Subpart C Compliance Checklist

February 16, 2026•Compliance Guide

This comprehensive checklist helps facility owners, operators, and HVAC professionals ensure full compliance with 40 CFR § 84 Subpart C refrigerant management requirements. Follow these steps to implement leak rate tracking, automatic leak detection, repair procedures, and recordkeeping systems.

Regulatory Overview

Under 40 CFR Part 84 Subpart C, facilities with HFC-containing equipment must comply with specific leak management, repair, and reporting requirements. The regulation applies to equipment containing ≥15 pounds of refrigerant with a Global Warming Potential (GWP) greater than 53.

Compliance Area	Key Requirement
Equipment Threshold	≥15 lbs refrigerant charge with GWP >53
Leak Rate Tracking	Calculate every time refrigerant is added
Repair Deadline	30 days (120 days for industrial process shutdown)
Automatic Leak Detection	Required for equipment with ≥1,500 lbs refrigerant
Record Retention	3 years after equipment retirement
Maximum Penalty	$69,733 per violation per day

Step 1: Identify Regulated Equipment

Begin by creating a comprehensive inventory of all equipment containing HFC refrigerants. This step establishes the foundation for all subsequent compliance activities.

Inventory All Equipment ≥15 lbs Refrigerant

Document supermarket refrigeration systems, walk-in coolers, rooftop HVAC units, cold storage systems, commercial refrigeration equipment, and chillers. Check equipment nameplates for full charge capacity.

Verify Refrigerant Type and GWP

Only refrigerants with GWP >53 are regulated under Subpart C. Common regulated HFCs include:

Refrigerant	GWP	Common Applications
R-404A	3,922	Supermarkets, cold storage
R-410A	2,088	Air conditioning, heat pumps
R-134a	1,430	Chillers, refrigerated transport
R-407C	1,774	Air conditioning

Classify Equipment by Application Type

Equipment classification determines applicable leak rate thresholds:

•Commercial Refrigeration: Supermarkets, grocery stores, convenience stores, restaurants
•Industrial Process Refrigeration: Manufacturing facilities, chemical plants, food processing
•Comfort Cooling: Commercial HVAC, office buildings, chillers
•Other: Refrigerated transport, ice machines, water coolers

Step 2: Understand Applicable Leak Rate Thresholds

Each equipment classification has a different annual leak rate threshold established under 40 CFR § 84.106(a):

Equipment Type	Annual Leak Rate Threshold	When Exceeded, Repairs Required
Commercial Refrigeration	20%	30 days
Industrial Process Refrigeration	30%	30 days (120 if shutdown required)
Comfort Cooling	10%	30 days
Other Appliances	10%	30 days

Step 3: Establish Leak Rate Tracking Process

Under § 84.106(b), you must calculate leak rates every time refrigerant is added to covered equipment, with limited exceptions.

Choose Your Calculation Method

Select either the Annualized method or Rolling Average method. You must use the same method for all equipment at your operating facility.

Method	Formula	Best For
Annualized	`(Total Added ÷ Full Charge) × 100`	Equipment with frequent additions
Rolling Average	`(Added ÷ Full Charge) × 100 × (365 ÷ Days)`	Equipment with infrequent additions

Calculation Exemptions

You do NOT need to calculate leak rates for these three scenarios:

✓Immediately following equipment retrofit or refrigerant replacement
✓Initial charging of newly installed equipment
✓Additions qualifying as seasonal variance adjustments

Document Every Refrigerant Addition

For each service event involving refrigerant addition, record: date of addition, amount added (pounds), technician name/certification number, calculated leak rate, and calculation method used.

Step 4: Automatic Leak Detection Requirements

Equipment containing ≥1,500 pounds of refrigerant must have automatic leak detection (ALD) systems installed and operational under 40 CFR § 84.108.

Equipment Category	ALD System Requirement	Compliance Deadline
New Equipment (installed after Jan 1, 2026)	ALD must be operational immediately upon installation	Within 30 days of installation
Existing Equipment (>1,500 lbs)	Retrofit with ALD system or retire equipment	January 1, 2027
Ongoing Maintenance	Annual auditing and calibration of ALD systems	Annually

Planning Note

If your facility has equipment with ≥1,500 lbs refrigerant installed before 2026, you must budget for ALD system installation or equipment replacement before the January 1, 2027 deadline.

Step 5: Leak Repair and Verification Procedures

When calculated leak rates exceed applicable thresholds, you must complete a series of mandatory repair and verification steps within strict deadlines.

Compliance Step	Deadline	Requirements
1. Complete Repairs	30 days (120 days if industrial shutdown required)	Identify and repair all leaks using EPA-certified technician
2. Initial Verification Test	Within repair deadline	Conduct leak test after repairs completed to confirm success
3. Follow-Up Verification	10 days after initial test	Second verification when equipment reaches normal operating conditions
4. Ongoing Inspections	Quarterly or Annually	Quarterly: Equipment ≥500 lbs Annually: Equipment 15-499 lbs Continue until leak rate drops below threshold

Step 6: Implement Recordkeeping System

Comprehensive recordkeeping is mandatory under § 84.106(e). All records must be retained for 3 years after equipment retirement.

Equipment Records

✓Make, model, serial number
✓Location and facility identifier
✓Installation date
✓Full charge capacity (pounds)
✓Refrigerant type and GWP
✓Equipment classification

Service Records

✓Date of each refrigerant addition
✓Amount added (pounds)
✓Technician name and certification
✓Calculated leak rate
✓Calculation method used
✓Repair and verification test results

Step 7: EPA Annual Reporting (If Applicable)

If refrigerant additions exceed 125% of equipment full charge capacity in a calendar year, you must submit an annual report to EPA.

Reporting Deadline: March 1 (Annually)

Reports must be submitted by March 1 each year for the previous calendar year's refrigerant additions.

Example Trigger:

Equipment with 300 lbs full charge → If you add ≥375 lbs total in a calendar year (300 × 1.25 = 375), EPA reporting is required by March 1 of the following year.

Common Compliance Mistakes to Avoid

❌ Overlooking Smaller Equipment

The 15 lb threshold captures many walk-in coolers, rooftop units, and smaller commercial systems that were previously unregulated under 50 lb rules.

❌ Skipping Leak Rate Calculations

You must calculate leak rates every time refrigerant is added (except the three specific exemptions). This is not optional.

❌ Inconsistent Calculation Methods

You must use the same method (annualized or rolling average) for all equipment at your facility. Mixing methods violates the regulation.

❌ Missing Verification Test Deadlines

Both initial and follow-up verification tests are required after repairs. Missing either deadline constitutes non-compliance.

❌ Inadequate Record Retention

Records must be kept for 3 years after equipment retirement, not just while equipment is in service.