⚖️ Does the EPA Leak-Repair Rule Apply to Your Unit? A Charge Guide by Equipment Type
Before you work out a leak rate, work out whether you owe one. The federal leak-repair rule starts at 15 pounds of HFC charge, and a 4-ton packaged unit is usually nowhere near it. Here is roughly what each kind of equipment holds, why the nameplate settles it, and what you still owe on a unit that is exempt.
Most of what gets written about refrigerant leak rates starts with the percentages. That is the second question. The first one is whether the rule applies to the thing you are standing in front of at all, and for a large share of the equipment a service tech touches in a week, it does not.
The gate is the charge. Since 1 January 2026, under the AIM Act regulations at 40 CFR Part 84, Subpart C, the federal leak-repair requirements bite at 15 pounds or more of full charge for an HFC or substitute refrigerant with a global warming potential above 53 — R-410A, R-404A, R-134a, R-407C, R-448A, R-449A and the rest of what is actually in the field. For ozone-depleting refrigerants the old line still stands: 40 CFR Part 82 keeps a 50-pound threshold, which is where an R-22 system is still handled.
There is a second exclusion in the same section, and it is not a number. 40 CFR 84.106(a)(3) takes two categories out of the leak-repair requirements entirely: appliances containing solely an ozone-depleting refrigerant, which stay under Part 82, and appliances used for the residential and light commercial air conditioning and heat pump subsector. The subpart does not define that subsector by tonnage or by Btu, so where a light-commercial rooftop unit sits against it is genuinely unclear from the text — a question to ask rather than one to answer off a charge table.
Underneath 15 pounds there is no leak-rate math to do, no 30-day repair clock, and no annualised percentage to calculate. What there still is, on every appliance regardless of size, is the venting prohibition and the recovery requirements. Those have no charge floor. A one-pound mini-split is exempt from leak repair and is not exempt from 40 CFR 82.154.
Start with the plate, not the tonnage
A nameplate prints the factory full charge, usually in pounds and ounces, sometimes per circuit. That number is the one the rule is written against, and it is the only one that settles the question for a specific unit. Tonnage is a proxy, and on a plate that has been in the weather for fifteen years the charge is often the line that is still legible when the model number is not.
The ranges in the next section exist to answer a different question: is this unit close enough to 15 pounds that I need to go up on the roof and look? For a single-zone mini-split the answer is no. For a 10-ton packaged unit the answer is yes, and it has probably already been answered for you by whoever holds the service contract.
One thing the ranges cannot decide for you, and the regulation can. A device with two independent refrigerant circuits is not one appliance: the definition of a refrigerant-containing appliance at 40 CFR 84.102 ends by saying that for such devices with multiple circuits, each independent circuit is considered a separate appliance, and 40 CFR 82.152 carries the same sentence for ozone-depleting refrigerants. So the 15-pound gate is read against each circuit’s own full charge — a packaged unit holding 20 pounds across two independent circuits of 10 is, on the face of that definition, two appliances under the gate rather than one over it. Record the per-circuit charges off the plate, because those are the numbers everything else is calculated against. Where the plate gives only a combined figure, or the circuits are not genuinely independent, that one is worth putting to your compliance contact in writing.
Roughly what each kind of unit holds
These are rule-of-thumb ranges, not specifications. Direct-expansion equipment generally runs somewhere around two to four pounds of refrigerant per ton of capacity, and line-set length moves it in both directions — a long run to a condenser on the other side of a roof adds charge that a factory figure does not include. Use this to decide whether the plate is worth walking to.
| Equipment | Typical full charge | Usually at or over 15 lb? |
|---|---|---|
| Single-zone ductless mini-split | About 2–6 lb | No — well under, before line-set additions |
| Residential split system, 1.5–5 ton | About 4–15 lb | Usually no, and a long line set is what pushes a 5-ton one close |
| Packaged rooftop unit, 3–5 ton | About 8–20 lb, often split across two circuits | Borderline — read the plate. This is the case people ask about most |
| Packaged rooftop unit, 7.5–12.5 ton | About 20–45 lb across circuits | Usually yes for the unit as a whole |
| Rooftop unit or air handler, 15–25 ton | Tens of pounds per circuit | Yes |
| Multi-zone VRF system | Tens of pounds, rising with pipe run | Usually yes |
| Walk-in cooler or freezer condensing unit | Anywhere from a few pounds to tens of pounds | Varies — read the plate |
| Supermarket refrigeration rack | Hundreds of pounds | Yes, and it is commercial refrigeration, so the rate is 20% |
| Air-cooled or water-cooled chiller | Tens to hundreds of pounds | Yes |
| Hydronic radiator, boiler or heating loop | No refrigerant at all | Not covered. Water or steam is not a refrigerant and Part 84 does not reach it |
The 4-ton packaged unit, specifically
It is the most-asked version of this question, so here is the direct answer. A 4-ton packaged rooftop unit is typically somewhere in the eight to twenty pound range depending on make, circuit layout and how far the charge was topped up over its life. That straddles the 15-pound line, which is exactly why it cannot be answered from the tonnage.
Go and read the plate. If the factory full charge is under 15 pounds and nobody has re-engineered the system, the leak-repair requirements in Part 84 do not apply to it: no trigger rate, no repair clock, no annualised calculation. If it is at or over 15 pounds, it is comfort cooling, and the rate that matters is 10%.
Either way, write the number down on the equipment record the first time you read it. The second person to ask this question about that unit should not have to climb up again.
If it does apply: 10, 20 and 30
Once an appliance is over the charge gate, 40 CFR 84.106(c)(2) sets three trigger rates by what the appliance is for. They are annualised leak rates, not the amount of gas you added on the day.
| Appliance class | Triggers repair above | What is in this class |
|---|---|---|
| Comfort cooling | 10% | Rooftop units, split systems, air handlers, chillers serving occupied space. Most field equipment that clears the gate lands here |
| Commercial refrigeration | 20% | Walk-ins, reach-ins, supermarket racks, ice machines |
| Industrial process refrigeration | 30% | Process cooling in manufacturing and chemical plants |
The clock, once a rate is exceeded
Exceeding a trigger rate starts a repair obligation, not a fine. The owner or operator has to locate and repair the leaks within 30 days of the refrigerant addition that revealed the leak, or 120 days where an industrial process shutdown is needed to get at it. Extensions exist under 84.106(f) for specific documented situations — a genuinely unavailable component is the usual one — and they are conditional, so they are not something to plan the season around.
A repair has to be verified, and an appliance that keeps failing verification is the one that turns into a real problem: repeated failures move you from a repair obligation into retrofit-or-retire territory rather than an indefinite series of top-ups.
On penalties: the amounts are set by statute and adjusted annually, so any specific dollar figure you read on a forum is out of date by definition. The defensible position is not knowing the number. It is holding the records that show the leak was found, dated, repaired and verified.
Working out the annualised rate
The percentage is not "how much did I put in today". It is the amount added to correct a leak, scaled to a year against the appliance’s full charge, so the same 4 pounds means something different added twice in a month than added once in a year.
You need three numbers: the full charge from the plate, the weight added, and the date of the previous addition. The free EPA leak-rate calculator on this site does the arithmetic from those three and tells you which side of the trigger rate you landed on. There is no account needed and nothing to install.
If the same appliance comes up more than once, the dates are the part that gets lost. In the app, refrigerant goes on the same service record as the maintenance note, the parts replaced and the photos, so the previous addition is already dated and the annualised rate is worked out from it against the 10 / 20 / 30 thresholds. That part is free on every tier, and it works with no signal, because the calculation happens on the phone.
What you owe on a unit that is exempt
Being under 15 pounds takes away the leak-repair obligation. It does not take away the rest.
The venting prohibition applies to every appliance, of every size: knowingly releasing refrigerant during maintenance, service, repair or disposal is prohibited regardless of charge. Recovery before opening a system, certified technicians, certified recovery equipment and the sales restrictions all sit outside the charge threshold too. A tech who vents a two-pound mini-split has not found a loophole.
And there is a commercial reason to keep the record even where there is no legal one. A unit that has been topped up three times in eighteen months is telling you something, and the only way to see that pattern is to have dated the additions. That is true at four pounds of charge and at forty.
What to write down, either way
The record that answers this question next time is short: refrigerant type, nameplate full charge, the date and weight of each addition, what was found, what was repaired, and how the repair was verified. Photographs of the plate and of the repair, attached to the unit rather than sitting in a camera roll.
On the phone that is one service record per visit with the refrigerant entry on it, and the EPA thresholds explained in full if you want the regulation rather than the field version. Entering the work — equipment, parts, photos, service logs, refrigerant charges and the leak-rate math — is free on every tier and works offline. Turning it into a PDF for a building owner or an auditor is part of Pro.
Three minutes on the roof that save the argument later
This question only gets asked twice on the same unit because nobody wrote down the answer the first time. The charge is printed on the plate today and may not be legible in five years.
Read the full charge off the plate and record it
Not the tonnage — the full charge in pounds, and the refrigerant type beside it. That one number decides whether any of the leak-repair rules reach this appliance, and it is the first thing to fade on a plate left in the weather. Photograph the plate while you are there.
Date every addition, even on an exempt unit
The annualised rate is arithmetic on dates. Without the previous addition date there is no rate to calculate, only a guess. On an exempt unit the dates are still what tell you a small system is losing gas faster than it should.
Run the number rather than eyeballing it
The leak-rate calculator takes the full charge, the weight added and the previous addition date, and returns the annualised rate against the 10 / 20 / 30 thresholds. It is free and needs no account.
Frequently Asked Questions
What is the allowable leak threshold for a packaged 4-ton rooftop unit?
It depends on the nameplate full charge, not the tonnage. A 4-ton packaged unit typically holds somewhere around 8 to 20 pounds, which straddles the 15-pound gate in 40 CFR Part 84 Subpart C. Under 15 pounds of HFC charge there is no federal leak-repair requirement and therefore no allowable rate. At or over 15 pounds it is comfort cooling, and the trigger rate is 10% annualised under 40 CFR 84.106(c)(2). Read the plate before assuming either.
Did the EPA leak repair requirements change in 2026?
Yes. From 1 January 2026 the AIM Act regulations at 40 CFR Part 84, Subpart C apply leak repair to appliances holding 15 pounds or more of an HFC or substitute with a global warming potential above 53. The previous federal leak-repair programme reached only 50 pounds and up. The 50-pound line did not disappear: it still governs ozone-depleting refrigerants under 40 CFR Part 82, which is where an R-22 system sits. The three trigger percentages themselves did not change.
What is the difference in allowed refrigerant loss between industrial process and comfort cooling?
Twenty percentage points. Under 40 CFR 84.106(c)(2) comfort cooling triggers repair above a 10% annualised leak rate, commercial refrigeration above 20%, and industrial process refrigeration above 30%. The classification follows what the appliance is used for, not its size or its refrigerant. A chiller cooling occupied space is comfort cooling at 10%, even if it holds several hundred pounds.
Does any leak rate apply to a radiator or a hydronic heating loop?
No. Refrigerant leak-repair rules apply to appliances containing a refrigerant. A hydronic radiator, a steam radiator and a boiler loop carry water or steam, which is neither an HFC under 40 CFR Part 84 nor an ozone-depleting substance under Part 82, so no leak rate and no repair clock applies. Water loss is a maintenance and a corrosion problem, and worth logging for that reason alone, but it is not a federal refrigerant obligation.
If my unit is under 15 pounds, is there anything I still have to do?
Yes, and this is the part people get wrong. The charge threshold only removes the leak-repair obligation. The venting prohibition at 40 CFR 82.154 has no charge floor at all: knowingly releasing refrigerant during maintenance, service, repair or disposal is prohibited on an appliance of any size. Recovery before opening a system, technician certification, certified recovery equipment and the refrigerant sales restrictions all apply regardless of charge.
Does the 15-pound threshold apply per circuit or per unit?
Per circuit, and the regulation says so rather than leaving it to judgement. The definition of a refrigerant-containing appliance at 40 CFR 84.102 ends: for such devices with multiple circuits, each independent circuit is considered a separate appliance. 40 CFR 82.152 says the same thing in almost the same words — "For a system with multiple circuits" in place of "For such devices with multiple circuits", and the same closing clause. So a packaged unit with two independent circuits of 10 pounds each is two appliances of 10 pounds rather than one of 20, and on the face of the definition neither clears the 15-pound gate. Record the per-circuit charges off the plate, because those are the numbers the leak rate and every threshold are calculated against. If the plate gives only a combined charge, or the circuits are not genuinely independent, that is the one to put to your compliance contact in writing.
Where does the app fit into any of this?
It holds the record the rules are argued from. Refrigerant type and nameplate full charge go on the equipment record, and each addition goes on the same service record as the maintenance note, the parts and the photos, so the previous addition is already dated. The annualised rate is worked out from those dates against the 10 / 20 / 30 thresholds. All of that is free on every tier and works with no signal, because it is calculated on the phone. Producing a PDF of it for an owner or an auditor is part of Pro.
Jonathan Curtis
HVAC Technician & Founder · Equipment Tracker Pro
Jonathan Curtis is an HVAC technician and the founder of Equipment Tracker Pro. He built the app to solve real problems he encountered in the field, including the daily frustration of faded nameplates and administrative double-entry.
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