Does 40 CFR Part 84 Subpart C Apply to My Building?

The EPA's refrigerant management regulations under Subpart C took effect January 1, 2026 — and the lowered 15-pound threshold means far more buildings are covered than under the previous rules. This guide explains which building types are affected, what equipment to look for, and how to determine whether your property has compliance obligations.

The Rule in Plain Language

Under 40 CFR Part 84 Subpart C, your building is covered if it contains any refrigerant-containing equipment that meets these two conditions:

  1. The equipment has a full refrigerant charge of 15 pounds or more
  2. The refrigerant has a Global Warming Potential (GWP) greater than 53

The GWP threshold is essentially a non-issue for most buildings. Virtually every refrigerant in common use today — R-410A (GWP 2,088), R-404A (GWP 3,922), R-134a (GWP 1,430), R-407C (GWP 1,774), and even the newer R-454B (GWP 466) — exceeds 53. Only natural refrigerants like CO₂, ammonia, and propane fall below it. If your building has standard HVAC or refrigeration equipment, the refrigerant is almost certainly covered.

That makes the real question: does any equipment in your building hold 15 or more pounds of refrigerant? The previous threshold under Section 608 was 50 pounds. The drop to 15 pounds expanded regulatory coverage by approximately 70%, bringing hundreds of thousands of previously unregulated commercial systems under federal oversight.

One Exemption to Know About

The regulation exempts equipment in the residential and light commercial air conditioning and heat pump subsector from certain Subpart C requirements. This exemption covers:

  • Residential split-system air conditioners and heat pumps
  • Residential packaged air conditioners and heat pumps
  • Small commercial systems generally classified as "light commercial"

However, there is an important caveat: there is no precise regulatory definition of "light commercial". The EPA has not drawn a bright line. Equipment is generally considered light commercial at 3–25 tons of capacity, but the classification depends on the actual equipment type (unitary, packaged, or split), not the building it serves.

In practice: a 5-ton split system in a small office is likely exempt. A 25-ton rooftop unit on the same building is not. Chillers are never "light commercial" regardless of size. When in doubt, assume the equipment is covered and verify with the manufacturer's specifications.

Typical Equipment Charge Sizes

The 15-pound threshold applies per individual appliance, not per building. Here is where common equipment types fall relative to the threshold:

Equipment TypeTypical ChargeCovered?
Residential split AC (2–5 ton)6–15 lbsNo — exempt as residential
Small commercial split (3–5 ton)6–15 lbsBorderline — may qualify as light commercial
Rooftop unit (5 ton)~15 lbsRight at the threshold — check nameplate
Rooftop unit (7.5–10 ton)15–30 lbsYes
Rooftop unit (15–25 ton)30–75 lbsYes
Large rooftop unit (25–80 ton)50–200+ lbsYes
Walk-in cooler20–35 lbsYes
Walk-in freezer20–35 lbsYes
VRF system (16 ton)64–96 lbsYes
Small chiller (50 ton)75–150 lbsYes
Medium chiller (100 ton)~150–300 lbsYes
Large chiller (200+ ton)300+ lbsYes
Supermarket rack system3,000–4,000 lbsYes
Data center CRAC unit15–50+ lbsYes

These are general ranges. The actual charge for any specific unit depends on the manufacturer, model, refrigerant type, and field piping length. Always check the equipment nameplate or manufacturer specifications for the exact full charge.

Building-by-Building Guide

Here is how Subpart C typically applies to common building types. The key question for each is: does the building contain at least one piece of refrigerant equipment with 15 or more pounds of charge?

Office Buildings

Almost always covered

Multi-tenant office buildings typically have multiple rooftop units (7.5–25+ tons each, 15–75 lbs each) or central chiller plants (100+ lbs). Even a single-story office with a 7.5-ton RTU crosses the threshold. Smaller offices with only 3–5 ton split systems may fall under the light commercial exemption, but most commercial office buildings have at least one unit above 15 lbs.

Common equipment: Rooftop units, split systems, chillers, VRF systems

Retail Centers and Strip Malls

Almost always covered

Retail properties typically have multiple RTUs serving tenant spaces plus common area cooling. Any tenant operating food service adds walk-in coolers (20–35 lbs each). A strip mall with a restaurant tenant likely has several covered units even if the other tenant spaces use smaller systems.

Common equipment: Rooftop units, walk-in coolers (food tenants), reach-in cases

Supermarkets and Grocery Stores

Always covered — highest compliance burden

Supermarkets are the most heavily regulated building type under Subpart C. A typical grocery store has 3,000–4,000 pounds of refrigerant in its rack systems. At 1,500+ lbs, these systems also require automatic leak detection under § 84.108. The commercial refrigeration leak rate threshold is 20%.

Common equipment: Refrigeration rack systems, walk-in coolers/freezers, display cases, HVAC rooftop units

Restaurants

Usually covered

Most restaurants have at least one walk-in cooler (20–35 lbs of R-404A) and often a walk-in freezer as well, both of which exceed the 15-pound threshold. The building's HVAC may also be covered depending on system size. Restaurant chains with multiple locations face portfolio-wide compliance obligations.

Common equipment: Walk-in coolers, walk-in freezers, HVAC rooftop units, ice machines

Hotels

Almost always covered

Hotels typically have central chiller plants or multiple large RTUs for guest room corridors and common areas. Properties with restaurants, bars, or banquet facilities add walk-in coolers and freezers. Individual PTAC units in guest rooms are generally under 15 lbs, but the central systems are well above the threshold.

Common equipment: Chillers, rooftop units, walk-in coolers (kitchen/bar), VRF systems

Hospitals and Healthcare Facilities

Always covered — typically large charges

Healthcare facilities have some of the largest refrigerant inventories of any building type. Central chiller plants can contain hundreds to thousands of pounds of refrigerant. Medical-grade refrigeration (pharmacy coolers, blood storage, laboratory freezers) adds additional covered units. HVAC reliability requirements mean these facilities often have redundant systems, multiplying the number of covered appliances.

Common equipment: Central chillers, medical refrigeration, pharmacy coolers, rooftop units, lab freezers

Schools and Universities

Usually covered

Even a mid-size school typically has RTUs or chillers exceeding 15 lbs. University campuses with central chiller plants, dining facilities (walk-in coolers), and research labs (specialty refrigeration) can have dozens of covered units across multiple buildings.

Common equipment: Rooftop units, chillers, walk-in coolers (cafeteria), lab freezers

Data Centers

Always covered — high charge density

Data centers rely on precision cooling (CRAC/CRAH units) that typically use R-410A in charges of 15–50+ pounds per unit. Larger facilities have chiller plants with thousands of pounds of refrigerant. The cooling-critical nature of data center operations means refrigerant loss directly impacts uptime, making compliance both a regulatory and operational priority.

Common equipment: CRAC units, chillers, rooftop units

Warehouses and Cold Storage

Cold storage: always covered. Standard warehouse: depends.

Cold storage and refrigerated warehouses have large industrial refrigeration charges (often 1,500+ lbs) that trigger both the standard Subpart C requirements and the automatic leak detection requirement. Standard (non-refrigerated) warehouses may only have comfort cooling — which is still covered if the HVAC units exceed 15 lbs.

Common equipment: Industrial refrigeration systems, rooftop units, dock coolers

Apartment Buildings and Condominiums

Depends on system configuration

Individual unit HVAC systems (split systems, PTACs) are generally under 15 lbs and may qualify for the residential exemption. However, common area and central plant equipment in large apartment and condo buildings — central chillers, boiler/chiller loops, large RTUs serving lobbies and corridors — are not "residential" equipment and are covered if they exceed 15 lbs.

VRF systems serving multiple units deserve special attention. A 16-ton VRF system can hold 64–96 lbs of refrigerant in a single system that spans many apartments, well above the threshold.

Common equipment: Central chillers, VRF systems, rooftop units (common areas), individual split systems (per-unit)

Convenience Stores

Usually covered

Remote condensing units for beverage coolers typically hold 15–25 lbs of refrigerant each. A convenience store with multiple cooler cases can have several individually covered units. Walk-in coolers and the HVAC system add additional compliance exposure.

Common equipment: Remote condensing units, walk-in coolers, rooftop units

If Your Building Is Covered: What Comes Next

If any equipment in your building meets the 15-pound/GWP threshold, you have compliance obligations under Subpart C. The first step is knowing what you have.

Step 1: Inventory Your Equipment

Identify every refrigerant-containing appliance in your building. For each unit, record the manufacturer, model, serial number, refrigerant type, and full charge (from the nameplate or manufacturer specs). You cannot calculate leak rates or maintain compliance records without knowing what you have.

Step 2: Determine Which Units Are Covered

For each unit, check: is the full charge 15 lbs or more? Is the refrigerant GWP above 53? If both answers are yes, that unit is subject to Subpart C. Our 15-pound threshold guide covers the details.

Step 3: Establish Compliance Tracking

For every covered unit, you must track refrigerant additions, calculate leak rates, maintain service records, and ensure repairs are completed within regulatory timelines. For property managers overseeing multiple buildings, a centralized compliance tracking system is essential. RefriTrak is designed specifically for this — it lets you monitor compliance status across all properties from a single dashboard, automatically calculates leak rates when contractors submit work orders, and keeps audit-ready records without manual data entry.

For the full list of what building owners are responsible for, see our owner compliance obligations guide.

Managing Multiple Properties

The 15-pound threshold applies per individual appliance, not per building or per portfolio. Each unit is evaluated independently. A property manager overseeing 50 buildings might have hundreds of individually regulated appliances, each requiring its own leak rate tracking, service records, and repair timelines.

The challenge compounds when different HVAC contractors service different properties. Service data arrives in different formats, at different times, from different vendors. Without a centralized system, compliance gaps are almost inevitable. Platforms like RefriTrak address this by accepting work orders from any contractor in any format — PDFs, Word docs, scanned tickets, even photos — and automatically extracting the refrigerant data to update compliance records across your entire portfolio.

Penalties under the AIM Act can reach $69,733 per violation per day. For a portfolio with dozens of covered units, a systemic compliance failure — like not calculating leak rates — can represent enormous financial exposure.

Frequently Asked Questions

My building only has residential-style split systems. Am I exempt?

Likely yes — if they are truly residential or light commercial air conditioning units and each holds less than 15 lbs of refrigerant. But check for common area equipment (lobby cooling, corridor RTUs, central plant) that may push you over the threshold.

Does each piece of equipment count separately?

Yes. The threshold applies per appliance. If you have ten 10-ton RTUs on your roof, each is evaluated individually against the 15-pound threshold. You do not add the charges together.

I manage the building but don't own it. Am I responsible?

Potentially. Under § 84.102, the "owner or operator" is anyone who "owns, leases, operates, or controls" equipment or "controls or supervises" related activities. If you oversee HVAC maintenance or manage contractor relationships, you may qualify as an operator. See our tenant vs. landlord liability guide for a detailed analysis.

Where do I find the refrigerant charge for my equipment?

Check the equipment nameplate — it is usually on a metal plate or sticker on the unit itself, listing the refrigerant type and factory charge. For systems with field-added piping, the total charge may exceed the nameplate amount. If nameplates are missing or illegible, contact the manufacturer with the model and serial number.

Are there state or local requirements on top of the federal rules?

Yes. Several states impose stricter requirements. California (CARB) requires ALD for systems with 200+ lbs (vs. federal 1,500 lbs) and leak repair within 14 days (vs. federal 30 days). New York, Washington state, and New Jersey all have registration and reporting requirements that go beyond the federal baseline. Check your state environmental agency for applicable rules.

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