📒 Refrigerant Log: What EPA 608 Says to Record on Every Service Call

A refrigerant log is the running record of refrigerant going into and coming out of a piece of equipment: which unit, what day, who did the work, and how much. On the units the federal leak-repair rules cover, the regulation spells out exactly what each entry has to hold, and it is shorter than most people expect. Eight items per service call, kept for three years.

This page lists those eight items with the section each one comes from, which units they apply to in 2026, how the leak rate on each entry is worked out, and what happens when it comes out over the line. Every regulatory statement links to the eCFR text as amended through 8 October 2026, so you can check it yourself.

Which Units Need a Refrigerant Log Under EPA 608?

The answer depends on the refrigerant and the full charge.

• ▸ HFCs such as R-410A, R-404A and R-134a: 40 CFR 84.106 covers an appliance with a full charge of 15 pounds or more of a regulated substance, or of a substitute with a global warming potential above 53. It has applied since 1 January 2026.
• ▸ R-22 and other ozone-depleting refrigerants: 40 CFR 82.157 covers appliances with a full charge of 50 pounds or more. The HFC rule leaves these out on purpose: an appliance containing solely an ozone-depleting refrigerant is excluded by 84.106(a)(3)(i).
• ▸ Residential and light-commercial air conditioning and heat pumps: 84.106(a)(3)(ii) takes equipment used in that subsector out of the HFC leak-repair section. The section does not define the subsector by tonnage, so a unit near the line is a question for your compliance contact.

Two details change the answer more often than people expect. The gate is read per circuit: the appliance definition in 40 CFR 84.102 says that for devices with multiple circuits, each independent circuit is a separate appliance. And under the gate you still cannot vent. The prohibition in 40 CFR 82.154 applies to anyone maintaining, servicing, repairing or disposing of an appliance, with no charge floor. For typical charges by equipment type, see does the EPA leak-repair rule apply to my unit.

What Does EPA 608 Say to Record on Every Service Call?

For a covered HFC appliance, 84.106(l)(2) lists what the owner or operator keeps every time the appliance is installed, serviced, repaired or disposed of. 82.157(l)(2) is the same list for R-22 equipment at 50 pounds and up.

The hand-off is a requirement of its own. Under 84.106(b), anyone adding or removing refrigerant must give the owner or operator that documentation when the job is done, and 84.106(l)(4) says it covers items 1 to 6 when somebody other than the owner did the work. The full charge and the leak rate are the owner’s to keep, but the tech standing at the unit with the scale and the nameplate is usually the best person to write them down.

What Else Does the Owner Have to Keep, and for How Long?

Every record in 84.106(l) is kept for at least three years, on paper or electronically. Three kinds of record sit beside the per-visit entries:

• ▸ The full charge of each appliance, how it was determined, any revisions and their dates, and the installation date. These are kept until three years after the appliance is retired, under (l)(1).
• ▸ Leak inspections: the date, the method, where each leak was found, and a certification that all visible and accessible parts were inspected, under (l)(5).
• ▸ Verification tests: the dates, the repaired leaks tested, the type of test and the results, for both the initial and the follow-up test, under (l)(7).

How Is the Leak Rate Worked Out?

The owner or operator calculates a leak rate every time refrigerant is added, except right after a retrofit, on a newly installed appliance, or for a seasonal variance, under 84.106(b). 84.102 defines the leak rate as the share of the full charge that would be lost over 12 months if the current rate of loss continued, and gives two methods. A facility uses the same method for all its covered appliances.

• ▸ Annualizing method: the pounds added to bring the unit back to full charge (in one addition or several for the same leak), divided by the full charge. Divide that by the days since the last addition (or 365, whichever is shorter) over 365. Multiply by 100.
• ▸ Rolling average method: everything added over the previous 365 days, or since the last successful follow-up verification test if that is shorter, divided by the full charge, times 100.

A worked example. A rooftop unit with a 40 lb full charge of R-410A takes 3 lb, 60 days after its last addition. 3 ÷ 40 is 0.075. 60 ÷ 365 is 0.164. 0.075 ÷ 0.164 is about 0.456, or 45.6%. A rooftop unit cooling an office is comfort cooling, so that is over the 10% trigger, and the repair clock starts on the day of that addition.

If this is the first leak-rate calculation on a unit since 1 January 2026, 84.106(b)(1) says to use 365 days as the days since the last addition. To check a number without the arithmetic, the free EPA leak-rate calculator takes the full charge, the pounds added and the days, and returns the rate against 10, 20 and 30 percent.

What Are the EPA Leak Repair Requirements in 2026?

Once a covered appliance’s leak rate is over its trigger, the clock starts at the addition that showed it.

• ▸ Find and fix the leaks within 30 days of that addition, or 120 days if an industrial process shutdown is needed, under 84.106(d). A certified technician does the leak inspection and the repairs.
• ▸ Prove the repair held with an initial and a follow-up verification test, under 84.106(e).
• ▸ If the repairs do not bring the rate under the trigger, the owner must create and carry out a retrofit or retirement plan, under 84.106(c)(1).
• ▸ A unit that leaks 125% or more of its full charge in a calendar year is reported to EPA by 1 March of the next year, under 84.106(j). That total adds up every leak in the year, and the 125% post walks through it.

One pending change. On 26 May 2026 EPA proposed taking road and intermodal container transport refrigeration units out of the HFC leak-repair requirements. It is a proposal, not a final rule, and it does not touch building HVAC or commercial refrigeration. For where the three rates came from, see EPA leak rate thresholds explained.

Is a Refrigerant Tracking Spreadsheet Enough?

The format is your choice: 84.106(l) accepts paper or electronic records, and a spreadsheet with a column for each of the eight items is a valid refrigerant log. Where spreadsheets usually fall down is not the columns. It is the timing.

• ▸ The entry gets typed at the office days later, from a ticket that never had the full charge on it.
• ▸ The date of the last addition is in another row, another file or another company’s records, so nobody works out the leak rate on the day.
• ▸ The 125% total and the verification tests need every entry for one appliance in one place, and a sheet sorted by date does not give you that.

Whatever you use, whether paper, a spreadsheet or software, judge it on three questions. Does it hold all eight items? Does it work out the leak rate while you are still at the unit? Can you pull one appliance’s whole year out of it in February?

How Do You Keep a Refrigerant Log on Your Phone?

In Equipment Tracker Pro the refrigerant log is part of the service log, not a separate book. Open a unit, start a service log, and open the REFRIGERANT LOG section. It is collapsed and marked optional, so a filter change does not ask about refrigerant.

• ▸ SOURCE CYLINDER (optional): pick the cylinder from that location’s inventory. The refrigerant type fills in from the cylinder’s name, and when you save, the amount you added comes off that cylinder’s weight.
• ▸ REFRIGERANT TYPE, SYSTEM CHARGE (LBS), and AMOUNT ADDED in pounds and ounces.
• ▸ DATE OF LAST CHARGE: with it, the screen shows an annual leak rate. Without it, the screen shows the plain percentage and tells you to add the last charge date to annualise it.
• ▸ REFRIGERANT NOTES for the recovery cylinder number, the amount recovered and anything else worth keeping.

As you type, the app checks the rate against the trigger for that kind of equipment: 20% for refrigeration equipment such as walk-ins, coolers, freezers and ice machines, 30% for industrial process refrigeration, and 10% for everything else. It only flags a unit at or over the charge gate for its refrigerant, which is 50 lb for R-22 and other ozone-depleting refrigerants and 15 lb for everything else. When both are true, the section shows ⚠ EPA FLAG and a warning that the leak must be repaired within 30 days. On air conditioners and heat pumps it adds a note that residential and light-commercial systems may be exempt. The verdict shows when the app is set to US units, because these are US rules.

The rest of the eight items are on the same screen: DATE, SERVICE TYPE, TECHNICIAN, VENDOR, DESCRIPTION, PARTS USED, and before and after photos. The refrigerant type and charge can also live on the unit itself, in its REFRIGERANT and REFRIGERANT CHARGE fields, so the next tech reads them off the record instead of the nameplate. For a closer tour of the screen, see how the refrigerant log records leak rates.

Is the Refrigerant Log Free?

Yes. Logging refrigerant, the leak-rate calculation and the EPA flag are free on every tier, and they work with no signal, because the calculation happens on the phone. Pro adds the paperwork:

• ▸ On the web dashboard, Reports has a Refrigerant tab with an EPA Section 608 Leak Log & Compliance Ledger: every service log with refrigerant on it, showing the date, equipment, location, refrigerant, system charge, amount added, leak rate, and a Compliant or Exceeded status.
• ▸ On the phone, the Refrigerant Inventory report lists your equipment grouped by refrigerant type and marks phased-out refrigerants such as R-22.

See pricing for the current plans, and all features for the rest of the app.

What the App Does Not Do

The leak-rate rules above decide what you owe. The app keeps the record they are argued from.

• ▸ It does not file anything with EPA. The 125% report and any extension request are yours to submit.
• ▸ It works out the rate from the amount added on this visit and the last-charge date you enter. If one leak took several additions, or the last charge was more than a year ago, check the figure against the method your facility uses.
• ▸ It has no separate fields for leak inspections or verification tests. Record each one as its own service log, with the method, where the leaks were and the result in the description.
• ▸ It records what you type. The leak rate is only as good as the full charge and the last-charge date behind it.

Sources

Every regulatory statement above was checked against the eCFR text of title 40, up to date as of 8 October 2026.

• ▸ 40 CFR 84.106: HFC leak repair. (a) applicability and exclusions; (b) documentation and when to calculate; (c) the 10 / 20 / 30 triggers; (d) and (e) repair and verification; (j) the 125% report; (l) recordkeeping.
• ▸ 40 CFR 84.102: definitions, including leak rate and its two methods, and the per-circuit sentence.
• ▸ 40 CFR 82.157: leak repair and recordkeeping for ozone-depleting refrigerants at 50 lb.
• ▸ 40 CFR 82.154: the venting prohibition.
• ▸ Federal Register 2026-10388: the May 2026 proposal on transport refrigeration units.
• ▸ This is not legal advice. It is a reading of the text with the citations attached. Where real money or an enforcement question depends on the answer, take the section numbers to your compliance contact.

What is a refrigerant log?

A dated record of refrigerant added to or removed from each piece of equipment. For appliances covered by the federal leak-repair rules, 40 CFR 84.106(l)(2) lists what each entry holds: the appliance and its location, the date, the parts serviced, the type of work, who did it, the refrigerant type and amount, the full charge, and the leak rate with the method used.

How long do I have to keep refrigerant records?

At least three years, on paper or electronically, under 40 CFR 84.106(l) for HFC equipment and 82.157(l) for R-22 equipment. The full-charge record for each appliance is kept until three years after the appliance is retired.

Do I need a refrigerant log on a residential split system?

Not under the federal leak-repair rules in most cases. The HFC rule starts at 15 lb of full charge and excludes the residential and light-commercial air conditioning and heat pump subsector, and R-22 equipment is covered only at 50 lb and up. The venting prohibition in 40 CFR 82.154 still applies to every appliance, and a dated record is still the only way to see a small system losing gas.

What are the EPA leak repair requirements in 2026?

For HFC appliances with 15 lb or more of full charge, a leak rate over 10% for comfort cooling, 20% for commercial refrigeration or 30% for industrial process refrigeration must be found and repaired within 30 days of the addition (120 days if an industrial process shutdown is needed), with an initial and a follow-up verification test. These requirements in 40 CFR 84.106 apply from 1 January 2026.

Does the technician have to give the customer the record?

Yes. Under 40 CFR 84.106(b), anyone adding or removing refrigerant must give the owner or operator documentation when the job is finished. When someone other than the owner did the work, 84.106(l)(4) says it covers the appliance and its location, the date, the parts, the type of work, who did it, and the refrigerant type and amount.

Is the refrigerant log in Equipment Tracker Pro free?

Yes. Logging refrigerant, the leak-rate calculation and the EPA flag are free on every tier and work offline. The web dashboard, including the EPA Section 608 Leak Log & Compliance Ledger, and the PDF reports are 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.