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The EPA leak repair requirements took effect January 1, 2026. They cover appliances with a full charge of 15 pounds or more of HFCs or substitutes with a GWP above 53, and they exempt residential and light commercial air conditioning and heat pumps.
Leak rate thresholds are 30 percent for industrial process refrigeration, 20 percent for commercial refrigeration, and 10 percent for comfort cooling and refrigerated transport. Appliances holding 500 pounds or more require quarterly inspections until the leak rate stays under the threshold for four consecutive quarters. Appliances between 15 and 500 pounds require annual inspections. Automatic leak detection can substitute for inspections, and records are kept three years. For a buyer, this converts leak history and seal condition from a maintenance detail into a recurring compliance cost that transfers with the asset.
Scope and thresholds
The rule applies to refrigerant containing appliances with a full charge of 15 pounds or more that use HFCs or HFC substitutes with a global warming potential above 53. Residential and light commercial air conditioning and heat pump systems are exempt. [1]
The leak rate thresholds are set by application, not by equipment type:
- Industrial process refrigeration: 30 percent
- Commercial refrigeration: 20 percent
- Comfort cooling and refrigerated transport: 10 percent
Exceed the applicable threshold and the clock starts on repair, with retrofit or retirement planning required if the repairs do not hold. [2] The thresholds are annualized leak rates, which means a system that loses a large charge quickly can cross the line well inside a year.
The inspection burden is the real cost
The repair obligation gets the attention. The inspection schedule is what shows up in the operating budget every year.
- 500 pounds or more: inspections once every three months, continuing until leak rate calculations show the appliance has stayed under the applicable threshold for four consecutive quarters.
- 15 to 500 pounds: annual inspections, with the same one year of compliant operation standard.
- Comfort cooling: annual inspections.
- Automatic leak detection (ALD): can be used as a compliance option in place of the inspection requirements.
- Recordkeeping: three years, paper or electronic.
On a large ammonia free HFC plant, quarterly inspection of every covered appliance is not a trivial line item, and it does not go away until the system demonstrates four clean quarters. A system with a history of chronic small leaks can sit in quarterly inspection indefinitely.
What this does to used equipment due diligence
The mechanical inspection you already do on a used package has not changed. What has changed is that several of the findings now carry a quantifiable recurring cost instead of a vague one.
Ask for the leak history, not just the service records
Records are kept for three years, which means on most recently operating equipment the leak history exists. A seller who cannot produce it is either not looking or not telling you something. Request the leak rate calculations, not just the repair invoices, because the calculation is what determines inspection frequency.
Price the seals and gaskets against the threshold, not against the repair cost
A shaft seal replacement is a known number. What matters more is whether the system’s leak profile is going to hold under the applicable threshold once it is running in your facility, because that determines whether you inspect quarterly or annually. The same repair carries a very different downstream cost depending on which side of the threshold the system settles.
Evaluate whether ALD can be retrofitted
Automatic leak detection is available as an alternative to the inspection schedule. On a large system, that trade can be worth more than the detection hardware costs. Assess during due diligence whether the machine room layout, the control panel capacity, and the system architecture make an ALD retrofit practical, and get a number for it before you close.
Confirm the actual charge against the 15 pound line
Coverage turns on full charge. On smaller condensing units and packaged systems, the difference between an appliance that is covered and one that is not can be a matter of pounds. Verify the real charge rather than the nameplate figure, and remember that the same verification drives your GWP obligations under the 2026 Technology Transitions rule.
The ammonia contrast, stated honestly
R-717 is not an HFC, and ammonia systems fall outside this rule entirely. For an operator weighing a used ammonia plant against a used HFC plant, that is a genuine difference in ongoing compliance burden, and it is one reason ammonia continues to hold its position in industrial applications.
It is not a free pass. Ammonia carries its own regulatory weight. Above threshold quantities, OSHA process safety management and EPA risk management program obligations apply, and those programs are more demanding in aggregate than quarterly leak inspection. [3] [4] Mechanical integrity programs, process hazard analysis, operator training, and emergency response planning are real and ongoing costs.
The honest comparison is not that ammonia has no compliance burden. It is that ammonia’s burden is well established, well understood by the contractors who service it, and stable, while the HFC regulatory picture has moved three times in three years. If your operation already runs ammonia compressors and has a mature PSM program, adding ammonia capacity is a smaller marginal step than most buyers assume. If it does not, the startup cost of a PSM program belongs in the acquisition analysis.
Our comparison of screw and reciprocating compressors covers the mechanical side of that decision. This is the regulatory side of it.
Putting a number on it
For a used HFC system, add these to the acquisition model: inspection labor at the applicable frequency, the cost of an ALD retrofit if it makes sense, seal and gasket work required to bring the leak rate under threshold, and the recordkeeping overhead. For a used ammonia system, add PSM and RMP program cost where threshold quantities apply, or confirm the marginal cost is near zero because the program already exists.
Then compare. In a lot of cases the ammonia package still wins on total cost of ownership, and now there is a defensible compliance reason to put in the file alongside the efficiency argument. If the system in question is going into an existing refrigerated warehouse, run the same numbers against the retrofit versus new construction comparison.
Browse ammonia and freon inventory or call 201-805-1441 to talk through a specific package. If you are moving equipment out, submit it here.
Frequently Asked Questions
About the Author
Michael Rosenberg works with buyers and sellers of surplus and used industrial refrigeration equipment at Refrigeration Equipment Professionals, which has supplied ammonia and freon systems directly to contractors and plants for more than 25 years. His day to day work covers plant decommissioning packages, compressor and chiller sourcing for food processing, cold storage, brewing, and industrial refrigeration operations, and equipment valuations for owners liquidating or upgrading a refrigeration plant. Reach him at 201-805-1441 or through the contact page.
Sources
- U.S. EPA, Leak Repair Requirements for Appliances Containing HFCs fact sheet (January 2026). https://www.epa.gov/system/files/documents/2026-01/er-r-fact-sheet-leak-repair-2026-01-13_1.pdf
- U.S. EPA, Regulatory Actions for Managing HFC Use and Reuse. https://epa.gov/climate-hfcs-reduction/regulatory-actions-managing-hfc-use-and-reuse
- U.S. OSHA, Ammonia Refrigeration: Evaluation and Control. https://www.osha.gov/ammonia-refrigeration/evaluation-control
- U.S. EPA, Risk Management Program (RMP) Rule. https://www.epa.gov/rmp

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