EPA Leak Repair Requirements 2026 for Controls Engineers

The EPA leak repair requirements have been in force since January 1, 2026. For a controls engineer, the first question is simple: is this appliance covered? The second is whether the service record has what the owner needs to calculate a leak rate when refrigerant is added. 

If you write the spec before those answers are known, you can add features an exempt product doesn’t need. Or you can ship a covered product without the data the owner has to keep. 

This isn’t about the HFC phase-down. We’ve covered the May 2026 extension of that timeline in EPA HFC Refrigerant Rule Rollback 2026, and leak repair wasn’t part of that post. 

What Do the EPA Leak Repair Requirements 2026 Cover? 

The requirements come from the 2024 Emissions Reduction and Reclamation final rule, under the AIM Act. EPA summarized them in a fact sheet dated January 13, 2026. The fact sheet is a summary; the rule is 40 CFR 84.106. If the two don’t match, follow the rule. 

Owners, operators, and certified technicians have to comply for certain appliances with a charge of 15 pounds or more. The refrigerant must contain an HFC, or be a substitute with a GWP above 53. 

Two cases are excluded before you add any control feature. Residential and light commercial air conditioning and heat pumps aren’t covered. Appliances that use a substitute with a GWP of 53 or below are also excluded. 

Charge size, refrigerant, and end use determine coverage. Until you know those three, leak-rate fields and automatic leak detection are guesses. 

When a Leak Rate Triggers a Repair 

Each time refrigerant is added, the owner calculates a leak rate, with a few exceptions. The two methods are annualizing and rolling average. The formulas are in 40 CFR 84.102. 

A repair is required when the leak rate is above: 

• 30% for industrial process refrigeration
• 20% for commercial refrigeration
• 10% for comfort cooling, refrigerated transport, and other covered appliances

The leak has to be found and repaired within 30 days. The window is 120 days if an industrial process refrigeration system has to shut down to do the work. The clock can pause if the appliance is evacuated and shut down. The repair has to bring the leak rate back below the applicable threshold for that appliance. 

Each repair needs an initial test and a follow-up test. The follow-up is due within 10 days of a successful initial test, or within 10 days of the appliance returning to normal operation. For the controls design, the useful point is when the clock starts. It starts when refrigerant is added, not when someone writes up the visit later. 

Inspections, Detection, and the Three-Year Record 

After the leak rate exceeds the applicable threshold, inspections continue quarterly or annually, depending on appliance type and charge size. Some owners have to install automatic leak detection. Others can use it instead of inspections. Check 40 CFR 84.106 before you put it in the spec. 

If the leak isn’t repaired, a retrofit or retirement plan is due within 30 days, and the work is generally due within one year. A calendar-year leak of 125% or more of the appliances full charge is reported to EPA by March 1 of the next year. Records are kept for three years. The owner keeps them. A controller field doesn’t change that. 

What to put in the controls spec 

The fact sheet tells the owner what to calculate, repair, test, and keep. It doesn’t say that data has to live in the controller. A controller, a building management system, or a paper file can hold it. 

Check charge size, refrigerant, and end use first. Then decide which of these items the product’s own record will hold: 

• Full charge, refrigerant, date, and quantity added, in a form that supports leak-rate methods.
• Whether the appliance was evacuated and shut down, if that’s what pauses the repair clock
• Sensor, alarm, and alarm record, only if automatic leak detection is required or the owner chooses it
• Date, quantity, refrigerant, test result, and who recorded it

This list is a practical reading of what a leak-rate file needs. EPA did not publish it as a required field list.  This isn’t legal advice. The January 13, 2026 fact sheet is a summary and the rule is 40 CFR 84.106. 

Key Takeaways 

• Since January 1, 2026, the leak repair rule covers many appliances with 15 pounds or more of HFC refrigerant, or certain substitutes with a GWP above 53.
• Residential and light commercial air conditioning and heat pumps are not covered. Neither are appliances that use a substitute with a GWP of 53 or below.
• The leak-rate thresholds are 30% for industrial process refrigeration, 20% for commercial refrigeration, and 10% for comfort cooling and other covered appliances.
• The repair window is 30 days, or 120 days if an industrial process has to shut down. An initial test and a follow-up test are required. Records are kept for three years.
• The fact sheet does not require the record to be stored in the controller. Confirm charge size, refrigerant, and end use before you add those fields to the spec.