Evaluate both frameworks independently
40 CFR 82.157 generally covers qualifying appliances with at least 50 pounds of refrigerant containing an ozone-depleting substance, including blends. From January 1, 2026, 40 CFR 84.106 covers qualifying 15+ pound appliances containing a regulated substance, or a substitute for a regulated substance with GWP greater than 53. That GWP cutoff belongs to the substitute branch. Refrigerant identity alone does not determine the answer.
Solely ODS appliances and residential/light-commercial air-conditioning and heat pumps are excluded from Part 84’s leak-repair requirements. This does not remove separate certification, recovery or venting duties. Confirm the appliance’s regulatory subsector and refrigerant composition instead of relying on a generic AC label. ODS-containing blends can require review under both frameworks.
| Covered category | Part 82 | Part 84 |
|---|---|---|
| Comfort cooling | 10% | 10% |
| Commercial refrigeration | 20% | 20% |
| Industrial process refrigeration | 30% | 30% |
| Refrigerated transport, when covered | 10% | 10% |
The earlier comparison of 15% versus 10% on this site was wrong. Crossing means exceeding the threshold, not merely equaling it. Part 84 also assigns 10% to covered other appliances, including transport categories under the current rule; a proposed exclusion is not an enacted change.
Part 84 has a special first-addition rule beginning in 2026, subject to its stated exceptions. Verification timing, recordkeeping and inspections must be evaluated against the relevant paragraphs. This short comparison is not a complete compliance checklist. Keep the original evidence and document corrections instead of silently rewriting historical determinations.
