🧮 Is the EPA 125% Leak Rate Cumulative? Chronic Leaker Reporting, Explained

Yes — it is cumulative. The 125% in 40 CFR 84.106(j) is what one appliance lost over a calendar year, added up across every leak you found and every repair you made. It does not have to be one continuous leak, and no single event has to reach 125% on its own. An appliance that gets there must be reported to EPA by March 1 of the following year.

It is also not the number that starts a repair. Those are separate, they live two paragraphs earlier in the same section, and they are the 10 / 20 / 30 rates at 84.106(c)(2). An appliance can blow through its repair trigger several times in a year and never come close to 125%. An appliance that reaches 125% has almost certainly blown through it repeatedly — which is the real meaning of the word chronic in that paragraph heading.

The rest of this page is the wording each of those rests on, what you actually file and for which unit, what happens to a leak that straddles 31 December, and the places where the section genuinely does not answer the question rather than where it answers it inconveniently.

The two numbers people mix up

Both apply only to appliances with a full charge of 15 pounds or more of a regulated substance or a substitute with a global warming potential above 53, under 84.106(a), in force since 1 January 2026. Above that gate they are different numbers, measured differently, and they oblige different things.

Cumulative, and the sentence that settles it

Paragraph (j) is one sentence long: owners or operators of refrigerant-containing appliances containing 15 or more pounds of refrigerant that leak 125 percent or more of the full charge in a calendar year must submit a report containing the information required in paragraph (m)(4) to EPA by March 1 of the subsequent year.

Read what that is measuring. "Leak 125 percent of the full charge in a calendar year" is a quantity over a period. Nothing in it limits the loss to one leak, one component or one uninterrupted event, and nothing in it refers back to the leak rate definition that the repair triggers use. A calendar year is the unit, and a calendar year contains however many leaks it contains.

The reporting form is the confirmation. Paragraph (m)(4) asks for the annual percent refrigerant loss, the dates of refrigerant addition, the amounts of refrigerant added, an explanation of the cause of the losses, a description of the repair actions taken, and the date of the last successful follow-up verification test. Dates and amounts are both plural, and a form written for one continuous leak would need neither a list of repairs nor a list of additions.

It is worth seeing why this is confusing, because the confusion is real and not carelessness. The defined term leak rate at 84.102 offers two methods, and neither of them produces the 125% figure. The annualizing method takes the pounds added to bring the appliance back to full charge — "whether in one addition or in multiple additions related to same leak" — divides by the full charge, and scales that by the time since the last addition, so it is a projection from one leak event. The rolling average method sums every addition over the previous 365 days, which is cumulative but is a trailing window that pays no attention to 1 January. The 125% is a third number: the year, as the calendar draws it.

Which appliance do you report, and does a clean unit get dragged in?

The second half of the question has a cleaner answer than the first. The obligation in (j) attaches to an appliance, so you file for each appliance that crossed 125%, and a unit on the same roof that stayed under it does not appear in that filing at all. There is no site total, no fleet total and no portfolio total anywhere in the paragraph.

Inside the appliance you do report, though, it is all of the leaks. (m)(4) wants that appliance’s whole year — every addition date, every weight, what caused the losses and what was done about them — not only the event that pushed it over the line.

One detail decides this more often than people expect. Under the definition of a refrigerant-containing appliance at 84.102, a device with multiple circuits is not one appliance: each independent circuit is considered a separate appliance. The older part says the same thing in almost the same words: 82.152 reads "For a system with multiple circuits" where 84.102 reads "For such devices with multiple circuits", and both finish "each independent circuit is considered a separate appliance". So a two-circuit rooftop unit is two appliances for every purpose here — the 15-pound gate, the leak rate, and the 125% total — and one circuit can be reportable while the other, sitting a foot away in the same cabinet, is not.

What crossing 125% does not do is replace anything. The repair obligations at (c) through (f), the verification tests at (e), the leak inspections at (g) and the records at (l) all continue to apply to every covered appliance whether or not it is ever reportable, and the extension and retrofit-or-retirement notifications at (m)(1) through (m)(3) are separate filings with their own triggers.

A worked year on one rooftop unit

A packaged rooftop unit, single circuit, serving offices. Nameplate full charge 40 pounds of R-410A: over the 15-pound gate, an HFC well above a GWP of 53, and comfort cooling, so its repair trigger is 10%.

No single event lost 125% of the charge; the largest was 22 pounds, 55% of it. The year did. Fifty-two pounds against a forty-pound charge is 130%, so that unit is reportable and the report is due 1 March of the following year. Under the other reading of the question — one continuous leak that has to exceed 125% by itself — this unit would never be reportable in any year, and that is not what (j) says.

Look at what else the year contains. Each of those three additions was over the 10% comfort-cooling trigger on its own, and not marginally: annualised, the July addition is about 110% and the November one about 182%, because 16 and 22 pounds went in 133 and 110 days apart. Each one therefore started a 30-day repair clock and each one needed an initial and a follow-up verification test. An appliance does not arrive at 125% quietly.

By the third event the question has stopped being whether to file in March. 84.106(c)(1) says that an owner or operator who elects to repair but fails to bring the leak rate below the applicable rate must create and implement a retrofit or retirement plan under (h) and (i). A unit on its third leak of the year is in that conversation, and the annual report is the smaller of the two obligations.

The leak that straddles 31 December

The count in (j) is a calendar year, so it does reset. Eighteen pounds added on 20 December belongs to that year’s total; twenty more on 8 January, chasing the same leak on the same machine, belongs to the next one. On the face of the paragraph, a unit can lose a great deal across a New Year and file nothing.

Nothing else resets, and this is the part worth carrying away. The 30-day repair clock started at the December addition and runs into January exactly as it would into July. The rolling average method looks back 365 days from wherever it is standing. The annualizing method measures the days since the last addition and does not ask which year they fell in. A retrofit-or-retirement obligation already triggered is not discharged by a new calendar.

So the year boundary is real for one report and invisible to everything else, which is why it is not worth engineering around. The obligations it does not touch are the ones with a 30-day deadline and a verification test attached.

Where the section genuinely does not say

Four honest gaps. Anyone who tells you these are settled is reading something other than the text.

• ▸ There is no formula for the 125%. The two leak-rate methods subpart C defines — annualizing and rolling average, both inside the definition of leak rate at 84.102 — are neither of them a calendar-year figure, and "annual percent refrigerant loss", the phrase (m)(4)(v) asks you to report, is not a defined term anywhere in the subpart. Total pounds added to correct leaks during the calendar year, divided by the nameplate full charge, is the arithmetic the sentence and the form imply between them. Write down which arithmetic you used.
• ▸ What comes out of the total is only half stated. 84.106(b) keeps three things out of a leak rate calculation: an addition made immediately after a retrofit, an addition to a newly installed appliance, and a seasonal variance as defined at 84.102. 84.106(k) keeps purged refrigerant destroyed at a verifiable 98% efficiency or better out of annual leak rate calculations. Carrying those exclusions across to the calendar-year total is the defensible reading, but paragraph (j) does not say so in terms.
• ▸ Recovered-and-returned refrigerant is not addressed. Pull a charge to change a compressor and put the same gas back, and nothing leaked — but the annualizing method counts "pounds of refrigerant added to the appliance to return it to a full charge", which read literally would count it. Record what was recovered as well as what was added, on the same service record, and the question answers itself on paper. Any other treatment is one to put to your compliance contact in writing rather than to decide on a roof.
• ▸ The applicability exclusion is not a number. 84.106(a)(3)(ii) takes appliances used for the residential and light commercial air conditioning and heat pump subsector out of this section entirely, and the subpart defines that subsector neither by tonnage nor by Btu. If the unit in front of you is near that line, that is a question to ask rather than to answer from a blog post — including this one.

R-22, and the rule that did not go away

Part 84 is the HFC part. An appliance containing solely an ozone-depleting refrigerant is excluded from 84.106 by (a)(3)(i) and stays where it always was, under 40 CFR part 82.

The chronic-leaker provision there is 82.157(j), and it is the same shape: 125 percent or more of the full charge in a calendar year, reported by March 1 of the subsequent year. Two things differ. The gate is 50 pounds or more, not 15. And the report is described in the text as a description of the efforts made to identify leaks and repair the appliance, rather than the twelve-item list at 84.106(m)(4). The three repair rates are the same three at 82.157(c)(2), applied above the 50-pound gate.

Working the numbers out

There are two calculations here and only one of them is awkward. The repair trigger needs three numbers you have on the day: the full charge from the plate, the weight you added, and the date of the previous addition. The free EPA leak-rate calculator on this site does that arithmetic and tells you which side of 10 / 20 / 30 you landed on. No account, nothing to install.

The 125% is simpler arithmetic on harder data: every addition to one appliance across twelve months, in one place, in February, when the technician who made the March entry may not work there any more.

That is the part a refrigerant log is actually for. In the app a refrigerant charge is entered on the same service record as the maintenance note, the parts and the photos, so the date, the weight and the appliance are one record rather than three, and the annualised rate against the 10 / 20 / 30 thresholds is worked out on the phone with no signal needed. Entering that work is free on every tier. Turning the year into a PDF for an owner, an auditor or the report itself is part of Pro.

What you have to be able to produce

Paragraph (l) sets the recordkeeping, and the retention is three years, electronic or paper. For every appliance at or over 15 pounds you hold the full charge, how it was determined, any revisions to it and the installation date. For every install, service, repair or disposal you hold the identity and location of the appliance, the date, the parts and the type of work, who did it, the amount and type of refrigerant added or removed, the full charge, and the leak rate with the method used to calculate it. Leak inspections carry their own record under (l)(5).

The March report then asks that year’s version of the same thing back: annual percent loss, the dates, the amounts, the cause, the repairs, the date of the last successful follow-up verification test, whether a retrofit or retirement plan exists with its anticipated date, and a signed statement from an authorised company official.

Every line in both lists is something somebody knew on the day and nobody wrote down. That is the whole compliance problem in one sentence, and it is why the argument about whether 125% is cumulative matters less than whether the twelve months behind it are legible.

Sources

Every regulatory sentence above was checked against the eCFR text of title 40 as amended through 17 September 2026. Section numbers are given so that you can check them too.

• ▸ 40 CFR 84.106 — leak repair. (a) applicability at 15 lb and the two exclusions; (b) when a leak rate must be calculated and what is left out; (c)(2) the 10 / 20 / 30 repair triggers; (d)–(f) the 30-day and 120-day clocks, verification tests and extensions; (h)–(i) retrofit or retirement; (j) chronically leaking appliances, the 125% provision; (k) destroyed purge gas; (l) recordkeeping; (m)(4) the twelve items in the report.
• ▸ 40 CFR 84.102 — definitions for subpart C: leak rate and its two methods, plus full charge, comfort cooling, commercial refrigeration, industrial process refrigeration, seasonal variance, and the appliance definition whose final sentence makes each independent circuit a separate appliance.
• ▸ 40 CFR 82.157 — the parallel leak-repair and chronic-leaker provisions for ozone-depleting refrigerants, at a 50 lb gate; the appliance definition at 82.152 carries the same per-circuit sentence.
• ▸ This is not legal advice. It is a reading of the text with the citations attached so that every sentence can be checked. Where an enforcement question or real money rides on the answer, the pages to hand your compliance contact or your counsel are 84.106(j) and 84.106(m)(4).

Is the EPA 125% leak rate cumulative across several repaired leaks, or does it mean one continuous leak?

Cumulative. 40 CFR 84.106(j) applies to an appliance of 15 pounds or more that leaks 125 percent or more of its full charge in a calendar year, which is a quantity totalled over the year rather than a single event. Nothing in the paragraph limits it to one leak or one component, and the report it points to at 84.106(m)(4) asks for the dates and the amounts of refrigerant addition in the plural, along with the annual percent refrigerant loss. A unit topped off three times for three different leaks is measured on what all three added up to.

Do I report on all leaks, or only the appliance that went over 125%?

Only the appliance that crossed it, and for that appliance, all of its leaks. The obligation in 84.106(j) attaches to an appliance, so a report is filed for each appliance over 125% and a unit that stayed under it is not part of that filing. Within the appliance you do report, 84.106(m)(4) wants the whole year: every addition date, every amount, the cause of the losses and the repairs carried out, not just the event that took it past the line.

Is 125% a leak rate or a quantity?

A quantity, and that is why it can exceed 100%. The repair triggers at 84.106(c)(2) are leak rates — a projection of what would be lost over twelve months at the current rate of loss. The 125% is what the appliance actually lost between 1 January and 31 December, measured against its full charge. An appliance that loses and is recharged with more than its own full charge in a year has lost more than 100% of it, which is exactly the situation the paragraph is written for.

Does the 125% report replace the 30-day repair requirement?

No. They are independent. Exceeding 10, 20 or 30 percent under 84.106(c)(2) obliges you to find and repair the leaks within 30 days — 120 if an industrial process shutdown is required — with an initial and a follow-up verification test, whether or not that appliance ever reaches 125% for the year. And if repairs do not bring the leak rate below the applicable rate, 84.106(c)(1) requires a retrofit or retirement plan under (h) and (i). The annual report is an additional obligation, not a substitute for any of them.

What happens to a leak that straddles 31 December?

The reporting count in 84.106(j) is by calendar year, so refrigerant added in December counts to that year and refrigerant added in January to the next, even on the same leak and the same machine. Nothing else resets: the 30-day repair clock runs across the year end, the rolling average method looks back 365 days from wherever it stands, the annualizing method counts days since the last addition without regard to the year, and a retrofit-or-retirement obligation already triggered stays triggered.

Does the 125% apply per circuit on a two-circuit rooftop unit?

Per circuit. The definition of a refrigerant-containing appliance at 40 CFR 84.102 ends by saying that for devices with multiple circuits, each independent circuit is considered a separate appliance, and 82.152 carries the same sentence for the older part. So each circuit is measured on its own full charge for the 15-pound gate, for its leak rate and for the 125% total. One circuit can be reportable while the other in the same cabinet is not.

Is there a 125% rule for R-22 equipment?

Yes, and it is older. An appliance containing solely an ozone-depleting refrigerant is excluded from 84.106 by paragraph (a)(3)(i) and sits under 40 CFR part 82, where 82.157(j) requires owners or operators of appliances containing 50 pounds or more that leak 125 percent or more of the full charge in a calendar year to report by March 1 of the subsequent year. The gate is 50 pounds rather than 15, and the report is described as the efforts made to identify leaks and repair the appliance rather than the itemised list Part 84 asks for.

How exactly do I calculate the annual percentage?

The regulation does not give a formula for it, and this is worth being straight about: the two methods defined under leak rate at 84.102 are the annualizing method and the rolling average method, and neither produces a calendar-year figure. The arithmetic the paragraph and the reporting form imply is the total pounds added to correct leaks during the calendar year divided by the appliance full charge. Keep out what 84.106(b) keeps out of a leak rate calculation — an addition immediately after a retrofit, an addition to a newly installed appliance, a seasonal variance — and what 84.106(k) excludes for destroyed purge gas, and record which method you used.

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.