Free Compliance Tools
Is It Covered? The EPA Leak Repair Rule Checker
Free · 40 CFR 84.106 and 82.157, each step cited · Nothing stored
Before a leak rate or a repair deadline means anything, one question comes first: does a federal leak-repair rule reach the appliance at all? Since January 1, 2026 (§ 84.106(a)(4)), the answer turns on three things: what is in the refrigerant, how much the appliance holds, and what kind of appliance it is. EPA places rooftop units, split systems and heat pumps in the exempt residential and light commercial subsector. Chillers and refrigeration of 15 lbs or more are covered, unless the refrigerant contains no listed HFC and has a GWP of 53 or less. R-22 and R-123 equipment answers to the older Section 608 rule at 50 lbs or more. This checker runs the applicability function Ref LeakLog uses for every appliance in a fleet, with the refrigerant test in front of it, and cites the paragraph behind each step.
Check an Appliance
The Appliance
- What's in it:
- HFC-32 / HFC-125 (50/50)
- Listed HFC:
- Yes, HFC-32, HFC-125
- GWP (§ 84.64):
- 2,088
The amount the appliance needs for normal operation: the manufacturer's figure, a calculation, measurements, or the midpoint of an established range, alone or in combination. Each independent circuit of a multi-circuit system is a separate appliance (40 CFR 84.102).
Cools the air directly. EPA places these in the residential and light commercial subsector that § 84.106(a)(3)(ii) exempts (89 FR 82718).
Outside both federal leak-repair rules
It is in the residential and light commercial air conditioning and heat pump subsector that § 84.106(a)(3)(ii) exempts; its refrigerant holds no class I or class II substance (40 CFR part 82, subpart A), so § 82.157 does not reach it either (§ 82.157(a)).
The three questions
- Reaches it: Refrigerant. R-410A contains HFC-32 and HFC-125, HFCs listed in appendix A to part 84, so § 84.106(a)(1) reaches it whatever its GWP.
- Reaches it: Full charge. 20 lb is 15 lb or more, the floor in § 84.106(a).
- Does not reach it: Kind of appliance. § 84.106(a)(3)(ii) exempts the residential and light commercial air conditioning and heat pump subsector, and EPA's preamble places packaged rooftop units, split systems, heat pumps and PTACs in it (89 FR 82718).
EPA frames the exempt subsector around appliances "used to cool individual rooms, single-family homes, and small commercial buildings" and lists "Some rooftop air conditioning" in it (89 FR 82717). Whether a rooftop system serving a large building qualifies is not settled; if you are not sure, choose "Something else, or not sure", which treats it as covered.
If 50 percent or more of the appliance's operating capacity is used for industrial process refrigeration, it is industrial process refrigeration, with the 30 percent rate (40 CFR 84.102; § 84.106(c)(2)(ii)).
This checks the two federal leak-repair rules only: 40 CFR 84.106 and 40 CFR 82.157. Other federal requirements and state rules are separate questions.
Refrigerant not listed?
The refrigerant question turns on what is in it. Any HFC listed in appendix A to part 84 answers it for 40 CFR 84.106 (§ 84.106(a)(1)); with no listed HFC, a substitute in it with a GWP above 53 in table 1 of § 84.64(b) does ((a)(2)). A refrigerant that is solely ozone-depleting, such as a CFC or an HCFC, is outside 40 CFR 84.106 and answers to 40 CFR 82.157 at 50 lbs or more instead. A blend of an HCFC with HFCs can answer to both rules; this checker does not cover those blends.
How the Checker Decides
The refrigerant comes first. § 84.106(a) reaches an appliance only if its refrigerant contains a regulated substance, meaning an HFC listed in appendix A to part 84, or a substitute with a GWP above 53 under table 1 of § 84.64(b). A blend with any listed HFC is in whatever its GWP: R-515B is 91.1 percent HFO, and its 8.9 percent HFC-227ea brings it in. R-1234ze(E), R-1233zd(E), R-514A, ammonia and CO2 contain no listed HFC and have table 1 GWPs of 5 or less, so they are out. The chiller post goes refrigerant by refrigerant.
Ozone-depleting refrigerants go to Part 82. An appliance containing solely an ozone-depleting refrigerant is outside § 84.106 (§ 84.106(a)(3)(i)). Section 608's leak-repair rule, 40 CFR 82.157, reaches it at 50 lbs or more, with the same 20, 30 and 10 percent leak rates and a repair clock of 30 days, or 120 days if an industrial process shutdown is required (§ 82.157(c)(2), (d)), and with no residential or light commercial exemption.
Then the full charge. 15 lbs or more for § 84.106; 50 lbs or more for § 82.157. Full charge is what the appliance needs for normal operation, set by one or a combination of four methods (§ 84.102), not the size of a top-off, and each independent circuit of a multi-circuit system is a separate appliance (§ 84.102). More on the 15-pound floor.
Then the kind of appliance. § 84.106(a)(3)(ii) exempts the residential and light commercial air conditioning and heat pump subsector. EPA did not define it in the rule; it used SNAP's terminology, and its preamble places packaged rooftop units, split systems, heat pumps and PTACs inside while saying the exemption “does not apply to a chiller” (89 FR 82717–82718). The exemption post walks through it, including the unsettled cases: VRF, and rooftop systems on large buildings.
The kind also sets the rate. 20 percent for commercial refrigeration (retail food and cold storage), 30 percent for industrial process refrigeration, and 10 percent for comfort cooling, refrigerated transport and everything else (§ 84.106(c)(2)). An appliance used for both industrial process refrigeration and other applications is industrial process refrigeration if 50 percent or more of its operating capacity serves the process (§ 84.102). Which category is yours.
Covered? Then the numbers. A leak rate over the applicable rate when refrigerant is added starts a repair clock of 30 days, or 120 days if an industrial process shutdown is required (§ 84.106(c)(1), (d)). Run the rate in the leak rate calculator and lay out every date in the repair deadline calculator.
Frequently Asked Questions
Is a rooftop unit covered by EPA's 2026 leak-repair rule?
In most cases, no. 40 CFR 84.106(a)(3)(ii) exempts the residential and light commercial air conditioning and heat pump subsector, and EPA's preamble places packaged rooftop units, split systems, heat pumps and PTACs in it (89 FR 82718). EPA frames the subsector around equipment that cools "individual rooms, single-family homes, and small commercial buildings" (89 FR 82717), so whether a rooftop system serving a large building qualifies is not settled. An R-22 rooftop unit is a different case: 40 CFR 82.157 reaches it at 50 lbs or more, with no subsector exemption.
Are chillers covered?
At 15 lbs or more, yes, when the refrigerant contains an HFC listed in appendix A to part 84 (R-134a, R-410A, R-513A and R-32 all do) or is a substitute with a GWP above 53. EPA says the residential and light commercial exemption "does not apply to a chiller" (89 FR 82718). A chiller on R-1234ze(E), R-1233zd(E) or R-514A contains no listed HFC and has a table 1 GWP of 5 or less, so § 84.106 does not reach it; none of those is a class I or class II substance, so § 82.157 does not either. R-123 and R-22 chillers answer to § 82.157 at 50 lbs or more.
Why is R-515B covered when it is mostly HFO?
Because § 84.106(a)(1) reaches any refrigerant that contains a regulated substance, whatever its GWP. R-515B is 91.1 percent HFO-1234ze(E) and 8.9 percent HFC-227ea (EPA SNAP Determination 36, 85 FR 79863), and HFC-227ea is listed in appendix A to part 84. Its GWP under § 84.64(b) is 287. The GWP-above-53 test in (a)(2) matters only for a refrigerant with no listed HFC at all.
What about R-22 and R-123 equipment?
An appliance containing solely an ozone-depleting refrigerant is outside § 84.106 (§ 84.106(a)(3)(i)). Section 608's leak-repair rule, 40 CFR 82.157, applies instead at 50 lbs or more of a class I or class II refrigerant (§ 82.157(a)), with the same 20, 30 and 10 percent leak rates (§ 82.157(c)(2)) and a repair clock of 30 days, or 120 days if an industrial process shutdown is required (§ 82.157(d)). § 82.157 has no residential or light commercial exemption, so an R-22 rooftop unit of 50 lbs or more is covered. Under 50 lbs, neither rule reaches it.
What charge does the 15-pound floor count?
The appliance's full charge: § 84.106(a) applies to appliances "with a full charge of 15 or more pounds of refrigerant". Full charge is the amount the appliance needs for normal operating characteristics and conditions, set from the manufacturer's determination, a calculation, measurements, or the midpoint of an established range, alone or in combination (§ 84.102). It is not the size of a top-off on a service call. And a system with multiple independent circuits is judged circuit by circuit: § 84.102 treats each independent circuit as a separate appliance.
Are VRF systems covered?
EPA's documents disagree. The 2024 preamble says VRF appliances "currently are exempt" under § 84.106(a)(3)(ii) (89 FR 82719); EPA's January 2026 leak-repair fact sheet says "certain variable refrigerant flow systems are covered under their own subsectors and not the residential and light commercial air conditioning subsector." Neither is the rule's text. Until EPA reconciles them, the checker does not apply the exemption to VRF, the cautious choice.
Does the checker store what I enter?
No. It runs in your browser and stores nothing you enter. It answers only whether a federal leak-repair rule reaches the appliance; other federal requirements and state rules are separate questions.
Covered Units Need a File That Keeps Up
In Ref LeakLog, a unit under 15 lbs, or an HFC rooftop unit you mark as one, gets no repair deadline. A covered appliance gets its leak rate calculated on every addition the rule does not exclude, its repair clock opened when it goes over, its verification tests tracked, and its leak inspections recorded. For a § 84.106 appliance, the inspection schedule is laid out too.
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Ref LeakLog is an independent product and is not affiliated with, approved by, or endorsed by the U.S. Environmental Protection Agency. The answers reflect 40 CFR 84.106 and 40 CFR 82.157 as published at ecfr.gov on October 9, 2026, and the EPA documents cited; the regulations control, not the checker.