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Refrigerant compliance

EPA refrigerant leak rules for grocery stores: what applies in 2026.

A plain-language guide to the AIM Act leak repair rule, Section 608, automatic leak detection, chronic-leak reporting, California’s RMP and Canadian rules, written for grocery operators.

The short version.

Since January 1, 2026, grocery refrigeration systems holding 15 lb or more of HFC refrigerant fall under EPA leak repair rules. Every time a technician adds refrigerant, a leak rate must be calculated. If it is above 20% for commercial refrigeration, the leak must be repaired within 30 days and the repair verified. Systems that lose 125% or more of their charge in a year must be reported to EPA.

Older R-22 systems were already covered by similar rules under Section 608. California and Canada have their own requirements on top.

Which systems are covered.

EPA’s Emissions Reduction and Reclamation (ER&R) rule, issued under the AIM Act and codified at 40 CFR Part 84, Subpart C, applies leak repair requirements to appliances with a full charge of 15 lb or more of an HFC, or of a substitute with a global warming potential above 53. In a grocery store that typically includes the rack systems and many remote condensing units using R-404A, R-407A, R-407F, R-448A or R-449A.

Systems using ozone-depleting refrigerants such as R-22 remain under the older Section 608 rules (40 CFR Part 82, Subpart F), which apply to appliances with 50 lb or more.

Leak rate triggers.

The leak rate that requires repair depends on the type of appliance. Supermarket racks, display cases and walk-in systems are commercial refrigeration.

Appliance typeLeak rate that triggers repair
Commercial refrigeration (supermarket racks, cases, walk-ins)20%
Industrial process refrigeration30%
Comfort cooling and other appliances10%

What to do when a system exceeds the trigger.

The obligations start with the refrigerant addition that shows the leak rate is over the limit.

  • Calculate the leak rate at every refrigerant addition, using the annualizing or rolling-average method.
  • Repair the leak within 30 days of that addition. Extensions are limited and have conditions.
  • Perform an initial verification test within the 30 days, and a follow-up verification test after the system returns to normal operation.
  • If the repair fails, prepare a retrofit or retirement plan within 30 days and complete it within one year.
  • After an exceedance, inspect the system for leaks: quarterly for systems of 500 lb or more, annually for smaller systems, until the required clean inspections are complete.
  • Keep records of additions, leak rate calculations, repairs, tests and inspections for three years.

Chronically leaking appliances.

A system that leaks 125% or more of its full charge during a calendar year is a chronically leaking appliance. The owner must report it to EPA by March 1 of the following year, including what was done to identify and repair the leaks. For HFC systems under the AIM Act rule, the first reports cover 2026 and are due March 1, 2027.

This is not a rare edge case. A 1,200 lb rack that needs a 500 lb top-up three times a year adds 1,500 lb, exactly 125% of its charge. We have seen that pattern in the field.

Automatic leak detection for large systems.

Commercial refrigeration systems with a full charge of 1,500 lb or more of HFC must have automatic leak detection (ALD). ALD can be direct (sensors that detect refrigerant in the air) or indirect (analysis of system data such as receiver levels, pressures and temperatures), and must meet EPA’s alerting and annual audit requirements.

System installedALD required by
On or after January 1, 2026Within 30 days of installation
January 1, 2017 to December 31, 2025January 1, 2027

Reclaimed refrigerant from 2029.

From January 1, 2029, servicing supermarket systems with HFC refrigerant must use reclaimed HFCs. Reclaimed refrigerant supply is limited, which makes every pound you don’t lose to a leak more valuable.

California: the Refrigerant Management Program.

California’s Air Resources Board runs its own Refrigerant Management Program for systems with more than 50 lb of high-GWP refrigerant. It is stricter than the federal rule in important ways: leaks must be repaired within 14 days regardless of leak rate, facilities must register and report through CARB’s R3 system, and records are kept for five years. Large facilities need automatic leak detection. Operators with 20 or more California stores also have fleet-wide GWP targets.

Canada.

In Canada, refrigerant leak rules for most private grocery stores come from the provinces. In Ontario, O. Reg. 463/10 covers ozone-depleting substances and other halocarbons, including HFCs, and requires work to be done by certified technicians with leak testing and record-keeping. The federal Halocarbon Regulations, 2022 set detailed leak testing, repair and release reporting rules, but apply mainly to federal works and undertakings and to federal and Aboriginal lands. Check the rules for each province you operate in.

Is the rule going to change?

The AIM Act leak repair rule is in effect as published. In November 2025, FMI (the Food Industry Association) petitioned EPA to raise the 15 lb threshold, relax the leak rate triggers, allow longer repair times and delay the ALD and reclaim dates. EPA has proposed changes for transport refrigeration and has said it may revisit other leak management provisions in future rulemaking. As of September 2026, the grocery requirements above still apply.

Separately, EPA’s 2026 changes to the Technology Transitions rule delayed the lowest GWP limits for new supermarket systems to 2032, so existing HFC systems will stay in service longer. That makes leak management more important, not less.

How to stay ahead of it.

Every compliance obligation above starts when refrigerant is added. The operators who find it easiest are the ones who find leaks before the top-up.

  • Know which systems are 15 lb or more, and which are 1,500 lb or more.
  • Choose one leak rate method and make sure your contractor applies it at every addition.
  • Watch refrigerant use per rack over a full year, not per service call. Repeat top-ups are the chronic-leak warning sign.
  • Use continuous monitoring to spot racks losing charge between visits.
  • Keep service records in one place you can hand to an auditor.

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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Common questions

What is the EPA leak rate threshold for supermarket refrigeration?

20% for commercial refrigeration, which includes supermarket racks, display cases and walk-ins. It applies to HFC systems with 15 lb or more under the AIM Act rule from January 1, 2026, and to ODS systems such as R-22 with 50 lb or more under Section 608.

How long do grocery stores have to repair a refrigerant leak?

Under EPA rules, 30 days from the refrigerant addition that showed the leak rate exceeded the trigger. In California, the Refrigerant Management Program requires repair within 14 days regardless of leak rate.

When is the first EPA chronic leak report due for HFC systems?

March 1, 2027, covering systems that leaked 125% or more of their full charge during calendar year 2026.

Does my store need automatic leak detection?

Only for commercial refrigeration systems with 1,500 lb or more of HFC refrigerant. New systems installed from 2026 need it within 30 days of installation. Systems installed from 2017 through 2025 need it by January 1, 2027.

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