Regulation: The United States Environmental Protection Agency (USEPA) enacted 40 Code of Federal Regulations (CFR) Part 84, the phasedown of hydrofluorocarbons (HFCs), to restrict the use of regulated substances. The requirements of this regulation maximize reclaiming and minimize releasing regulated substances from equipment and ensure the safety of technicians and consumers.
In addition to implementing major restrictions, 40 CFR Part 84 also establishes sectors for enforcement that are regulated individually. Each sector places limits on the types and amounts of regulated substance that may be used, in addition to setting new compliance deadlines and regulatory requirements such as recordkeeping and reporting.
Who does this rule apply to?
40 CFR Part 84 applies to owners and operators of equipment containing regulated substances. These regulated substances—found in 40 CFR 84.64(b) Table 1 and including substances such as formic acid, acetone, HCFO-1233yd(z), and R600a—are used to recharge refrigerant-containing equipment. Each of the listed substances has been assigned a global warming potential (GWP), and a GWP threshold has been applied to the different sectors of equipment, based on equipment details.
The rule has established the following sectors; please refer to 40 CFR 84.54 for sector details and thresholds:
- Commercial ice machines
- Retail food refrigeration
- Industrial process refrigeration
- Cold storage warehouse systems
- Residential and light commercial air-conditioning and heat pump systems
What are the requirements?
In addition to compliance with GWP thresholds for equipment charge and recharge, 40 CFR Part 84 implements multiple additional requirements. The following list includes, but is not limited to, the major requirements with a compliance deadline of January 1, 2026:
- GWP thresholds: Chillers and industrial process refrigeration systems (Please refer to 40 CFR 84.54[c] for equipment details such as charge capacity and temperature.)
- Equipment labeling: Permanent labels for equipment containing regulated substances
- Leak rate calculations and recordkeeping: New leak rate calculation options and acceptable leak rate amounts
- Leak repair: Requirements for leak repairs, verification, inspection, recordkeeping, and reporting of such incidents
- Automatic leak detection systems: Installation of continuously monitored automatic leak detection systems in indoor areas and on subject equipment
- Training and certification: Requirements for the training and certification of technicians servicing subject equipment and handling regulated substances
- Fire suppression equipment: Restrictions on the venting and release of regulated substances from maintenance failures, requirement of recycled regulated substance use, and requirements for technician training and records
Please keep in mind that 40 CFR Part 84 has many parts and subparts. The regulation, listed below as a reference, provides finite details on equipment, HFCs and regulated substances, and regulatory requirements as of January 1, 2026.
Questions? We’re here to help.
Stay ahead of compliance deadlines and ensure your facility meets all refrigerant and fire suppression requirements. For support with compliance or to discuss any questions or concerns you may have, please contact Taylor Wheelon or Katie Milk.
Reference
40 Code of Federal Regulations Part 84—Phasedown of Hydrofluorocarbons
