Refrigerant Regulations in 2026: Your Complete Guide

This guide reflects regulatory requirements as of January 2026. We are actively monitoring rule changes at the federal and state levels, and this guide will be updated as new regulations are finalized or existing rules are amended. Always consult official regulatory sources or your legal/compliance team for the most current information. If you’re unsure whether a requirement applies to your facility, contact your environmental compliance advisor.

As we move into the new year, multi-site facility managers have plenty of important tasks on their To-Do Lists. With a new year comes new regulatory expectations and new opportunities to lead in sustainability and compliance. While some organizations are focused on stabilizing after a rough patch, others are riding an exciting wave to new heights.

No matter what challenges or opportunities you might be facing in 2026, all companies are facing an increasingly complex landscape of refrigerant management regulations. Multiple reporting deadlines are heading your way, each of which requires careful planning and preparation.

This Fexa guide provides a breakdown of these key deadlines and what practical steps you can take to ensure that your organization meets all of its reporting obligations.

Rule-by-Rule: Your Compliance Obligations 

EPA AIM Act (American Innovation and Manufacturing Act) – Subsection H

The Environmental Protection Agency (EPA) finalized rules in September 2024 concerning the management of certain Hydrofluorocarbons (HFCs) and substitutes under Subsection (h) of the AIM Act. These rules took effect January 1, 2026. These rules expand compliance obligations for HFC-containing systems and introduce new performance and reporting standards for system owners, service providers, and refrigerant suppliers. Companies should prepare for more rigorous compliance checks and potential changes in allowable substances.

These requirements are based on the final rule titled “Management of Certain Hydrofluorocarbons and Substitutes under Subsection (h) of the AIM Act,” published in September 2024. These changes are part of the broader efforts to curb the environmental impact of HFCs. The EPA aims to implement an Emissions Reduction and Reclamation Program that includes several key components, including:

• Leak Repair Requirements: Stricter protocols for identifying and repairing leaks in refrigeration and air conditioning systems. This includes mandatory use of automatic leak detection systems in large equipment to ensure timely identification and mitigation of leaks.
• Use of Reclaimed HFCs: Regulations to promote the use of reclaimed HFCs for servicing certain subsectors (including supermarket systems, refrigerated transport, and automatic commercial ice makers beginning January 1, 2029)
• Cylinder Recovery and Tracking: Implementation of a container-tracking system to ensure the recovery of HFCs from cylinders before disposal.
  • Tracking of disposable cylinders (40 CFR 84.116) is as of January 1, 2028, so teams still have time to plan for this stricter tracking of disposable cylinders
• Alternative Recycling Criteria: Proposals for alternative recycling criteria for ignitable used refrigerants, leveraging the authority of the Resource Conservation and Recovery Act (RCRA).

The October 2023 rules and following updates represent the most comprehensive changes to refrigerant management since the 1994 Clean Air Act.

Who is Affected?

Systems with 15+ pounds of refrigerants with a GWP greater than 53

• Not included: residential and light commercial air conditioning and heat pumps

Systems with 1,500+ pounds require automatic leak detection

Applies to:

• Industrial refrigeration
• Commercial refrigeration
• Comfort cooling systems
• Small businesses meeting thresholds

The EPA finalized a lower threshold of 15 pounds for HFC-containing systems under Subsection (h).

What is Required?

• Asset inventory with refrigerant types, charge sizes, GWP ratings
• Automatic leak detection system records (for large systems)
• Leak inspection and repair documentation
• Refrigerant usage tracking
• Service records and maintenance history
• Reclamation documentation

Compliance effective: January 1, 2026. Ongoing documentation and recordkeeping required; no universal annual federal submission deadline applies.

Related Resources

Read more about the AIM Act.

New York Part 494 Amendments

New York’s 6 NYCRR Part 494, Hydrofluorocarbon Standards and Reporting, has been adopted and is in effect. The rule establishes prohibitions, registration requirements, leak management obligations, and reporting standards for businesses using high-GWP refrigerants. Facilities operating in New York must maintain ongoing compliance and submit required reports according to the regulation’s established deadlines.

The DEC adopted 6 NYCRR Part 494 to establish prohibitions, registration requirements, leak detection and repair standards, and reporting obligations regarding the sale, use, and supply of HFCs and new products and systems that contain regulated substances. The goal of the rule is to implement recommendations from the Climate Action Council Scoping Plan to achieve the required statewide greenhouse gas emission limits and the net zero goal outlined in the Climate Act.

Who is Affected?

Owners and operators of facilities in New York with refrigeration systems containing 50 pounds or more of high-GWP refrigerant, as well as suppliers, distributors, and reclaimers of regulated substances. 

What is Required?

The adopted requirements under Part 494 include several key elements:

• Prohibitions and Reporting Requirements: New regulations will prohibit certain uses of HFCs in specific end-uses, aligning with the EPA’s Significant New Alternatives Policy (SNAP) program. Businesses will need to comply with these prohibitions and maintain detailed records for administrative purposes.
  
• Enhanced Accountability: Suppliers and reclaimers of regulated substances must submit annual reports detailing quantities supplied, sold, reclaimed, or destroyed in New York State. Owners and operators of covered refrigeration systems must maintain detailed records and demonstrate compliance upon request.
  
• Administrative and Record-Keeping Requirements: Manufacturers of products affected by these regulations must develop and maintain comprehensive administrative and record-keeping systems. This includes tracking the lifecycle of HFCs from acquisition through disposal.

Required reporting includes:

• HFC usage tracking
• Refrigerant sales data
• Inventory records
• Disposal documentation
• Compliance with prohibitions on certain HFC uses

Reporting Date: March 31 annually. The first annual supplier and reclaimer reports are due March 31, 2026, covering calendar year 2025 activity.

Washington State HFC Regulations (Chapter 173-443 WAC)

Washington State continues to phase in its refrigerant regulations under Chapter 173-443 WAC. The next major compliance step impacts medium-sized facilities, which must register their refrigeration systems by March 15, 2026. Facility managers should begin compiling the required data now to ensure timely registration. The new requirements underscore the importance of early preparation and thorough documentation to meet the state’s enhanced refrigerant management standards.

Adopted in November 2023 and effective January 1, 2024, the regulations focus on managing the environmental impact of HFCs. Established as Chapter 173-443 WAC, the rule targets HFCs and other fluorinated greenhouse gasses by setting maximum global warming potential (GWP) thresholds and mandating stringent management practices. These regulations aim to curb HFC emissions, which the state Department of Ecology estimates could account for 7-19% of global greenhouse gas emissions by 2050 if unaddressed.

Washington’s HFC phasedown rule aims to reduce emissions from high-GWP refrigerants through a phased registration approach based on system size.

Who is Affected?

Registration: Facilities must register their refrigeration and air conditioning systems based on the refrigerant charge size of their largest asset:

• Large facilities (>1,500 pounds): Registration by March 15, 2024
• Medium facilities (200-1,499 pounds): Registration by March 15, 2026
• Small facilities (50-199 pounds): Registration by March 15, 2028

Applies to refrigeration/AC systems with refrigerants having GWP of 150 or more

What is Required?

Leak Inspection and Repair: Facilities must conduct regular leak inspections and repairs with a certified technician. The inspection schedule varies by asset size:

• Large assets: Monthly inspections
• Medium assets: Quarterly inspections
• Small assets: Annual inspections

Inspections are also required during verification tests, when refrigerant is added in significant amounts, or when oil residue indicates a potential leak. Leak rates must be calculated and monitored to ensure compliance with established thresholds:

• Cold Storage Warehouse or Retail Food Refrigeration: 16%
• Industrial Process Refrigeration (IPR): 24%
• Air Conditioning: 8%

Leaks must be repaired within 14 days of detection, a significantly shorter timeframe than the EPA’s 30-day requirement. Failure to repair leaks within this period may necessitate a retrofit or retirement plan for the leaking system.

Recordkeeping and Reporting: All facilities with systems containing a minimum of 50 pounds of high-GWP refrigerants (GWP greater than 150) must maintain detailed records throughout the operational life of each covered system. Medium and large facilities must submit annual facility reports.

Required documentation includes:

• Registration in RAMP (Refrigeration and Air Conditioning Management Platform)
• Leak inspection records
• Repair documentation
• Service records
• System specifications
• Retrofit/retirement plans if applicable

Reporting Dates

Phase 1: Large facilities registered by March 15, 2024; first annual reports due March 15, 2025

Phase 2: Medium facilities register by March 15, 2026; submit reports one year later

Phase 3: Small facilities register March 15, 2028; submit reports one year later

Impact and Preparation

The Department of Ecology anticipates that these regulations will have a significant environmental impact, equivalent to mitigating emissions from approximately 740,000 cars annually. Businesses of all sizes, especially those in commercial refrigeration, HVAC, and industrial sectors, will need to adapt their practices to comply with the new rules.

Facility managers should start gathering the necessary information for registration and enhance their documentation practices to ensure compliance. Investing in robust refrigerant management systems, like those offered by Trakref, can simplify compliance by providing timely alerts, recordkeeping, and guidance on regulatory standards.

Related Resources

For more information, check out our official deep dive into the Washington State Regulations.

California Climate Disclosure Rules

California is moving towards implementing stricter climate disclosure rules that will significantly impact refrigerant management reporting. While these new regulations may face delays, businesses should not become complacent. Staying informed and preparing for eventual compliance is crucial as these rules will likely require detailed disclosure of refrigerant usage and management practices, reinforcing California’s commitment to environmental transparency and accountability.

The state of California has enacted three climate-related disclosure laws: S.B. 253, S.B. 261, and A.B. 1305. These laws focus on greenhouse gas (GHG) emissions, climate-related risks, and voluntary carbon offset transactions, respectively. However, proposed amendments are currently making their way through the legislative process, which could delay key compliance deadlines and relax some requirements.

Who is Affected?

Companies with total annual revenues exceeding $1 billion that do business in California, regardless of physical presence.

What is Required?

S.B. 253: This law requires companies to disclose their GHG emissions, including Scope 1, Scope 2, and Scope 3 emissions.

S.B. 261: This law mandates companies to report on climate-related risks based on the Task Force on Climate-Related Financial Disclosures (TCFD) framework.

A.B. 1305: This law requires companies to disclose their activities related to voluntary carbon offsets and emissions reduction claims. Proposed amendments clarify that these requirements only apply to activities occurring after January 1, 2025, and explicitly exclude certain renewable energy certificates (RECs) from being classified as voluntary carbon offsets.

Implications for Refrigerant Management

The amendments to S.B. 253 and S.B. 261 specifically target the reporting of GHG emissions and climate-related risks, which include the use and management of refrigerants. Businesses will need to ensure accurate and comprehensive reporting of refrigerant usage and emissions as part of their overall GHG disclosures. Refrigerants, as direct GHGs with high global warming potentials, fall under Scope 1 emissions and must be accurately quantified and disclosed under SB 253.

This includes:

Detailed Disclosure: Companies must provide thorough documentation of refrigerant types, quantities, and leakage rates. Accurate record-keeping and regular audits will be essential to meet the new disclosure requirements.

Environmental Accountability: The new rules reinforce California’s commitment to transparency in environmental practices. Companies will need to demonstrate their efforts in reducing refrigerant emissions and adopting sustainable practices.

Preparation for Compliance: Despite potential delays, businesses should begin preparing now by upgrading refrigerant management systems, training teams, and building accurate data collection processes to ensure compliance once disclosure rules take effect.

Reporting Dates (with Proposed Amendments)

The proposed amendments would delay the initial compliance deadlines for these disclosures:

• SB 253 GHG emissions disclosures: Delayed from January 1, 2025, to January 1, 2027
• Scope 1 and Scope 2 reporting: Limited assurance delayed from 2026 to 2028, Reasonable assurance delayed from 2030 to 2032
• Scope 3 reporting: Initial reporting delayed from 2027 to 2029, Reasonable assurance delayed from 2030 to 2032
• SB 261 (TCFD-aligned climate risk reporting): First report delayed from 2026 to 2028

Additional 2025 Reporting Requirements

EPA 608: Chronically Leaking Appliances

Section 608 of the Clean Air Act is part of the National Recycling and Emission Reduction Program, which regulates the handling of ozone-depleting refrigerants (Class I and II substances). It addresses appliances that have experienced significant refrigerant leaks.

Reporting date: March 1, 2025

Who Must Report:

• Operators with systems containing 50+ pounds of Class I or II ozone-depleting refrigerants
• Applies when a system leaks 125% or more of its full charge in a calendar year and contains a Class I or Class II refrigerant.
• Any business or facility with qualifying HVAC/R equipment

Required Documentation and Reports:

• Leak rate calculations
• Repair attempt records
• Verification test results
• Full system specifications
• Service and maintenance history

California Air Resources Board (CARB) Refrigerant Management Program

CARB’s Refrigerant Management Program (RMP), adopted in 2009, regulates stationary refrigeration systems to reduce emissions of high-GWP refrigerants in accordance with California’s Global Warming Solutions Act (AB 32).

Because reporting to CARB is due on the same date as EPA 608 and NY Part 494, organizations with facilities in California need to prepare their documents in advance.

Reporting date: March 1, 2025

Who Must Report:

Any facility physically located in California with stationary refrigeration systems:

• Large facilities (2,000+ pounds refrigerant)
• Medium facilities (200-1,999 pounds refrigerant)
• Small facilities (50-199 pounds refrigerant)

Applies to facilities with refrigeration systems containing more than 50 pounds of refrigerant with a GWP ≥ 150

Required Documentation and Reports:

• Registration information for facility and owner/operator
• Annual report (Medium and Large facilities only)
• Leak inspection records
• Service and repair documentation
• Installation/calibration records for leak detection systems
• Refrigerant purchase records
• Records of refrigerant shipments for reclamation/destruction
• System capacity calculations and supporting data
• Any retrofit or retirement plans
• Registration fees, dependent upon facility size

How to Prepare for the March 1 Reporting Date:

• Complete facility registration
• Implement inspection program
• Monitor leak repair compliance
• Maintain documentation system

Related Resources

Learn more in our CARB Act guide.

New Jersey Greenhouse Gas Monitoring and Reporting Rule

New Jersey’s GHG Monitoring and Reporting Rule (N.J.A.C. 7:27E) requires facilities with qualifying refrigeration systems to track refrigerant usage, calculate emissions, and report to the Department of Environmental Protection (DEP) annually.

Reporting date: April 1, 2025

Who Must Report:

• Facilities in New Jersey with refrigeration systems/chillers containing 50+ pounds of high-GWP refrigerant (GWP ≥ 150)
• New facilities must register within 90 days of installation

Required Documentation and Reports:

• Facility identification and contact information
• System details (ID number, installation date, manufacturer, model, serial numbers)
• Equipment specifications and classification
• Full charge amounts
• Refrigerant purchase records
• Charging/recovery documentation
• Inventory records
• Reclamation/destruction shipping records
• Registration fee: ($400 for 5-year registration)

EPA GreenChill Store Certification Program

This voluntary program recognizes food retail stores for environmentally friendly refrigeration practices. Participation in the GreenChill Store Certification Program helps food retailers demonstrate leadership in environmental stewardship by reducing refrigerant emissions and exceeding regulatory standards.

Reporting date: Rolling (Annual recertification required)

Who Must Report:

Participation is voluntary.

Any U.S. food retail store can choose to participate:

• Supermarkets
• Grocery stores
• Cooperatives
• Supercenters
• Wholesale clubs

Two categories based on installation date:

• Pre-2025 installations: Silver, Gold, or Platinum certification levels
• Post-2025 installations: “GreenChill Certified” status

Required Documentation and Reports:

Store Certification Application Workbook (XLS) including:

• Refrigerant types and amounts
• Refrigeration loads
• Emissions data
• Technology specifications
• Installation leak testing documentation (new stores)
• Annual recertification documentation

Building Your Compliance Strategy

With multiple deadlines and overlapping requirements, your organization may face significant compliance changes in 2026, especially if you have locations in multiple states.

It is important to build an effective compliance strategy that can be implemented for any and every requirement that comes your way.

Centralize Your Data Management

A central source of refrigerant-related data will help immensely. When you can go to one single source for your reporting data, it saves you hours of searching different databases, platforms, and APIs.

This isn’t just about centralizing your data for one facility, either. You need to standardize documentation across all of your facilities, creating a consistent approach for everyone in the organization.

These steps will enable real-time access to critical information.

Streamline Your Workflows

What do your workflow processes look like? Are they consistent across all of your facilities and assets? If not, it’s time to design consistent processes for inspections, routine maintenance, and emergency repairs.

Automating these processes is another step toward streamlining your workflows. You should also establish clear communication channels between departments, facilities, and tradespeople.

Use CMMS software that creates automated alerts for upcoming deadlines so that you can avoid surprises.

Maintain Comprehensive Records

The foundation of compliance is accurate, comprehensive record-keeping. In refrigerant management, that looks like:

• Tracking equipment specifications and service history
• Documenting refrigerant usage and disposal
• Storing compliance certificates and testing results
• Preserving maintenance and repair records

Choose the Right Technology Partners

There are two technology solutions that are essential to smooth compliance: a flexible CMMS and a thorough refrigerant management API.

A modern CMMS platform like Fexa can help you:

• Automate compliance tracking across jurisdictions
• Generate required reports for different agencies
• Maintain detailed audit trails
• Integrate with Trakref for specialized refrigerant management
• Scale your compliance program as regulations evolve

Fexa Trakref can work hand-in-hand with Fexa, enabling:

• Real-time refrigerant usage tracking
• Automated compliance alerts
• Multi-jurisdiction reporting
• GWP calculations and monitoring
• Leak rate analytics
• Equipment performance tracking
• Reclamation documentation
• EPA and state regulatory compliance
• Automated workflow triggers based on leak detection
• Integration with automatic leak detection systems

The complexity of refrigerant management regulations makes manual tracking impractical. Fexa’s purpose-built solutions help organizations stay compliant while reducing administrative burden.

Fexa Trakref Can Help You Stay Ahead of Ongoing Compliance Requirements

Most of these requirements are annual obligations, meaning facilities must continue reporting year after year. Deadlines set for 2025 have passed, and 2026 deadlines are rapidly approaching, but that won’t be the end of your reporting obligations. Refrigerant management compliance isn’t a one-time project because it’s actually an ongoing operational responsibility that requires consistent attention, accurate data collection, and timely reporting.

The landscape of refrigerant regulations will only grow more complex as environmental standards tighten and enforcement increases. Facilities operating across multiple states face the additional challenge of managing different requirements, deadlines, and reporting formats simultaneously.

Manual tracking systems simply can’t keep pace with this level of complexity. Spreadsheets become outdated, documents get lost, and deadline alerts get missed. That’s where purpose-built technology makes the difference.

Fexa’s CMMS platform combined with Fexa Trakref creates a comprehensive solution for managing refrigerant compliance across your entire portfolio. From automated deadline alerts to jurisdiction-specific reporting templates, these tools eliminate the administrative burden while ensuring nothing falls through the cracks. Real-time tracking, automatic leak detection integration, and multi-jurisdiction reporting capabilities mean your team can focus on facility operations rather than scrambling to compile compliance documents.

Whether you’re managing ten facilities or a thousand, Fexa and Fexa Trakref provide the infrastructure you need to meet every deadline, satisfy every requirement, and demonstrate compliance to every regulatory authority—year after year.

Schedule a Fexa Trakref demo today.