Regulatory Deadlines To Watch Out For In 2025

As we move into 2025, multi-site facility managers have plenty of important tasks on their To-Do Lists. Another year, another opportunity for growth. 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 2025, 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. 

Reporting Requirement	Reporting Date	Who is Affected	What to Report
EPA 608 Chronically Leaking Appliances	March 1, 2025	Systems containing 50+ pounds of Class I or II ozone-depleting refrigerants that leaked 125% or more of full charge in prior year	Leak rates, repair attempts, verification tests, and system details for chronically leaking appliances
California Air Resources Board (CARB)	March 1, 2025	California facilities with refrigeration systems using 200+ pounds of high-GWP refrigerant	Complete inventory of refrigeration systems, leak check records, service records, and calculated annual leak rates
New York Part 494	March 1, 2025	New York facilities with high-GWP refrigeration systems	HFC usage tracking, refrigerant sales data, inventory records, disposal documentation, and compliance with prohibitions on certain HFC uses
Washington State Department of Ecology	March 15, 2025 (possibly earlier)	Facilities with systems using 1,500+ pounds of high-GWP refrigerant (threshold dropping to 200 pounds in 2026)	System registration, refrigerant types and quantities, leak detection records, and maintenance history
New Jersey DEP GHG Monitoring	April 1, 2025	New Jersey facilities with systems requiring 50+ pounds of high-GWP refrigerant	GHG emissions data, system specifications, refrigerant usage, and leak rate calculations
EPA GreenChill Store Certification	Rolling	Food retailers participating in voluntary certification program	Environmental performance metrics, refrigeration system data, and sustainability practices documentation
EPA AIM Act	January 1, 2026 (Preparation required in 2025)	Systems with 15+ pounds of refrigerants with GWP >53; Systems with 1,500+ pounds require automatic leak detection	Leak repair documentation, refrigerant tracking, automatic leak detection system installation and monitoring, use of reclaimed HFCs for servicing

EPA 608: Chronically Leaking Appliances 

Section 608 of the EPA is part of the Clean Air Act’s National Recycling and Emission Reduction Program. 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 systems leaked 125% or more of full charge in prior calendar year
• Any business or facility with qualifying HVAC/R equipment

Required Documentation and Reports

1. Leak rate calculations
2. Repair attempt records
3. Verification test results
4. Full system specifications
5. Service and maintenance history

How to Prepare for the March 1 Reporting Date

This is one of your first reporting requirements of the year. If you are already collecting data about your assets, generating reports for EPA 608 will be pretty straightforward. If not, these steps will help you prepare. 

• Audit your systems
• Review leak records
• Prepare documents
• Implement a tracking system for leaks

California Air Resources Board (CARB) Refrigerant Management Program 

CARB's Refrigerant Management Program (RMP) aims to reduce greenhouse gas emissions from stationary sources through comprehensive refrigerant management. The program was adopted in 2009 as part of California's Global Warming Solutions Act.

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 any facility with stationary refrigeration system containing over 50 pounds of high-GWP refrigerant

Required Documentation and Reports

1. Registration information for facility and owner/operator
2. Annual report (Medium and Large facilities only)
3. Leak inspection records
4. Service and repair documentation
5. Installation/calibration records for leak detection systems
6. Refrigerant purchase records
7. Records of refrigerant shipments for reclamation/destruction
8. System capacity calculations and supporting data
9. Any retrofit or retirement plans
10. 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

Washington State Refrigerant Management Program 

Washington's RMP aims to reduce emissions from high-GWP refrigerants through a phased registration approach based on system size. The only organizations that have to report their numbers to Washington’s RMP are those with facilities that have large systems (1500+ pounds). 

These facilities were required to register by March 15, 2024, and annual reports are due starting one year later. If you submitted before March 15, 2024, then your reporting date will also occur earlier than March 15 of this year. 

Facilities with smaller systems should prepare their registration for RAMP before their respective due dates. 

Reporting date: March 15, 2025 (or earlier) 

Who Must Report

• Phase 1 (March 15, 2024): Systems with 1,500+ pounds refrigerant
• Phase 2 (Register by March 15, 2026; submit reports one year later): Systems with 200-1,499 pounds refrigerant
• Phase 3 (Register March 15, 2028; submit reports one year later): Systems with 50-199 pounds refrigerant
• Applies to refrigeration/AC systems with refrigerants having GWP of 150 or more

Required Documentation and Reports

1. Registration in RAMP (Refrigeration and Air Conditioning Management Platform)
2. Leak inspection records
3. Repair documentation
4. Service records
5. System specifications
6. Retrofit/retirement plans if applicable

How to Prepare for the March 15 Reporting Date

You might start to notice some familiar tasks on this list. Fortunately, you can duplicate many documentation and reporting tasks for various deadlines, as long as you submit the exact requirements to the governing authorities of each rule. 

• Set up RAMP access
• Implement inspection program
• Maintain your documentation system
• Review facility service practices

New Jersey Greenhouse Gas Monitoring and Reporting Rule 

New Jersey's DEP GHG regulation requires New Jersey facilities with refrigeration systems to track and report their refrigerant usage to calculate GHG emissions.

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

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

How to Prepare for the April 1 Reporting Date

• Complete state registration
• Track all required data
• Keep detailed records
• Prepare your annual report

EPA GreenChill Store Certification Program 

This voluntary program recognizes food retail stores for environmentally friendly refrigeration practices. In an era where consumers prefer to shop with environmentally-friendly companies that go above and beyond compliance requirements, participating in the GreenChill Store Certification Program can be a great idea. 

Reporting date: Rolling (Annual recertification required)

Who Must Report

Reporting is not mandatory. 

• Any U.S. food retail store can participate voluntarily:
  • 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

1. Store Certification Application Workbook (XLS)  including:
   • Refrigerant types and amounts
   • Refrigeration loads
   • Emissions data
   • Technology specifications
2. Installation leak testing documentation (new stores)
3. Annual recertification documentation

EPA AIM Act Emissions Reduction and Reclamation Program 

A major regulatory shift requiring facilities to minimize emissions of refrigerant gases and maximize reclamation. Although the deadline for reporting is not until January 1, 2026, corporations need to begin preparing in 2025 to meet that deadline. 

Read more about the AIM Act in our Fexa guide. 

Reporting date: January 1, 2026 

Who Must Report

• Systems with 15+ pounds of refrigerants with GWP >53
• Systems with 1,500+ pounds require automatic leak detection
• Applies to:
  • Industrial refrigeration
  • Commercial refrigeration
  • Comfort cooling systems
  • Small businesses meeting thresholds

Required Documentation and Reports

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

How to Prepare for January 2026

• Conduct a thorough asset inventory
• Install any required systems
• Establish an inspection program
• Implement meticulous record-keeping

What can you do to start preparing for these compliance obligations? 

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.

Check out Fexa’s Asset Inventory Checklist to prepare for the AIM Act. This checklist will also help you prepare for the reporting tasks you need to accomplish in 2025.