For commercial building owners and operators, refrigerant management is becoming an increasingly important part of HVAC compliance. Effective January 1, 2026, the U.S. Environmental Protection Agency’s Emissions Reduction and Reclamation (ER&R) rule established leak-repair requirements for certain refrigerant-containing appliances charged with 15 pounds or more of an HFC or certain HFC substitutes. The requirements apply to several equipment types, including many commercial comfort-cooling systems. 

For properties with chillers, rooftop units, commercial split systems or other covered equipment, the rule adds new responsibilities: identifying leaks, calculating leak rates, completing repairs and maintaining records. Building owners and operators should understand which equipment is covered and set clear expectations with the engineers and HVAC contractors who service it. 

Start With the Equipment Inventory

The first step is to identify which refrigerant-containing appliances at a property are covered by the rule. The 15-pound threshold is based on the appliance’s full charge, and the refrigerant must contain an HFC or an HFC substitute with a global warming potential greater than 53. Residential and light-commercial air-conditioning and heat-pump equipment is exempt from these leak-repair provisions, while chillers and certain commercial systems may be subject to the requirements. 

For building owners, creating an accurate equipment inventory is a good place to start. Records should list each unit’s equipment type, full refrigerant charge, refrigerant in use, and servicing contractor. This information can also help property teams identify which systems may need additional attention during service work. 

Understand the Leak-Rate Threshold

The ER&R rule sets a different leak-rate threshold for each appliance type: 10% for comfort-cooling equipment, 20% for commercial refrigeration, and 30% for industrial process refrigeration. 

For comfort-cooling equipment, covered systems may include chillers, commercial split systems, and packaged rooftop units. When refrigerant is added to a covered appliance, the owner or operator generally must calculate the leak rate, subject to the rule’s exceptions and calculation methods. If the rate exceeds the applicable threshold, the leak generally must be identified and repaired within 30 days. A longer period may apply when an industrial process shutdown is necessary, but that exception generally does not apply to typical commercial comfort-cooling equipment. 

The amount of refrigerant added during service is therefore more than a maintenance detail. It can help determine whether a system has exceeded the regulatory threshold and whether further action is required. 

Know Who Holds the Responsibility

Building owners and operators should also understand how responsibility is shared between them and their HVAC service providers. Contractors may conduct leak inspections, calculate leak rates, make repairs and maintain records on an owner’s or operator’s behalf. However, the owner or operator remains responsible for meeting applicable requirements and must have access to the equipment records. 

That distinction matters when service work is outsourced. Property teams should know what information the contractor documents, where those records are stored and how the information will be shared with the building. A service invoice alone may not provide the complete documentation needed to show what happened during a repair. 

Service agreements and maintenance procedures can set clear expectations. Owners and operators should ensure contractors understand that documentation of refrigerant additions, leak calculations, repairs and verification activities is part of the service record for covered equipment. 

Give Engineers a Clear Documentation Trail

Documentation is especially important when a covered appliance repeatedly loses refrigerant. Records should help the property team determine when and how much refrigerant was added, why it was added, and what steps were taken to address the leak. 

EPA requirements include records of the appliance’s full charge, refrigerant added or removed, leak inspections, service and maintenance, repair verification, and, when applicable, retrofit or retirement plans. These records generally must be kept for three years. 

For building engineers and property managers, keeping this information together can make it easier to track an individual piece of equipment’s history. Repeated refrigerant needs may signal that a system requires further investigation, even if each service call seems routine. 

Ask HVAC Contractors the Right Questions

Property teams don’t need to handle every refrigerant calculation themselves, but they should know what to ask once service work is complete. When a contractor adds refrigerant to a covered appliance, they should provide the amount added and the reason for the addition, along with the calculated leak rate when required. 

If a leak is found, the service record should state where it was located, what repair was made, and how the repair was verified. Owners and operators should also know whether the repair requires additional inspections. 

For comfort-cooling equipment, the EPA requires annual leak inspections after a repair until the appliance’s leak rate stays below the applicable threshold for one year. 

These discussions can be built into routine service procedures. It’s generally easier to request this information during the repair than to reconstruct an equipment history months or years later. 

Pay Attention to Chronic Leaks

The rule also covers appliances that lose significant amounts of refrigerant over the course of a year. A covered appliance with a full charge of 15 pounds or more that loses more than 125% of that charge in a calendar year is considered a chronic leaker and must meet reporting requirements. The report is generally due to EPA by March 1 of the following year. 

A chronic leak can therefore involve more than another service call. If a system repeatedly requires substantial refrigerant additions, the property team should understand how those additions affect the appliance’s calculated leak rate and whether the system now requires additional action or reporting. 

Keep Compliance Information With the Building

Refrigerant records are most useful when accessible to those operating the property. Ownership, management or contractor changes can make equipment history hard to reconstruct if records exist only in a technician’s files or a contractor’s system. 

HVAC documentation should track covered equipment’s refrigerant type and full charge, service, refrigerant additions, leak calculations, repairs and required follow-up. Keeping these records with other property equipment files helps future engineers and managers assess aging systems and plan replacements. 

EPA’s ER&R requirements support broader federal efforts to reduce emissions of HFCs and certain substitutes and increase refrigerant recovery and reclamation. ER&R leak-repair rules are separate from EPA’s Technology Transitions requirements, which restrict certain higher-GWP refrigerants in new equipment and have sector-specific rules and compliance dates. 

Understanding the distinction and maintaining reliable service histories helps commercial property teams determine which requirements apply and what information to obtain from HVAC providers. As regulations evolve, equipment-level knowledge remains essential to responsible building operations. 

Thank you to our ENERGY STAR Month sponsor, Georgia Power

Learn More about Georgia Power’s Commercial Energy Efficiency Program here.

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