The 2027 dates that change the file
Two dates in 2027 matter for US equipment owners, and both sit inside the AIM Act's Emissions Reduction and Reclamation rule at 40 CFR part 84, subpart C. The EU record duty is not tied to 2027 — Regulation (EU) 2024/573 has applied since 11 March 2024 and already requires an operating record per system — but the same discipline decides whether either file survives an inspection.
1 January 2027 — Automatic leak detection installed and in use (US)
Under 40 CFR § 84.108, owners and operators of refrigerant-containing appliances used for industrial process refrigeration or commercial refrigeration with a full charge of 1,500 pounds or more of a regulated substance — or a substitute with a global warming potential above 53 — must have an automatic leak-detection system installed and in use by 1 January 2027 for appliances installed on or after 1 January 2017 and before 1 January 2026. Appliances installed on or after 1 January 2026 need one at installation, or within 30 days of it.
14 February 2027 — First reclaimed-HFC report due (US)
Under 40 CFR § 84.112(f), reclaimers, distributors and wholesalers of reclaimed refrigerant report their 2026 activity to the EPA by 14 February 2027. The filing is supplier-side — but it is built from the quantities that passed through the supply chain, which is why the facility record still matters.
The leak-repair rules came into force earlier, on 1 January 2026, for appliances with a charge of 15 pounds or more of an HFC or a substitute with a global warming potential above 53. And the 2027 dates are not the whole file: the Clean Air Act refrigerant-management rules at 40 CFR part 82, subpart F, run alongside the AIM Act rules, with their own servicing records and their own retention period.
Per-system charge and tCO₂e records
Every F-gas record is per system, never a fleet total. The threshold that decides your leak-check interval, your leak-detection obligation and your reporting exposure is the charge in that system, converted to tonnes of CO₂ equivalent. For each system, keep the identifier and location, refrigerant type, charge in kilograms, the GWP used and the basis it came from, the computed tCO₂e, the installation year, and every change to the charge with its date.
The conversion is tCO₂e = charge (kg) × GWP ÷ 1,000. The trap is the GWP basis: AR4 and AR5 values differ by around 8–10% for common HFCs — R134a is 1,430 on AR4 but 1,300 on AR5; R407C is 1,774 on AR4 and 1,624 on AR5. A file that mixes the two inflates or deflates tCO₂e silently, and a regulator who recomputes on a different basis will notice. Use the values published in your jurisdiction's current rules, state the basis on every report, and record it once in the asset register so the next person does not have to guess.
EU operators should also see the leak-check interval guide for how the tCO₂e bands map to the Article 5 schedule and when the hermetically sealed exemption applies.
Leak-check records
For each check, record the system, the date, the method used, the result, the technician or company that performed it — and, in the EU, its certificate number. Add the next due date that follows from the interval, so the schedule is visible from the record itself rather than living in someone's calendar.
In the EU, Article 5 of Regulation (EU) 2024/573 sets the minimum intervals by charge: every 12 months for 5 to under 50 tCO₂e (every 24 months with a leak-detection system), every 6 months for 50 to under 500 tCO₂e (12 with detection), and every 3 months at 500 tCO₂e or more (6 with detection). A leak-detection system is mandatory at 500 tCO₂e or more under Article 6, and the detection system is itself checked at least every 12 months. The intervals are floors: a system with a history of leaks can reasonably be checked more often.
The US rules follow appliance categories and charge thresholds rather than the EU tCO₂e ladder, so do not copy the EU intervals into a US log. The AIM Act leak-repair and leak-detection requirements sit at 40 CFR part 84, subpart C; the older Clean Air Act refrigerant-management recordkeeping sits at 40 CFR § 82.166. For appliances normally containing 50 pounds or more of refrigerant, § 82.166(k) requires servicing records with the date and type of service and the quantity of refrigerant added, and § 82.166(m) requires those records to be kept for a minimum of three years.
Repair, recovery and re-check records
A leak is not closed by the repair — it is closed by the repair record and the re-check. Keep, for every leak: what leaked, when it was found, the calculated leak rate and the full charge the calculation used, what was repaired and by whom, the date, the follow-up check and its result, and, where applicable, the extension request if the repair took longer than the rules allow.
Recovery gets its own line in the file: the quantity recovered in kilograms, the date, and where it went — recycled, reclaimed or destroyed, with the facility name and certificate details where the gas was reclaimed. For US appliances where more than 30 days are needed to complete a repair, the rules require a report to the EPA with the facility identification, the leak rate, the method used to determine it and the plan to complete the work (40 CFR § 82.166(n)); keep the dated copy of that submission with the repair record.
EU Regulation (EU) 2024/573, Article 7, lists what the operator's record has to contain. In summary:
- The quantity and type of gas in the equipment.
- Quantities added during installation, maintenance or because of a leak, each with its date.
- Quantities recovered, with the date and where the gas went.
- For added gas, whether it was recycled or reclaimed, the name and address of the facility, and its certificate number where applicable.
- The undertaking, and where relevant the person, that did the installation, servicing, maintenance, repair, leak check or decommissioning — with certificate numbers.
- The date and result of every leak check and every repair.
- If the equipment was decommissioned: the measures taken to recover and dispose of the gas.
Repairs must be checked afterwards, and the follow-up check is its own entry with its own date and result — not a note appended to the repair invoice. The record is the chain: leak found, rate calculated, repair made, repair verified, gas recovered and accounted for.
The 14 February 2027 reclaimed-HFC report
Under 40 CFR § 84.112(f), reclaimers, distributors and wholesalers of reclaimed refrigerant must report to the EPA electronically where the reclaimed refrigerant is sold or distributed for the servicing or repair of equipment in supermarket systems, refrigerated transport or automatic commercial ice makers. The first report is due 14 February 2027 and covers activity from 1 January to 31 December 2026; the next is due 14 February 2028 for 2027 activity.
Each report states the company and responsible contact, the quantity of reclaimed refrigerant by name and mass, and which of the three subsectors the refrigerant was sold or distributed for (§ 84.112(f)(1)). Separately, from 1 January 2029, servicing and repair of equipment in those three subsectors must use reclaimed refrigerant that meets the rule's standard (§ 84.112(e)).
How long to keep it
- EU. Operators must keep the installation and servicing record for at least five years under Regulation (EU) 2024/573, Article 7, and make it available to the competent authority on request. The undertaking that did the work is expected to keep copies too.
- US AIM Act leak-detection records. At least three years under 40 CFR § 84.108(i): the leak-detection system installation, each annual audit and calibration, every date the system triggered an alert, and the location of the leak behind each alarm.
- US refrigerant-management records. A minimum of three years under 40 CFR § 82.166(m) for the servicing and leak-repair records required by that section.
- Contracts and insurers. Frequently longer than any regulation. Where two requirements collide, keep to the longer one — and stop deletion entirely on a legal hold.
Five years is a floor, not a target. The point of the file is to answer a question years after the engineer who did the work has moved on, so keep it somewhere the next person can find, export and read without a vendor portal login.
The record checklist
Build the file around these ten items:
- A system inventory with the identifier and location, refrigerant type, charge in kilograms, the GWP basis used, the computed tCO₂e and the installation year.
- Threshold flags per system: which units cross the US 1,500 lb leak-detection line, and which cross the EU 500 tCO₂e leak-detection and quarterly-check line.
- A leak-check schedule per system with the next due date, and whether a leak-detection system changes the interval.
- Leak-check entries with the date, method, result, and the technician or company (and, in the EU, the certificate number).
- Repair records: the leak-rate calculation with the full charge used, what was repaired, by whom, the date, and the follow-up check result.
- Recovery records: quantity recovered and its destination (recycled, reclaimed or destroyed).
- Added-refrigerant records: quantity, type, origin (virgin, reclaimed or recycled) and certificate details.
- Leak-detection-system records: the installation record, each annual audit and calibration, every alert date, and the location of the leak behind each alarm.
- Reclaimed-refrigerant purchase and service records, reconciled with your supplier ahead of their 14 February report.
- A retention schedule mapped to each rule — and a legal-hold stop for anything under request.
How Cryovo fits
Cryovo's environmental record covers the per-system side: refrigerant charge, the GWP basis stated on the report, the computed tCO₂e, the leak-check interval per system and flags for units that need a permanent leak-detection system. Alongside it, the audit-trail report keeps the temperature record for the rooms those systems serve — a refrigerant leak often shows up as an excursion before anyone finds the leak, and the log is the evidence trail from symptom to repair.
Cryovo does not replace the certified leak check, the leak-detection system itself, or any statutory filing. Those stay with your certified contractor and your regulator. What the record can do is keep the per-system numbers and the temperature evidence in one place, with the basis stated. F-gas records are included on the Facility plan and above — see pricing.
General information, not legal or compliance advice for your operation; cite the published rule for your jurisdiction and equipment. Sources reviewed 4 November 2026: 40 CFR § 84.108, § 84.112, § 84.106, 40 CFR § 82.166 and Regulation (EU) 2024/573. This page is a summary of the published rules, not legal advice.