The 2027 HFC deadlines: leak detection and reclaimed refrigerant

40 CFR § 84.108 requires 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 refrigerant containing a regulated substance — or a substitute with a global warming potential (definition) above 53 — to install and use an automatic leak-detection system (definition). The timing depends on when the appliance was installed:

• Appliance installed

  On or after 1 January 2017, before 1 January 2026

  Leak detection required

  Installed and in use by 1 January 2027

• Appliance installed

  On or after 1 January 2026

  Leak detection required

  At installation, or within 30 days of it

If the appliance is older than that window, read § 84.108 directly rather than assuming the 2027 date covers it.

What the system has to do

• Direct-detection systems must monitor refrigerant concentrations in air near the compressor, evaporator, condenser and other leak-prone areas; detect a concentration of 10 ppm of the specific refrigerant; and alert at 100 ppm (§ 84.108(f)).
• Condition-monitoring systems must alert when measurements indicate a loss of 50 pounds of refrigerant, or 10 per cent of the full charge — whichever is less (§ 84.108(g)).
• Systems must be audited and calibrated annually (§ 84.108(d)) and must monitor components inside an enclosed building or structure (§ 84.108(e)).

When an alert fires

The owner or operator must calculate the leak rate within 30 days of the alert (120 days where an industrial process shutdown is necessary) — or preemptively repair the leak and then calculate it — and, if the leak rate is above the applicable threshold, follow the full leak-repair requirements in § 84.106 (§ 84.108(h)).

Records to keep

§ 84.108(i) requires records for at least three years of: the leak-detection system installation, each annual audit and calibration, every date the system triggered an alert, and the location of the leak(s) behind each alarm.

Under 40 CFR § 84.112(f), reclaimers, distributors and wholesalers of reclaimed refrigerant (definition) containing a regulated substance — where it is sold or distributed for the servicing or repair of equipment in supermarket systems, refrigerated transport or automatic commercial ice makers — must report to EPA electronically.

• Report due

  14 February 2027

  Covers activity

  1 January – 31 December 2026

• Report due

  14 February 2028

  Covers activity

  1 January – 31 December 2027

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)).

Note who files: this is a supplier-side report, not a filing obligation on most facility owners. Facilities that buy reclaimed refrigerant should still keep purchase and service records — they are how you show what went into which appliance, and your supplier's totals are built from the quantities it sold or distributed.