Determine applicability first
40 CFR 82.157 generally covers appliances containing at least 50 pounds of a class I or class II ozone-depleting refrigerant, or a blend containing one. 40 CFR 84.106 covers qualifying appliances from January 1, 2026 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. It excludes residential and light-commercial air conditioning and heat pumps. A rooftop unit’s charge and refrigerant alone do not establish coverage.
A five-pound residential AC system is not subject to these federal leak-repair provisions. Separate certification, recovery, venting, safety and other applicable requirements still matter.
Annualizing method
The definitions in 40 CFR 82.152 and 40 CFR 84.102 specify:
Leak rate = (pounds added to restore full charge / full charge) × (365 / elapsed days, capped at 365) × 100
Include multiple additions related to the same leak as the rule requires. Short intervals can produce a high annualized rate; that does not authorize changing methods to obtain a lower result.
For a covered R-404A walk-in cooler with a 55-pound full charge, an eight-pound addition after 200 days gives 26.5%. This exceeds the 20% commercial-refrigeration threshold under Part 84. R-404A alone does not place the appliance under Section 608’s ODS leak-repair provisions. This example assumes the first-calculation transition rule discussed below does not apply.
Rolling-average method
Leak rate = (sum of pounds added during the applicable lookback period / full charge) × 100
The lookback is the preceding 365 days, or the shorter period since the last successful follow-up verification test showing that all identified leaks were repaired. For example, eligible additions totaling 12 pounds to a 55-pound covered walk-in cooler produce 21.8%, above its 20% threshold.
A single eight-pound addition divided by 55 pounds is 14.5%. That number is a useful service quantity, but is the legal rolling-average result only if eight pounds is the complete eligible lookback total. Our earlier article incorrectly called a single-addition screening calculation EPA’s second method.
Use the same calculation method for covered appliances at an operating facility. Part 84 also restricts method changes; do not switch freely between methods to avoid an exceedance. See the definitions and §84.106(b)(3).
First Part 84 calculation beginning in 2026
For the first annualizing calculation after January 1, 2026, §84.106(b)(1) substitutes 365 days for elapsed days. For the first rolling-average calculation, §84.106(b)(2) uses pounds added since January 1, 2026. Apply these provisions before interpreting a worked example.
Compare and retain the evidence
For covered appliances, both frameworks use 10% for comfort cooling, 20% for commercial refrigeration and 30% for industrial process refrigeration. A rate must exceed the applicable threshold to trigger the repair provisions. Refrigerant identity, appliance category and charge all matter.
The ordinary repair period is 30 days; 120 days applies when an industrial process shutdown is required. Initial and follow-up verification tests are separate steps. Both rules generally require follow-up within 10 days of successful initial verification, or of returning to normal operating conditions when evacuated for repair. Review the detailed exceptions, extensions and retrofit/retirement provisions in §§82.157 and 84.106.
Retain the full-charge basis, addition history, calculation method, applicable rule and verification evidence. Initial installation, qualifying seasonal variance and immediately post-retrofit additions have specific treatment; a generic post-repair recharge is not automatically excluded. FieldPad supports calculation and recordkeeping; an app result does not certify compliance.
