Determine which rule applies
Section 82.157 generally covers appliances with a full charge of at least 50 pounds of an ODS refrigerant or a blend containing ODS. Section 84.106 applies from January 1, 2026 to qualifying appliances with a full charge of at least 15 pounds of refrigerant containing either a regulated substance, or a substitute for a regulated substance whose GWP is greater than 53. The GWP cutoff belongs to the substitute branch. Part 84 excludes solely-ODS appliances and residential/light-commercial AC and heat pumps. Refrigerant identity or charge alone does not establish coverage.
Reporting threshold and deadline
Both §82.157(j) and §84.106(j) require the owner or operator of a covered appliance that leaks 125% or more of its full charge in a calendar year to report by March 1 of the following year. Exactly 125% qualifies. This reporting threshold is distinct from the applicable 10%, 20% or 30% leak-repair threshold.
For example, documented leakage of 250 pounds from a covered appliance with a 200-pound full charge reaches 125%. A report for the 2026 calendar year is due March 1, 2027. Refrigerant additions are important evidence, but a gross total of all charging activity is not automatically identical to refrigerant leaked. Preserve recovery, recharge and other service facts needed to explain the loss calculation.
Report contents and records
Section 82.157(j) requires a description of efforts to identify leaks and repair the appliance; paragraph (m) provides its submission route. Section 84.106(m)(4) specifies identification, appliance and refrigerant details, full charge, annual percent loss, addition dates and amounts, the last successful follow-up test, causes and repair actions, retrofit/retirement-plan status, and a signed statement from an authorized company official. Use the applicable rule’s current submission process.
FieldPad records and exports can support preparation. Verify the scope, quantities, completeness and required signature before submission. A generated report or reminder is not proof that EPA received the report. Preserve the submission and response records required by the applicable rule.
