The EPA 15-lb Threshold: What Changes on January 1, 2026

Under the current rule (pre-2026), only systems containing 50 lbs or more of refrigerant are subject to EPA leak rate tracking requirements under 40 CFR Part 82, Subpart F. This meant most residential AC systems, small commercial units, and many light commercial rooftop units were exempt. Starting January 1, 2026, the threshold drops to 15 lbs. Any system — residential, commercial, or industrial — with a full charge of 15 lbs or more must now comply with leak rate tracking, mandatory repair timelines, and chronic leaker reporting.

The biggest impact falls on equipment that was previously below the 50-lb threshold but sits at or above 15 lbs. This includes residential split-system air conditioners (typically 5–25 lbs of R-410A), residential heat pumps, ductless mini-split systems with multiple indoor heads, small commercial rooftop units, reach-in coolers and display cases in convenience stores and restaurants, and walk-in coolers in small commercial kitchens. Systems below 15 lbs remain exempt from Subpart C requirements, though EPA venting prohibitions still apply to all systems regardless of charge size.

For every system with ≥15 lbs of refrigerant, equipment owners must track all refrigerant additions with dates and quantities, calculate leak rates using an EPA-approved method (Annualizing or Rolling Average), initiate repairs within 30 days if the calculated leak rate exceeds the category threshold (10% for comfort cooling, 20% for commercial refrigeration, 30% for industrial process), conduct verification testing after repairs, report chronic leakers (systems exceeding 125% of full charge in additions per calendar year) to the EPA by March 1 of the following year, and maintain records for a minimum of 3 years for audit purposes.

The threshold reduction is part of the AIM Act's broader strategy to reduce HFC emissions. By bringing smaller systems under regulatory oversight, the EPA expects to identify and repair leaks that have been going undetected for years. The agency estimates that the 15-lb threshold will prevent millions of pounds of additional refrigerant emissions annually — a significant contribution to climate goals under the Kigali Amendment.

Start by inventorying every system you own or service. Identify which systems have a full charge of 15 lbs or more — these are now in scope. For each regulated system, you need to know the full charge in lbs, the equipment category (comfort cooling, commercial refrigeration, industrial process, or transport), the refrigerant type, and the serial number and location. Next, choose your calculation method — Annualizing or Rolling Average — and apply it consistently across your organization. Finally, set up a tracking system that can calculate leak rates automatically, flag threshold exceedances, track repair deadlines, and generate audit-ready reports.