California’s refrigerant phase-out rules aim to cut hydrofluorocarbon (HFC) emissions 40 percent below 2013 levels by 2030, a target set by Senate Bill 1383.1California Air Resources Board. California Significant New Alternatives Policy (SNAP) The California Air Resources Board (CARB) gets there through three tools: Global Warming Potential (GWP) caps on new equipment, a phased ban on bulk HFC sales, and mandatory leak management for stationary refrigeration and air conditioning systems. Several deadlines land in 2026, including a new GWP limit for variable refrigerant flow systems and a company-wide emissions target for large retail food chains.
What GWP Means for the Rules
Global Warming Potential measures how much heat a greenhouse gas traps compared to carbon dioxide. A refrigerant with a GWP of 1,500 is 1,500 times more potent than CO₂ pound for pound. Older commercial refrigerants like R-404A sit above 3,900. CARB defines “low GWP” as below 150 and “ultra-low GWP” as below 10.2California Air Resources Board. FRIP Funding Guidelines C&I Refrigeration Those thresholds are the numbers everything else in the program hangs on.
GWP Caps on New Equipment
Commercial Refrigeration
New refrigeration equipment with a charge greater than 50 pounds installed at commercial facilities has been capped at a GWP of 150 since January 1, 2022.1California Air Resources Board. California Significant New Alternatives Policy (SNAP) Supermarkets, convenience stores, and similar retail operations fall under this cap. Most new installations use CO₂ transcritical systems or low-GWP HFO blends.
Cold storage warehouses split into two categories. New equipment installed in an existing cold storage facility has been limited to a GWP of 1,430 since January 1, 2023. Cold storage facilities built after 2022 must meet the stricter 150 cap. Ice rink facilities, new and existing, have been under GWP limits since January 1, 2024.
Air Conditioning, Heat Pumps, and VRF Systems
New residential and commercial air conditioning equipment, including chillers and heat pumps, must use refrigerants with a GWP below 750. That cap took effect January 1, 2025 for most equipment types. Variable Refrigerant Flow systems got an extra year: the 750 GWP cap applies to new VRF installations starting January 1, 2026.3California Air Resources Board. Updated Informative Digest
A federal sell-through window let residential and light commercial AC units manufactured before January 1, 2025 be installed through January 1, 2026, even above the 750 GWP threshold.4California Public Utilities Commission. CPUC Rulemaking 19-01-011 – Prohibition on High GWP Refrigerants in Appliances Incentivized by Building Decarbonization Programs That window has closed. New installations must now comply regardless of when the unit was manufactured.
Bulk HFC Sales Ban Under SB 1206
Senate Bill 1206 restricts the supply side by banning the sale of newly produced bulk HFCs on a phased schedule:5California Legislative Information. Bill Text – SB-1206 Hydrofluorocarbon Gases: Sale or Distribution
- January 1, 2025: newly produced bulk HFCs with a GWP above 2,200 banned (covers R-404A and R-507A).
- January 1, 2030: ban extends to HFCs above 1,500 GWP (covers R-410A, the dominant residential AC refrigerant).
- January 1, 2033: ban extends to HFCs above 750 GWP (covers R-134a and mid-range blends like R-448A and R-449A).
Reclaimed HFCs are exempt from these prohibitions.5California Legislative Information. Bill Text – SB-1206 Hydrofluorocarbon Gases: Sale or Distribution You can still buy reclaimed refrigerant to service existing equipment. As the 2030 and 2033 deadlines approach, though, even reclaimed supply will tighten and prices will climb. If you run equipment on R-410A, the 2030 deadline is the one to plan around.
Leak Inspections and Repairs Under the RMP
The Refrigerant Management Program (RMP) governs ongoing maintenance for any facility with a refrigeration system containing more than 50 pounds of high-GWP refrigerant.6California Air Resources Board. Refrigerant Management Program The core duties are routine leak inspections, prompt repairs, and complete service records. A 10 percent annual leak rate is the threshold that separates a well-maintained system from one that triggers escalating compliance obligations.7California Air Resources Board. Final Regulation Order
How Often You Must Inspect
Inspection frequency depends on the refrigerant charge:8California Air Resources Board. Leak Inspection – Save Money Through Early Detection
- 50 to 199 pounds: annual leak inspections.
- 200 pounds or more: quarterly leak inspections, unless the system uses an approved automatic leak detection system.
- 2,000 pounds or more (components inside a building): continuous automatic leak detection monitoring, with annual calibration.
Repair Deadlines
When a leak is found, you have 14 days to complete the repair using an EPA-certified technician.9California Air Resources Board. Refrigerant Management: Are You Leaking Money? The clock starts at detection, and initial plus follow-up verification tests must confirm the fix. Three situations extend the window:
- 45 days when a certified technician is not available, necessary parts are on backorder with vendor documentation, or the repair requires shutting down an industrial process.
- 120 days when the facility is subject to mandatory greenhouse gas reporting, the system is industrial process refrigeration, and the repair requires an industrial process shutdown.
- Indefinite if the refrigerant is evacuated and the system is mothballed.
If a leak cannot be repaired within the applicable deadline, the owner must prepare a retrofit or retirement plan. That plan must schedule all work to be completed within six months of the date the leak was first detected.10Legal Information Institute. California Code of Regulations Title 17, 95387 – Requirements to Prepare Retrofit or Retirement Plan Six months goes fast once you factor in equipment lead times and contractor availability.
Company-Wide Targets for Retail Food
Large grocery chains and supermarket operators face targets that apply across all California locations, not just individual systems. Companies owning or operating 20 or more retail food facilities in California, along with national supermarket chains operating in the state, must reach one of two benchmarks by December 31, 2026: a company-wide weighted-average GWP below 2,500, or a 25 percent reduction in greenhouse gas emission potential below 2019 levels.11California Air Resources Board. Retail Food Facility
By January 1, 2030, all retail food companies in California, regardless of size, must reach a company-wide weighted-average GWP below 1,400 or a 55 percent reduction in emission potential below 2019 levels.11California Air Resources Board. Retail Food Facility For operators with fewer than 20 facilities, 2030 is the first mandatory benchmark. Meeting these targets generally means converting existing cases and walk-ins to CO₂ or low-GWP HFO systems.
Annual Reports and Recordkeeping
Facilities with a refrigeration system containing 200 pounds or more of high-GWP refrigerant in the largest system must submit an annual report to CARB through the Refrigerant Registration and Reporting (R3) tool by March 1, covering the prior calendar year.12California Air Resources Board. Refrigerant Management Program (RMP) Frequently Asked Questions Smaller facilities in the 50 to 199 pound range still must conduct inspections and keep records, though they do not file annual reports.
The report is detailed. It must include service and leak repair records with dates, the cause of each leak, descriptions of repairs, verification test results, and the name and EPA certification number of the technician who performed the work. You also report the total weight of each type of refrigerant purchased, charged into systems, recovered, stored in inventory, and shipped for reclamation or destruction during the calendar year. Equipment-specific data (system full charge, refrigerant type, manufacturer and model, temperature classification, and location on a floor plan) is required for each registered system.13California Air Resources Board. RMP: Registering and Reporting
Records and supporting documentation must be kept for at least five years from the date the report is submitted.14Legal Information Institute. California Code of Regulations Title 17, 93405 – Document Retention and Record Keep invoices for refrigerant purchases, vendor backorder documentation used to justify extended repair timelines, and automatic leak detection calibration records. If you cannot produce documentation, CARB treats it as a violation even when the underlying practice was compliant.
Penalties
CARB enforces the RMP and SNAP regulations under California Health and Safety Code section 38580. Each day a violation continues counts as a separate offense.15Legal Information Institute. California Code of Regulations Title 17, 95368 – Enforcement A missed repair deadline or a late annual report can generate rapidly accumulating liability. CARB can also seek injunctive relief under Health and Safety Code section 41513, which lets a court order you to stop operating non-compliant equipment.
Federal violations of the Clean Air Act, which includes the AIM Act provisions, carry civil penalties of up to $472,901 per day under the most recent inflation adjustment.16eCFR. Statutory Civil Monetary Penalties, as Adjusted for Inflation, and Tables Penalties at that scale are typically reserved for major violations, but a single enforcement action can be financially devastating for a mid-size operation.
How the Federal Rules Fit In
The federal American Innovation and Manufacturing (AIM) Act runs a separate nationwide HFC phasedown. From 2024 through 2028, the federal HFC consumption cap sits at 60 percent of historical baseline levels, stepping down to 15 percent by 2036. The AIM Act does not preempt California’s stricter rules. Both apply simultaneously.17US EPA. Frequent Questions on the Phasedown of Hydrofluorocarbons
California’s rules are stricter in most categories, so complying with CARB usually means you satisfy the federal standards. The federal Technology Transitions Rule imposes its own GWP limits that took effect January 1, 2025 and January 1, 2026 across various equipment sectors.18US EPA. Technology Transitions HFC Restrictions by Sector If you operate in multiple states, check both the federal and California limits for each equipment type. The stricter of the two applies.