Refrigerant compliance
Chronically leaking appliance reports: a grocer’s guide to EPA’s 125% rule.
Which grocery refrigeration systems count as chronically leaking, how to check, what the March 1 report covers, and how to stay off the list.
What counts as chronically leaking.
A refrigeration system is a chronically leaking appliance when the refrigerant added to it during a calendar year totals 125% or more of its full charge. The owner must report it to EPA by March 1 of the following year.
For HFC systems with 15 lb or more, this applies under the AIM Act rule from 2026, so the first reports are due March 1, 2027. Older ozone-depleting systems, such as R-22 systems with 50 lb or more, have had the same requirement under Section 608.
How to check a rack.
Add up every refrigerant addition to the system in the calendar year and compare the total with its full charge.
| Rack full charge | Chronic-leak line (125%) | Example additions in the year | Chronic leaker? |
|---|---|---|---|
| 1,200 lb | 1,500 lb | 500 + 500 + 500 = 1,500 lb | Yes |
| 1,200 lb | 1,500 lb | 300 + 250 = 550 lb | No |
| 400 lb | 500 lb | 150 + 200 + 180 = 530 lb | Yes |
What the report covers.
The report identifies the system and describes what was done to find and repair its leaks during the year. Section 608 reports for ozone-depleting systems go to EPA at 608reports@epa.gov. For HFC systems under the AIM Act rule, follow the submission instructions on EPA’s HFC regulatory pages, which EPA updates as reporting systems change.
Why grocery racks end up on the list.
The usual pattern is a leak that keeps coming back. Each service visit finds and fixes a small leak and tops the system up, and nobody sees the total across the year. In our leak study, a 1,200 lb rack was receiving about 500 lb three times a year: exactly the 125% line.
How to stay off it.
- Track refrigerant additions per system for the whole year, not per service call.
- Treat a second top-up on the same rack within a few months as a warning sign.
- Use continuous leak detection to confirm whether a repair actually stopped the loss.
- Escalate to a deeper leak search when losses continue after repairs.
Sources
- eCFR: 40 CFR 82.157 Appliance maintenance and leak repair
- EPA: Section 608 recordkeeping and reporting
- EPA: Regulatory actions for managing HFC use and reuse
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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