EPA 608 and the 2026 HFC Rule: What Changed for Techs

Ask three questions, in this order.

1. What refrigerant is in it? If the appliance holds only an ozone-depleting refrigerant (a CFC or HCFC, such as R-22), the old Part 82 rule still applies, and only when the full charge is 50 pounds or more. Part 84 leak repair does not apply to appliances that contain solely an ozone-depleting refrigerant.
2. If it is an HFC or a substitute, how big is the charge? Part 84 leak repair covers appliances with a full charge of 15 pounds or more of a refrigerant that contains an HFC, or a substitute with a global warming potential (GWP) above 53.
3. What kind of equipment is it? Systems in the residential and light commercial air conditioning and heat pump subsector are left out of Part 84 leak repair, even if they hold 15 pounds or more.

Why two rules? Part 82 once covered HFC systems too, but as of April 10, 2020, its leak repair section applies only to appliances with 50 pounds or more of CFC or HCFC refrigerant, and not to appliances that contain only substitute refrigerants. From then until the end of 2025, a large HFC chiller had no leak repair duty under Part 82. Part 84 fills that gap.

If you learned the Part 82 trigger rates for the test, you already know the Part 84 ones. They are the same:

• 20 percent a year for commercial refrigeration (retail food and cold storage)
• 30 percent for industrial process refrigeration
• 10 percent for comfort cooling, refrigerated transport, and all other covered appliances

The big change is who is covered: 15 pounds instead of 50, and HFCs instead of only CFCs and HCFCs.

There is also a start-up rule for the first leak rate calculation after January 1, 2026. With the annualizing method, you use 365 days as the time since the last addition. With the rolling average method, you count only refrigerant added since January 1, 2026.

Worked example. A comfort cooling chiller has a full charge of 120 pounds of an HFC refrigerant.

1. First top-off after January 1, 2026: 9 pounds. Using 365 days, 9 ÷ 120 = 0.075, or 7.5 percent. That is under 10 percent, so no repair is required.
2. Ninety days later, another 6 pounds is added. 6 ÷ 120 = 0.05. Then 90 ÷ 365 = about 0.247. And 0.05 ÷ 0.247 = about 0.203, or 20.3 percent. That is over 10 percent, so the repair clock starts.

Once an appliance is over its trigger rate, the steps follow the Part 82 pattern.

• The owner or operator has 30 days to find and repair the leaks (120 days if the repair would need an industrial process shutdown).
• A certified technician must do the leak inspection and the repairs. Part 84 does not create a new certification. It defines a certified technician as one certified under 40 CFR 82.161, the same Section 608 certification.
• Each repair needs an initial verification test, done before refrigerant is added back, and a follow-up verification test within 10 days after that (or 10 days after the system returns to normal operation, if it was evacuated).
• If repairs fail, or the owner chooses not to repair, a retrofit or retirement plan is due within 30 days, and the work must be finished within one year unless EPA grants more time.

An appliance that leaks 125 percent or more of its full charge in a calendar year must be reported to EPA by March 1 of the next year. Records are kept for at least three years.

After a successful repair, leak inspections continue on a schedule until the appliance stays under its trigger rate.

• Commercial refrigeration and industrial process refrigeration with 500 pounds or more: every three months, until it stays under the rate for four quarters in a row.
• The same equipment with 15 to under 500 pounds, and comfort cooling and other appliances: once a year, until it stays under the rate for one year.

Part 84 also adds a requirement that Part 82 never had: automatic leak detection systems for commercial refrigeration and industrial process refrigeration with a full charge of 1,500 pounds or more. A system installed on or after January 1, 2026, needs one at installation or within 30 days. A system installed from January 1, 2017, through December 31, 2025, needs one by January 1, 2027. Detectors that sense refrigerant in the air must be able to detect 10 parts per million, and every system must be audited and calibrated once a year. Parts watched by an automatic leak detection system that is audited or calibrated each year do not need the quarterly or yearly hands-on inspection.

The rule also changes what refrigerant you may use and what you do with empty jugs, on three dates.

1. January 1, 2026: Refrigerant sold as "reclaimed" may contain no more than 15 percent virgin (never-used) HFC by weight, and certified reclaimers must label containers to say so.
2. January 1, 2028: A used disposable cylinder that still holds an HFC heel (the leftover refrigerant), and that you will not use again, must be sent to a certified reclaimer, a refrigerant supplier, or a final processor such as a scrap metal recycler that can remove the heel.
3. January 1, 2029: Servicing and repair of supermarket systems, refrigerated transport, and automatic commercial ice makers that contain HFCs must be done with reclaimed refrigerant that meets the 15 percent standard.

One rule did not change and is a common test topic: recovered refrigerant may not be sold to a new owner for use unless a certified reclaimer has reclaimed it to the required purity standard.

In May 2026, EPA proposed exempting road and intermodal container transport refrigeration units (TRUs), the refrigeration units on trailers and shipping containers, from the Part 84 leak repair requirements, whatever their charge size. The proposal was published in the Federal Register on May 26, 2026.

As of November 1, 2026, this is still a proposal. The eCFR text of 40 CFR 84.106 checked that day does not contain the exemption, and refrigerated transport is still listed under the 10 percent rate. If you work on reefer units, check EPA's regulatory actions page for a final rule before you rely on the exemption.

EPA keeps the 608 test bank private, so no one outside the certifying organizations can say exactly which questions changed. The rules you are tested on in Part 82 are still in force. What changed is that more of the equipment you will service now carries leak repair duties.

Before your next service call on a larger HFC system:

• Note the full charge and refrigerant type on the unit. Under 15 pounds, or a residential or light commercial AC unit, Part 84 leak repair does not apply.
• Leave documentation with the owner every time you add or remove refrigerant: the date, the parts you worked on, the type of service, your name, the amount and type of refrigerant, and the full charge. Part 84 requires the person adding or removing refrigerant to give the owner documentation, and the owner uses it to calculate the leak rate.
• For your exam prep, learn the three trigger rates and the 30-day and 10-day timelines once. They now apply under both rules.