EPA 608 Leak Repair Requirements: 50 lb, 15 lb & 10/20/30%

EPA 608 leak repair requirements cover appliances with a full charge of 50 pounds or more of an ozone-depleting refrigerant or a blend containing one (§82.157). Since January 1, 2026, the separate 15-pound HFC rule has covered qualifying appliances but excluded the residential and light commercial air conditioning and heat pump subsector; both rules use these triggers (§84.106):

Annual leak-rate trigger by appliance use
Appliance use	Action is required when the annual leak rate is over
Industrial process refrigeration	30%
Commercial refrigeration	20%
Comfort cooling and all other covered appliances	10%

Once a covered appliance goes over its trigger, the owner has 30 days from the triggering refrigerant addition to find and fix the leaks. That becomes 120 days if the repair requires an industrial process shutdown. The owner can also choose to retrofit or retire the appliance under a written plan. Sources: §82.157(c)–(d), §84.106(c)–(d).

Which leak repair rule applies?

The rule depends on what refrigerant is in the appliance and how much it holds when full. The 15-pound number did not replace Section 608's 50-pound threshold. It belongs to a different rule.

Which leak repair rule applies?
Refrigerant in the appliance	Full charge	Federal leak repair rule
Only an ozone-depleting refrigerant (for example, R-22, R-11, or R-123)	50 lb or more	Section 608: §82.157
Only an ozone-depleting refrigerant	Under 50 lb	Neither rule
A regulated HFC or a blend containing one (such as R-410A, R-404A, R-134a, or R-448A)	15 lb or more	HFC rule: §84.106, except residential and light commercial air conditioning and heat pumps
A substitute that contains no regulated HFC or ODS, with a global warming potential above 53	15 lb or more	HFC rule: §84.106, with the same exception
A refrigerant with a global warming potential of 53 or below that contains no regulated HFC or ODS (such as CO₂ or ammonia)	Any	Neither rule
An HFC or HFC-substitute appliance under 15 lb	Under 15 lb	Neither rule

"Neither rule" means neither §82.157 nor §84.106 applies to that appliance. It is not a blanket exemption from other refrigerant requirements: venting, recovery, and technician-certification rules have their own scope and exceptions (§82.154; §82.161).

Table sources: §82.157(a), §84.106(a), EPA ODS list, EPA blend compositions, and EPA GWP reference table.

A few terms, so the table reads cleanly:

Ozone-depleting substance (ODS): for this page, a Class I or Class II substance used as a refrigerant. Examples include CFCs and HCFCs, such as R-11 and R-22 (EPA ODS list).
HFC (hydrofluorocarbon): a refrigerant with no chlorine, so it doesn't deplete ozone. Many HFCs have a high global warming potential. The refrigerant-content test includes any HFC regulated under the American Innovation and Manufacturing (AIM) Act; the appliance must also meet the charge and use conditions above.
Global warming potential (GWP): a substance's warming effect compared with CO₂. The "above 53" test applies only to substitutes that aren't HFCs themselves. The lowest value the AIM Act assigns to a regulated HFC is 53 (EPA fact sheet, Jan. 2026, p. 1, note 4).

A blend that contains both an ODS and an HFC can meet the conditions of both rules. The HFC rule's ODS exclusion covers only appliances that contain solely an ODS (§82.157(a); §84.106(a)(3)).

For 608 exam study, EPA lists leak repair under Type II and Type III in its public test topics. That list does not establish whether a certifying organization tests the newer HFC rule, so do not treat “50 pounds for the exam, 15 pounds for the field” as an official rule. Keep the two regulations distinct and use your certifying organization's current study materials. The regulation itself says "50 or more pounds," so a 50-pound ODS appliance is covered.

What counts as full charge and appliance type?

Full charge is the amount of refrigerant the appliance needs to run normally. It is not the weight of the equipment, the amount left after a leak, or the amount you added today. EPA allows four ways to determine it:

the manufacturer's figure
a calculation from component sizes and piping
actual measurements
an established range based on the best available data about normal operating conditions, whose midpoint is used

Each independent circuit counts as its own appliance. Sources: 40 CFR 82.152, "Appliance" and "Full charge"; 40 CFR 84.102.

Classify the appliance by what it does, not by who owns it:

Comfort cooling is air conditioning for people in occupied buildings, such as chillers, commercial split systems, and packaged rooftop units. A store's rooftop AC is comfort cooling, not commercial refrigeration.
Commercial refrigeration means retail food and cold storage warehouse equipment. Supermarket racks, restaurant walk-ins, and cold storage all fit here.
Industrial process refrigeration (IPR) is complex, customized equipment tied to an industrial process. Industrial ice machines, equipment used directly in generating electricity, and ice rinks also count. An appliance that serves both industrial and other uses is IPR if at least half its operating capacity serves the industrial process.

The HFC rule also names refrigerated transport in its 10% group. Under Section 608, an appliance that isn't comfort cooling, commercial, or IPR falls under "other," also at 10%. Sources: §82.152; §84.106(c)(2).

Does the 15-pound HFC rule apply to home air conditioners?

No. Appliances in the residential and light commercial air conditioning and heat pump subsector are excluded from §84.106, whatever their charge. EPA describes this subsector as equipment that cools individual rooms, single-family homes, and small commercial buildings. Chillers and certain variable refrigerant flow (VRF) systems belong to other subsectors, so they are not excluded. The cited EPA description does not define "light commercial" by a pound cutoff, so classify by the equipment's subsector, not the building's name (EPA fact sheet, p. 1, note 3).

Transport refrigeration: On May 26, 2026, EPA proposed exempting road and intermodal container transport refrigeration units from the HFC leak repair rule. As of the rule text we checked (eCFR, current through September 24, 2026), the proposed exemption was not in the codified text (EPA regulatory actions; Federal Register, May 26, 2026).

How to calculate the annual leak rate

The leak rate is the percentage of the full charge the appliance would lose over a year if it kept leaking at its current pace. EPA allows two methods. The owner or operator must use the same method for every covered appliance at the facility, so you can't pick whichever method gives a lower number on a given day. Sources: §82.152, "Leak rate"; §84.102. The HFC rule allows a switch only after acquiring a facility whose method differs from the method at the owner's other facilities, if the affected appliances are not exceeding their triggers under either method and the change is documented (§84.106(b)(3)).

For a covered appliance, calculate the rate every time refrigerant is added. There are three exceptions: an addition made right after a retrofit, one made right after installing a new appliance, and an addition that qualifies as a seasonal variance (§82.157(b); §84.106(b)).

Annualizing method

Leak rate (%) = (pounds added ÷ full charge) ÷ (days since the last addition ÷ 365) × 100

Pounds added is the amount needed to bring the appliance back to full charge. Several additions for the same leak count together.
Days since the last addition is capped at 365. If more than a year has passed, use 365.

Worked example 1 (Section 608, comfort cooling)

Worked example 1 (Section 608, comfort cooling)
Input	Value
Appliance	R-22 comfort cooling unit
Full charge	100 lb
Refrigerant added to restore full charge	4 lb
Days since the previous addition	90

(4 ÷ 100) ÷ (90 ÷ 365) × 100 = 16.222…% ≈ 16.2%

That's over the 10% comfort cooling trigger, so the 30-day repair clock starts with this addition.

The trap here: 4 pounds is 4% of the charge, which looks harmless. But losing it in 90 days means losing about 16% over a year. The time factor is the whole point of annualizing.

Rolling average method

Leak rate (%) = (pounds added over the previous 365 days ÷ full charge) × 100

If the last successful follow-up verification test showed all identified leaks repaired less than a year ago, count only the pounds added since that test. This is not a January-to-December total, and you don't average the individual additions.

Worked example 2 (Section 608, commercial refrigeration)

Worked example 2 (Section 608, commercial refrigeration)
Input	Value
Appliance	R-22 cold storage refrigeration system
Full charge	100 lb
Additions in the past 365 days, including today's	10 lb, 6 lb, 8 lb
Successful follow-up verification in that window	None

(10 + 6 + 8) ÷ 100 × 100 = 24%

That's over the 20% commercial refrigeration trigger. Add the pounds first, then divide by the full charge. Don't multiply a rolling result by a day factor.

The first HFC calculation after January 1, 2026

The HFC rule has a transition step for each appliance's first calculation after January 1, 2026 (§84.106(b)(1)–(2)):

Annualizing: use 365 days as the time since the last addition.
Rolling average: count only pounds added since January 1, 2026.

Worked example 3 (HFC rule, comfort cooling): An R-134a chiller with an 80-lb full charge gets its first 2026 addition of 5 lb to restore full charge. Using the annualizing method with 365 days: (5 ÷ 80) ÷ (365 ÷ 365) × 100 = 6.25%. That's under the 10% trigger, so this addition doesn't start a repair clock. It still has to be recorded.

Exactly at the trigger

The rules require corrective action when the leak rate is over the trigger. A result of exactly 20.0% on a commercial system doesn't exceed 20%. When a repair is required, it must bring the rate below the trigger (§82.157(c)–(d)). Round only at the end, and never round a result down to make it pass.

What happens after an appliance goes over the trigger

The steps are nearly identical under both rules. Where they differ, the table says so.

What happens after an appliance goes over the trigger
Step	What's required	Deadline
1. Find the leaks	A certified technician does a leak inspection that locates the leaks. Under the HFC rule, the repairs themselves must also be done by a certified technician.	Within the repair window
2. Repair	Fix the leaks so the leak rate drops below the trigger.	30 days from the refrigerant addition that showed the appliance was over its trigger, or 120 days if an industrial process shutdown is required
3. Initial verification test	Test each repaired leak to show the repair holds. Do it before refrigerant is added back. If the repair required evacuating the system, test before recharging. You can repair and retest as many times as you need inside the window.	Within the same 30- or 120-day window
4. Follow-up verification test	Test again once the appliance is running normally, to show the repair held.	Within 10 days of a successful initial test; if the appliance or isolated portion was evacuated, within 10 days of reaching normal operating conditions
5. Confirm	The next leak rate calculation, at the next addition, must confirm that the rate is below the trigger.	At the next addition
6. Ongoing leak inspections	See the inspection schedule below.	Quarterly or yearly

Sources: §82.157(d)–(e); §84.106(c)–(e).

If testing at normal operating conditions would be unsafe or impossible, the follow-up test must instead be conducted before returning to those conditions, where practicable (§82.157(e)(2); §84.106(e)(2)). Section 608 also has a separate certification rule for work that could violate the refrigerant circuit; the comparison is not permission for an uncertified person to open an ODS system (§82.161(a)).

Methods that only show whether a system leaks don't count as a leak inspection by themselves. That includes standing pressure or vacuum decay tests, sight glass checks, receiver levels, and charging charts. They have to be paired with a method that finds where the leak is, such as an electronic or ultrasonic detector, bubbles, or a gas-imaging camera (§82.152, "Leak inspection").

Under Section 608, a repair is presumed successful if no refrigerant is added for 12 months after the repair, or if the required leak inspections find no leaks. Under the HFC rule, the 12-month period starts at the successful follow-up verification test: either no refrigerant is added during that period, or the required inspections and/or an automatic leak detection system required by §84.108 find no leaks during it (§82.157(d)(2); §84.106(d)(2)).

When parts are late, or the system is shut down

Extensions exist for specific situations, not for any delay. They cover three cases:

Parts: a needed part isn't available within 30 days (or 120 with a shutdown). Additional time is allowed up to 30 days after the part arrives, but no later than 180 days from when the appliance went over its trigger (270 days with an industrial process shutdown).
Other rules: other federal, state, or local rules make a timely repair impossible. The HFC rule adds Tribal rules.
Radiological contamination: the appliance is in a contaminated area, or shutting it down would cause contamination.

To use an extension, the owner must:

complete and verify repairs within the original window for any leaks the technician identified as a significant cause of the exceedance, if they don't need the extra time
document every repair effort and why the deadline can't be met
file the extension request with EPA within the original 30 days (or 120)

Sources: §82.157(f); §84.106(f).

Mothballing pauses the specified repair and verification deadlines, and the retrofit or retirement plan timelines—not the recordkeeping duties or the calendar-year reporting rule. EPA defines it as evacuating the appliance, or the isolated leaking section, to at least atmospheric pressure and temporarily shutting it down. Switching the power off is not mothballing. The clock picks up again on the day refrigerant is added back. Keep records of both dates (§82.152, "Mothball"; §82.157(d)(3), (i), (l)(8); §84.106(d)(3), (i), (l)(10)).

When repair isn't the answer: retrofit or retirement

A retrofit converts the appliance to a different refrigerant. Retirement means removing the refrigerant and disabling the refrigerant circuit so nobody can use the appliance again. For a covered appliance, the owner must write a retrofit or retirement plan within 30 days of the applicable event below:

the appliance is leaking over its trigger and the owner intends to retrofit or retire instead of repairing
the appliance is leaking over its trigger and the owner fails to act to find or repair the leaks
the appliance still leaks over its trigger after the required repairs and verification tests

The plan must include:

the appliance and its location
the current refrigerant and full charge
for a retrofit, the new refrigerant, its full charge, and an itemized conversion procedure
what happens to the recovered refrigerant and, for a retirement, to the appliance
a schedule of no more than one year

It must be signed by an authorized company official, dated, and kept at the site. All identified leaks must be repaired as part of any retrofit. The work must be finished within one year of the plan's date unless an extension applies. Sources: §82.157(h); §84.106(h).

If the owner establishes within 180 days of the plan's date that the appliance no longer exceeds its trigger, the owner can ask EPA to be released from the plan. The owner must agree in writing to repair all identified leaks within one year of the plan's date and submit the plan and supporting information required by §82.157(h)(5)(ii) or §84.106(h)(5)(ii). The extension options for the one-year schedule differ between the two rules; see the comparison table below.

How often are leak inspections required?

These recurring inspections apply after an appliance has gone over its trigger. They aren't a standing schedule for every appliance.

How often are leak inspections required?
Appliance after an exceedance	Section 608 (§82.157)	HFC rule (§84.106)
Commercial refrigeration or IPR, full charge 500 lb or more	Every 3 months, until 4 quarters in a row do not exceed the trigger	Every 3 months, counted from the successful follow-up verification test, until 4 quarters in a row do not exceed the trigger
Commercial refrigeration or IPR under 500 lb	Once per calendar year, until one year does not exceed the trigger (covers 50 to under 500 lb)	Once per year after the successful follow-up verification test, until one year does not exceed the trigger (covers 15 to under 500 lb)
Comfort cooling and other appliances	Once per calendar year, until one year does not exceed the trigger	Once per year after the successful follow-up verification test, until one year does not exceed the trigger

Sources: §82.157(g); §84.106(g). The owner must demonstrate the no-exceedance period through the required leak rate calculations.

Under these schedules, the size of a comfort cooling appliance never moves it to quarterly inspections. A covered office chiller with a 900-lb full charge is still on the annual schedule.

A certified technician does the inspection and checks all visible and accessible components. The exceptions are parts that are insulated, iced over, underground, or behind walls; parts that would require personnel to be more than two meters above a support surface; and parts that site personnel determine are unsafe to inspect. A continuously monitoring automatic leak detection (ALD) system can replace scheduled inspections for the parts it monitors only if it meets the applicable requirements in §82.157(g)(4) or §84.106(g)(4). Section 608 requires annual auditing or calibration and the specified detection performance. The HFC provision also incorporates §84.108(c)–(g) and (i), including annual auditing and calibration. Any parts it doesn't monitor still need inspections.

Mandatory ALD under the HFC rule: For covered commercial refrigeration and IPR appliances with a full charge of 1,500 lb or more of refrigerant containing a regulated HFC (or a qualifying substitute with a GWP above 53), §84.108 sets these installation deadlines:

Installed on or after January 1, 2026: at installation or within 30 days.
Installed from January 1, 2017 through December 31, 2025: by January 1, 2027.

Section 608's leak repair rule does not require ALD; it's an option there (40 CFR 84.108; EPA fact sheet, Table 2).

For an appliance subject to §84.108, an ALD alert also creates a response duty under §84.108(h): calculate the leak rate within 30 days of the alert, or 120 days where an industrial process shutdown would be necessary. The owner may repair the identified leak before adding refrigerant, but must still calculate within that alert window. If the calculated rate exceeds the trigger, the full §84.106 leak repair requirements apply. Keep the ALD installation, annual audit/calibration, alert, and leak-location records for at least three years (§84.108(i)).

What records and EPA reports are required?

The leak repair duties fall mainly on the owner or operator. Anyone who adds or removes refrigerant from a covered appliance must give the owner a service record when the job is done. That record covers the appliance, date, parts, work done, the technician's name, and the type and amount of refrigerant. Technicians who do leak inspections and verification tests must hand over those results too. Sources: §82.157(b), (l); §84.106(b), (l).

Keep records for at least three years. Keep full-charge records until three years after the appliance is retired. For the HFC rule, the full charge of every covered appliance had to be determined by January 1, 2026, or at installation for newer equipment, and the records include the installation date. Sources: §82.157(l); §84.106(l)(1).

The 125% chronic leak report

An appliance covered by the applicable leak repair rule that leaks 125% or more of its full charge in a calendar year needs a report to EPA by March 1 of the following year. This is about the refrigerant actually lost from January through December, not an annualized projection. It's separate from the 10/20/30% repair triggers. For 2026, the report is due March 1, 2027. Sources: §82.157(j); §84.106(j).

Quick math: on an HFC commercial refrigeration appliance with a 40-lb full charge, 125% is 50 lb lost in one calendar year.

Where reports go

Section 608: Send notifications to 608reports@epa.gov. Submissions containing confidential business information go by mail to the address in §82.157(m).
HFC rule: File electronically through EPA's HAWK platform. To get access, register in EPA's Central Data Exchange (CDX) with the Leak Reporter role. EPA's forms cover repair extensions, retrofit or retirement extensions, requests to be released from a plan, chronic leak reports, and purged-refrigerant notices (EPA reporting resources).

Don't send an HFC filing to the Section 608 email address.

A leak repair worksheet

Use this checklist to organize a leak event or to study the sequence. It's a checklist, not a compliance certificate, and it doesn't replace the records the rules require.

A leak repair worksheet
Field	What to record or check
W01 Appliance	Appliance or circuit ID, location, and the owner or operator
W02 Refrigerant and full charge	Refrigerant, full charge in pounds, how it was determined, and installation date for the HFC rule
W03 Rule and use	§82.157, §84.106, both, or neither; any exclusion; comfort cooling, commercial refrigeration, IPR, or other
W04 Addition history	Date and pounds of this addition, earlier additions and their dates, and any exception (retrofit, new install, seasonal variance)
W05 Calculation	The facility's method, all inputs, the unrounded result, the trigger, and whether the rate is over it
W06 Repair response	Date of the triggering addition; 30- or 120-day deadline; leak inspection and repair results; verification of significant leaks within the original window when seeking an extension; any extension request or mothball dates
W07 Verification	Initial test date and result; whether the system was evacuated; date it returned to normal operation; follow-up test date and result
W08 Continuing duties	Inspection schedule, ALD duties if they apply, and retrofit or retirement plan date and completion date if required
W09 Calendar-year check	Total lost this calendar year compared with 125% of full charge; if required, report route and March 1 due date
W10 Records kept	Service records, inspection and test results, calculations, ALD installation/audit/calibration/alert records, plans, EPA submissions and responses, and how long to keep each

If you don't know the refrigerant, full charge, or dates, you can't finish the rule or rate decision. Missing information doesn't make an appliance exempt.

Section 608 vs. the HFC rule: the differences that matter

The trigger percentages and basic repair windows match. These details don't:

Section 608 vs. the HFC rule: the differences that matter
Topic	Section 608 (§82.157)	HFC rule (§84.106)
Covers	Full charge of 50 lb or more of a Class I or Class II refrigerant, or a blend containing one	Full charge of 15 lb or more of refrigerant containing a regulated HFC, or a qualifying non-HFC substitute with GWP above 53
Left out	Appliances containing only substitute refrigerants, such as HFCs	Appliances containing only an ODS; residential and light commercial AC and heat pumps
In force	Current trigger rates since January 1, 2019; substitute-only appliances excluded April 10, 2020	January 1, 2026
Who must be certified	Leak inspection expressly requires a certified technician; §82.161 separately governs refrigerant-circuit work during repairs	Leak inspection and leak repairs expressly require a certified technician
Refrigerated transport	Counts as "other," 10%, if it holds 50 lb or more of an ODS	Named in the 10% group; a road/intermodal-container exemption is proposed, not present in the reviewed codified text
Automatic leak detection	Optional in place of inspections if §82.157(g)(4) is met	Covered commercial refrigeration/IPR of 1,500 lb or more has the installation-date deadlines above; qualifying ALD may also replace inspections
Annual inspection timing	Once per calendar year	Once per year, counted from the successful follow-up verification test
Reports and extension requests	Email to 608reports@epa.gov; confidential submissions use the prescribed mailing route	EPA's HAWK platform, signed by an authorized company official
Extra time on a retrofit or retirement	Conditional extensions for IPR and federally owned commercial/comfort-cooling equipment; 18 months total to retire when the replacement uses an exempt substitute	For IPR only (including radiological contamination)
First leak rate calculation	No special rule	First calculation after January 1, 2026 uses 365 days (annualizing) or only pounds added since that date (rolling)

Sources: §82.157; §84.106; §84.108; EPA fact sheet, Table 2.

Old numbers you'll still see

Older study guides mix rules from different years. Here's what each date changed:

Old numbers you'll still see
Date	What changed	What it means for you
Before January 1, 2019	Triggers were 35% for commercial refrigeration and IPR, and 15% for comfort cooling	Historical. For a covered appliance under the current rules, the commercial refrigeration trigger is over 20%.
January 1, 2019	Current triggers took effect: 30% IPR, 20% commercial refrigeration, 10% comfort cooling and other	These are the Section 608 numbers to learn
April 10, 2020	Appliances containing only substitute refrigerants, such as HFCs, were removed from §82.157	Section 608 leak repair covers ODS refrigerants and blends containing them at the 50-lb threshold. Other Section 608 rules, such as the venting ban, still apply to HFCs.
January 1, 2026	The separate HFC leak repair rule (§84.106) took effect at 15 lb	A new rule, not a change to Section 608's 50-lb threshold

Sources: EPA, Regulatory Updates: Section 608; §82.157(a), (c); §84.106(a).

A quick way to organize any leak repair question: identify the refrigerant and full charge, classify the use, calculate the rate, then apply the response and records. It's our study aid, not an EPA rule.

Practice: 14 leak repair scenarios

These are original, unofficial practice questions written by Castleport Test Prep. They are not EPA exam items. Each answer and explanation sits right under its question. Your score reflects these 14 questions only. It isn't an official score or a prediction of your exam result. The set combines Section 608 concepts with current HFC-rule scenarios; it is not a claim about an exam bank's HFC coverage. Stated appliance charges are full charges, and “HFC” in these scenarios means a regulated HFC or a blend containing one.

Question 1 · LR-01

HFC rule · Leak repair requirements (applicability)

It's 2026. A cold storage warehouse refrigeration unit holds 30 lb of R-407C, an HFC blend. Which federal leak repair rule applies?

Choose one answer for LR-01A. None, because it holds less than 50 lbB. §84.106, with a 20% triggerC. §82.157, with a 20% triggerD. §84.106, with a 10% trigger

Reveal answer and explanation for LR-01

Answer: B. §84.106, with a 20% trigger.

Why: Cold storage is commercial refrigeration. The appliance holds 15 lb or more of a refrigerant containing an HFC, so the HFC rule applies from January 1, 2026, at the 20% commercial trigger.

Why not the others: A applies the 50-lb line, which now governs only ozone-depleting refrigerants. C is wrong because §82.157 hasn't covered HFC-only appliances since April 10, 2020. D uses the comfort cooling rate.

Source: §84.106(a), (c)(2); §84.102, "Commercial refrigeration"; EPA, Compositions of Refrigerant Blends

Which leak repair rule applies?

What counts as full charge and appliance type?

Does the 15-pound HFC rule apply to home air conditioners?

How to calculate the annual leak rate

Annualizing method

Rolling average method

The first HFC calculation after January 1, 2026

Exactly at the trigger

What happens after an appliance goes over the trigger

When parts are late, or the system is shut down

When repair isn't the answer: retrofit or retirement

How often are leak inspections required?

What records and EPA reports are required?

The 125% chronic leak report

Where reports go

A leak repair worksheet

Section 608 vs. the HFC rule: the differences that matter

Old numbers you'll still see

Practice: 14 leak repair scenarios

Question 1 · LR-01

Question 2 · LR-02

Question 3 · LR-03

Question 4 · LR-04

Question 5 · LR-05

Question 6 · LR-06

Question 7 · LR-07

Question 8 · LR-08

Question 9 · LR-09

Question 10 · LR-10

Question 11 · LR-11

Question 12 · LR-12

Question 13 · LR-13

Question 14 · LR-14

Quick answers

Sources