Refrigerant compliance
California refrigerant rules for grocers: CARB’s RMP vs. EPA’s AIM Act.
How California’s Refrigerant Management Program differs from federal EPA leak rules for supermarkets: thresholds, repair deadlines, reporting, records and GWP targets.
The short version.
California grocery stores answer to two sets of refrigerant rules: the California Air Resources Board’s Refrigerant Management Program (RMP) and EPA’s federal AIM Act rules. Where they differ, the stricter rule applies. In practice that usually means CARB: every leak must be repaired within 14 days, facilities register and report through CARB’s R3 system, and records are kept for five years.
Side by side.
| CARB Refrigerant Management Program | EPA AIM Act (federal) | |
|---|---|---|
| Systems covered | More than 50 lb of refrigerant with a GWP of 150 or more | 15 lb or more of HFC, or a substitute with GWP above 53 |
| When repair is required | Any leak, regardless of leak rate | When the leak rate exceeds 20% for commercial refrigeration |
| Repair deadline | 14 days | 30 days from the refrigerant addition |
| Leak inspections | Periodic, based on system size | After an exceedance, until the system passes |
| Registration and reporting | Register and report through CARB’s R3 system; annual reports due March 1 | Chronic-leak reports due March 1 for systems losing 125% of charge |
| Records | 5 years | 3 years |
| Automatic leak detection | Required for large systems | Required for systems of 1,500 lb or more |
Fleet-wide GWP targets for larger operators.
CARB also sets company-wide targets for operators with 20 or more California stores: a weighted-average refrigerant GWP below 2,500, or a 25% reduction in greenhouse gas potential, by the end of 2026; and below 1,400, or a 55% reduction, by 2030. New supermarket refrigeration systems in California have been limited to very low-GWP refrigerants since 2022.
Other states.
New York, Washington and several other states have their own HFC rules, some with their own leak detection requirements. If you operate across state lines, check each state as well as the federal rule.
What this means day to day.
Under CARB there is no leak rate below which a leak can wait. The 14-day clock starts when a leak is found, so the practical goal is to find leaks while they are small and keep repair records complete. Continuous leak detection helps on both counts: fewer surprise top-ups, and a clear history of when a loss started and when the repair stopped it.
Sources
This guide summarizes public rules for grocery operators. It is not legal advice; confirm obligations for your systems with your compliance adviser.
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