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EPA compliance · guide
10%, 20% or 30%? Which EPA leak rate threshold applies
40 CFR 84.106 · in force since January 1, 2026
Three numbers, and picking the wrong one is the difference between “log it and move on” and a 30-day repair clock you did not know was running. Here is how the EPA decides which applies, and the two questions to settle before you even get to the percentage.
First: is the appliance covered at all?
The leak repair rules under the AIM Act apply to a refrigerant-containing appliance with a full charge of 15 pounds or more, where the refrigerant is either a regulated substance (an HFC) or a substitute for one with a global warming potential above 53.
Two carve-outs matter, and both catch people:
- Residential and light commercial air conditioning and heat pumps are exempt. That is equipment cooling individual rooms, single-family homes and small commercial buildings. Chillers and certain variable refrigerant flow systems are not in that subsector, so they stay covered.
- Appliances running solely on an ozone-depleting refrigerant are not covered by this rule. They fall under the older Section 608 leak repair regime instead, which works to different numbers.
“This section applies to refrigerant-containing appliances with a full charge of 15 or more pounds of refrigerant… The requirements of this section apply as of January 1, 2026.” — 40 CFR 84.106(a)
The 15-pound trap
If you learned this rule before 2026, the number in your head is probably 50 pounds. That was the threshold under Section 608, and it still is for ozone-depleting refrigerants. For HFCs it is now 15 pounds, which pulls a very large amount of equipment into scope that was previously outside it — small rack systems, walk-ins, process chillers, plenty of things nobody was calculating leak rates for in 2025.
| AIM Act — 40 CFR 84.106 | Section 608 — 40 CFR 82.157 | |
|---|---|---|
| Refrigerant | HFCs and substitutes with GWP above 53 | Class I and Class II ozone-depleting substances |
| Charge size | 15 lb or more | 50 lb or more |
| Residential / light commercial AC | Exempt | No exemption |
| In force | January 1, 2026 | Still in force for ODS appliances |
Then: which of the three thresholds
| Appliance type | Threshold | Typical equipment |
|---|---|---|
| Industrial process refrigeration | 30% | Process cooling in manufacturing, chemical and pharmaceutical plants, ice rinks |
| Commercial refrigeration | 20% | Supermarket racks, walk-ins, display cases, cold storage |
| Comfort cooling, refrigerated transport, or anything else | 10% | Chillers and other covered building cooling, transport refrigeration units, and every covered appliance that is not one of the two above |
“20 percent leak rate for commercial refrigeration appliances; 30 percent leak rate for industrial process refrigeration appliances; and 10 percent leak rate for comfort cooling appliances, refrigerated transport appliances, or other refrigerant-containing appliances with a full charge of 15 or more pounds of refrigerant not covered by paragraph (c)(2)(i) or (ii).” — 40 CFR 84.106(c)(2)
The 10% category is the catch-all, not a category
This is worth reading twice. Ten per cent is not simply “comfort cooling”. It is comfort cooling, refrigerated transport, and everything else that is covered but is not commercial refrigeration or industrial process refrigeration. If you cannot confidently put an appliance in the 20% or 30% box, it is in the 10% box — the strictest of the three.
So the safe order to think in is: is it IPR? No. Is it commercial refrigeration? No. Then it is 10%. Not the other way round.
The costly mistake. Assuming a large air conditioning chiller gets the 20% commercial refrigeration threshold because it is big and it is on a commercial building. It does not. Commercial refrigeration means refrigeration — keeping product cold. A chiller cooling a building is comfort cooling, at 10%.
Work out where you actually stand
Once you know the threshold, the number that matters is the leak rate on the last refrigerant addition. Our refrigerant leak rate calculator runs both of the EPA’s permitted methods and tells you whether you are over the line for the appliance type you pick.
If you are over it
Being over the threshold starts a fixed sequence with fixed dates: locate and repair within 30 days, an initial verification test inside that same window, and a follow-up verification test within 10 days of the initial one succeeding. The 30-day repair clock and the two verification tests walks through it.
Being under it does not mean there is nothing to do. The calculation itself is a record you are required to keep, along with seven other things about that service visit. What refrigerant records the EPA requires lists them.
Getting this right every time
AirCert knows which threshold each appliance is on
Set the appliance type once and AirCert applies the right threshold on every refrigerant addition afterwards — so nobody has to remember whether the rack is 20% and the chiller is 10% at half past four on a Friday. Out now on Android, and coming soon to iPhone and iPad.
Get it on Google PlayWhere this comes from
Applicability, exemptions and the three thresholds are at 40 CFR 84.106. The Section 608 comparison is at 40 CFR 82.157. The EPA sets both side by side in its January 2026 leak repair fact sheet.
This is a guide, not legal advice. Every figure here is cited, but which category your equipment falls in depends on what it does and how it is used. Check the regulation, and take advice if the answer is not obvious.