what decides whether § 84.106's leak-repair rules apply. The kind of appliance does — and a new R-454B unit sits in the same subsector as the R-410A unit it replaced.

That definition still matters — it sets the 10% threshold (§ 84.106(c)(2)(iii)) for a comfort-cooling appliance that is covered. It doesn't decide whether an appliance is covered. The exemption post maps the whole line.

The Exceptions Worth Knowing

An R-22 rooftop unit at 50 pounds or more. An appliance containing solely an ozone-depleting refrigerant is outside § 84.106 entirely ((a)(3)(i)) — but it falls under the older Section 608 rule, § 82.157, which applies to appliances with "a full charge of 50 or more pounds of any class I or class II refrigerant or blend containing a class I or class II refrigerant." That rule has no residential or light commercial exemption; in EPA's words, "There are no exemptions for appliances with a charge size of 50 pounds or more of an applicable refrigerant." Comfort cooling there is judged at 10% (§ 82.157(c)(2)(iii)). Part 82 counts circuits the same way Subpart C does: "For a system with multiple circuits, each independent circuit is considered a separate appliance" (§ 82.152). So for an older R-22 unit, the nameplate charge — per circuit — still decides.

A rooftop unit that mostly serves a process. § 84.102 treats an appliance used for both process refrigeration and other applications as industrial process refrigeration "if 50 percent or more of its operating capacity is used for industrial process refrigeration," and that category is covered at 30%. EPA's preamble doesn't discuss rooftop units in that role. If a unit exists mainly to cool a process area rather than people, treat it as covered.

A rooftop array serving a large building. EPA's preamble speaks of "some rooftop AC units" and frames the subsector around small commercial buildings, without saying where an array on a department store or a large office building falls. Keeping the leak-rate records on those is the cautious choice.

VRF on the same roof. The 2024 preamble puts VRF inside the exempt subsector (89 FR 82719); EPA's January 2026 leak-repair fact sheet says "certain variable refrigerant flow systems are covered under their own subsectors." EPA's documents disagree, so for a large VRF system, keeping the leak-rate records is the cautious choice.

A supermarket rack that also provides comfort cooling. EPA says it "would not be exempt" (89 FR 82718). It isn't a rooftop unit, but it is an air-conditioning load on a grocery roof route that the exemption doesn't reach — EPA adds that "some but not all supermarket air conditioning systems" fall inside the subsector.

Where Your Covered Work Actually Is

The same maintenance route that runs past six rooftop units usually runs past the equipment the rule does cover: the walk-in cooler and freezer behind the restaurant, the reach-ins and display cases at the convenience store, the rack at the grocer, the chiller at the office park. At 15 pounds or more of a covered refrigerant, those are covered appliances — commercial refrigeration at 20%, comfort-cooling chillers at 10%, process refrigeration at 30% (§ 84.106(c)(2)).

For those appliances, everything the old version of this post said about the nameplate is still true:

• The full charge decides coverage. § 84.102 lets you determine it by the manufacturer's figure, by calculation, by measurement, or by an established range — and § 84.106(l)(1) wants the full charge and the method used to determine it on file for every appliance with 15 or more pounds. The full-charge post covers all four methods.
• Circuits count separately. "For such devices with multiple circuits, each independent circuit is considered a separate appliance" (§ 84.102). A multi-circuit chiller or rack is judged circuit by circuit, off the per-circuit charges.
• Small charges trip thresholds fast. With no earlier addition on record, the first annualizing calculation after January 1, 2026 substitutes 365 days (§ 84.106(b)(1); 89 FR 82724), so 3 pounds into an 18-pound circuit annualizes to 16.7% — under the 20% commercial refrigeration threshold, over the 10% a comfort-cooling chiller is judged at. Check your own numbers with the leak rate calculator.

When a calculation comes back over the threshold, the § 84.106(d) clock starts: repair within 30 days (120 if an industrial process shutdown is required), with the deadline running from the day refrigerant was added.

The Roof Inventory, Revised

If you maintain commercial accounts, one visit per site still sorts it out:

1. Photograph every nameplate. Model, serial, refrigerant, factory charge — per circuit where circuits are listed separately.
2. Sort by kind of appliance. Rooftop units, split systems, heat pumps, and PTACs are in the exempt subsector — but one with a full charge of 50 pounds or more of R-22, another class I or class II refrigerant, or a blend containing one is under § 82.157, and for a rooftop array serving a large building or a large VRF system, keeping the leak-rate records is the cautious choice. Chillers, refrigeration, and process equipment holding 15 pounds or more of a refrigerant containing a listed HFC are covered (for chillers, that turns on the refrigerant — see which ones).
3. File the covered ones properly. Per circuit, the (l)(1) record: who the owner or operator is; the address where the appliance is located; the full charge and the method used to determine it (and, if you used an established range, the range, its midpoint, and how the range was determined); any revisions to the full charge, how they were determined, and when; and the date of installation — kept until three years after the appliance is retired.
4. Tell the building owner which is which. The duty to calculate leak rates and repair on deadline sits with the appliance's owner or operator — your customer — and the contractor who can say "your rooftop units are outside the federal leak-repair rule; your walk-in and your chiller are in, and here's the file" is the contractor who owns that conversation.