EPA 608 leak repair rules in 2026: the 15-pound threshold and the 10/20/30% triggers

Checked on September 11, 2026, against the current eCFR text (Title 40 as amended through September 9, 2026) and EPA's January 2026 fact sheet. Every figure below names its source; the sources are listed at the end.

Since January 1, 2026, there have been two federal leak repair rulebooks for stationary refrigeration and air conditioning, and a technician can meet both on the same day. The older one, 40 CFR 82.157 under Clean Air Act Section 608, covers ozone-depleting refrigerants in appliances of 50 pounds or more. The newer one, 40 CFR 84.106 under the AIM Act, covers HFC refrigerants in appliances of 15 pounds or more. The percentages and the clocks are almost identical; the thresholds, and the refrigerants they attach to, are not. This page covers what changed, which rule catches which appliance, and what the Section 608 exam outline still expects you to know.

What changed on January 1, 2026

EPA's Emissions Reduction and Reclamation (ER&R) rule, published on October 11, 2024, created a leak repair program for HFCs in 40 CFR Part 84, Subpart C. Its leak repair section, 40 CFR 84.106, applies as of January 1, 2026 (§84.106(a)(4); EPA fact sheet, January 2026).

The section covers refrigerant-containing appliances with a full charge of 15 or more pounds where the refrigerant contains a regulated substance (an HFC listed under the AIM Act) or a substitute for one with a global warming potential greater than 53 (§84.106(a)(1) and (a)(2)). The number 53 is not arbitrary: it is the lowest exchange value the AIM Act assigns to any regulated HFC (EPA fact sheet, footnote 4).

Two groups are carved out (§84.106(a)(3)):

• Appliances that contain only an ozone-depleting substance as refrigerant. Those stay under the Section 608 rule.
• Appliances in the residential and light commercial air conditioning and heat pump subsector. EPA describes that subsector as equipment for cooling air in individual rooms, single-family homes and small commercial buildings, and notes that chillers and certain variable refrigerant flow systems belong to other subsectors, so they are not excluded (EPA fact sheet, footnote 3).

A concrete case that is clearly inside the new rule: a walk-in cooler in a grocery store holding 20 pounds of an HFC blend. Retail food is commercial refrigeration by definition (§84.102), the charge is above 15 pounds, and the refrigerant is an HFC.

The 10/20/30 triggers

Both rules use the same three leak-rate thresholds, expressed as a percentage of the full charge per year:

• 30 percent for industrial process refrigeration
• 20 percent for commercial refrigeration
• 10 percent for comfort cooling and all other covered appliances; Part 84 names refrigerated transport in this group explicitly

(§84.106(c)(2); §82.157(c)(2))

Part 84 also defines the buckets. Commercial refrigeration means the retail food and cold storage warehouse subsectors. Comfort cooling includes chillers, commercial split systems, dual-function heat pumps and packaged roof-top units (§84.102).

The trigger is checked every time refrigerant is added, using either the annualizing method or the rolling average method, except when the addition comes right after a retrofit, right after a new installation, or qualifies as a seasonal variance (§84.106(b); §82.157(b)). If you are the person adding the refrigerant, you must hand the owner or operator a record at the end of the job: which appliance, the date, the parts worked on, the type of work, your name, and the amount and type of refrigerant added. Calculating the leak rate from that record is the owner's or operator's job, not yours (§84.106(b) and (l)(4); §82.157(b) and (l)(2)).

Which rule catches which appliance

• 40 CFR 82.157 (Section 608): since April 10, 2020, only appliances with 50 or more pounds of a class I or class II refrigerant (for example CFCs and HCFCs) or a blend containing one; not appliances that hold only substitutes such as HFCs (§82.157(a)).
• 40 CFR 84.106 (AIM Act): from January 1, 2026, appliances with 15 or more pounds of an HFC or of a substitute with a GWP above 53, minus the two exclusions above (§84.106(a)).

EPA's fact sheet puts the two programs side by side in its Table 2: most of the mechanics are the same; the applicability lines differ, and Part 84 requires automatic leak detection on appliances that meet the criteria in §84.108, where Section 608 leaves it optional (EPA fact sheet, Table 2).

After the trigger: the clocks are the same

Once a calculation shows the appliance over its trigger rate, the sequence is the same in both rulebooks, with one difference in who may do the work.

1. Repair within 30 days, or 120 days if an industrial process shutdown is required. A certified technician must do the leak inspection that locates the leaks; under Part 84 the repairs must also be done by a certified technician, defined there as a technician certified under 40 CFR 82.161, that is, Section 608 certified (§84.106(c)(1) and (d)(1); §84.102; §82.157(d)(1)).
2. An initial verification test inside that same 30-day or 120-day window, then a follow-up verification test within 10 days of a successful initial test, or within 10 days of the appliance returning to normal operating conditions if it was evacuated for the repair (§84.106(e); §82.157(e)).
3. Leak inspections afterward, by a certified technician: every three months for commercial and industrial process appliances of 500 pounds or more, until the calculations show four clean quarters in a row; once a year for everything else, until one clean year. An automatic leak detection system audited or calibrated every year can replace them (§84.106(g); §82.157(g)).
4. If the owner chooses to retrofit or retire the appliance instead of repairing it, does not attempt repairs at all, or the repairs fail to bring the rate under the trigger, a retrofit or retirement plan is due within 30 days, signed by an authorized company official, with the work finished within one year (§84.106(h); §82.157(h)).
5. An appliance that leaks 125 percent or more of its full charge in a calendar year is a chronically leaking appliance, and the owner must report it to EPA by March 1 of the following year (§84.106(j); §82.157(j)).
6. Records are kept for at least three years. Part 84 adds a deadline: by January 1, 2026, or at installation for newer equipment, the owner must determine and record the full charge of every appliance with 15 or more pounds (§84.106(l)(1); §82.157(l)).

Both rules allow extensions in a short list of situations, most commonly parts that cannot arrive in time: the deadline then becomes 30 days after delivery, capped at 180 days, or 270 days with an industrial process shutdown, counted from the day the trigger rate was exceeded (§84.106(f)(1)(iii); §82.157(f)(1)(iii)).

Why the 608 exam still asks about 50 pounds

EPA publishes a topic outline for the four Section 608 tests; the tests themselves are administered by EPA-approved certifying organizations, and the certification does not expire (EPA, Section 608 Technician Certification page). On that outline, last updated December 5, 2025, both the Type II and the Type III sections list the allowable leak rate for commercial and industrial process refrigeration and the allowable leak rate for other appliances above 50 pounds. Type II adds leak repair recordkeeping and extensions to the repair time frame; Type III adds leak inspection requirements for appliances that exceed the leak rate and reporting for chronically leaking appliances (EPA, Test Topics). One wording detail worth knowing: the outline's phrase is "more than 50 pounds", while the regulation itself says "50 or more pounds" (§82.157(a)).

Read that as follows. The exam is anchored in the Section 608 program, so a leak repair question is most likely built around the 50-pound ozone-depleting threshold and the 10/20/30 percentages. The 15-pound HFC threshold is the one you will meet on the job. Learn both, and learn which refrigerant each belongs to; the percentages and the clocks you only learn once.

Numbers to memorize

• Thresholds: 50 pounds for ozone-depleting refrigerants (Part 82); 15 pounds for HFCs and substitutes with GWP above 53 (Part 84, since January 1, 2026)
• Triggers: 30 percent industrial process refrigeration; 20 percent commercial refrigeration; 10 percent comfort cooling and everything else (refrigerated transport is named in Part 84)
• Repair clock: 30 days, or 120 days with an industrial process shutdown
• Follow-up verification test: within 10 days of a successful initial test
• Leak inspections: every three months at 500 pounds or more (commercial and industrial process); once a year otherwise
• Retrofit or retirement plan: written within 30 days, finished within one year
• Chronically leaking appliance: 125 percent of the full charge in a calendar year; report due March 1
• Records: three years
• Outside Part 84: appliances with only ozone-depleting refrigerant; residential and light commercial air conditioning and heat pumps

If you want to drill these numbers until they stick, the EPA 608 Prep app covers both rulebooks and marks the 2026 changes with a badge: EPA 608 Prep: HVAC Tests 2026.

This article is a study aid, not compliance advice. For the binding text, use the eCFR links above. StudyRig is an independent publisher and is not affiliated with or endorsed by the U.S. Environmental Protection Agency or any certification provider.