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What You Need to Know About CARB Refrigeration Regulations

Modified on

March 6, 2024

In recent years, several states, including California, Colorado, and New York, have introduced commercial refrigeration regulations to help reduce the impact of refrigerant leaks on the environment. Refrigerants like chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HFCS) can absorb infrared radiation and trap it in the atmosphere. These substances significantly contribute to global warming and can erode the ozone layer.

For instance, the global warming potential (GWP) of HFC emissions is 14,800 times higher than CO2. Even though there are significantly fewer HFC emissions compared to CO2 emissions, this incredibly high global warming potential makes it a very concerning greenhouse gas.

Given the high concern surrounding greenhouse gas from refrigeration systems, it makes sense that CARB regulations are being implemented. To better understand CARB and what this means for your business, you will need to research your state’s specific regulations. This map should help. 

What is CARB?

CARB stands for California Air Resources Board. CARB compliance regulations are in place to protect the public from exposure to air contaminants, maintain healthy air quality, and combat global warming. Even though the “C” stands for California, these standards extend to other states.

Alongside controlling air pollution, CARB also focuses on helping business owners and residents find new innovative ways to ensure they can easily meet these regulations.

What are CARB Refrigerant Regulations in 2023?

As of January 1, 2023, any refrigerant with a GWP higher than 750 cannot be used in A/C systems. This mandate will extend to ice rinks and chillers in 2024. Further restrictions on purchasing and consuming HFC refrigerants are gradually being implemented, with dates being announced as they come, allowing facilities and manufacturers to switch to lower GWP alternatives such as hydrofluoroolefins (HFOs).

CARB also outlines how facilities can control refrigerant leaks through better detection and monitoring. Facilities are categorized based on the total refrigerant charge or amount of gas used within the facility’s largest system within the Refrigerant Management Program (RMP).

  • Small: Over 50 to under 200 pounds of refrigerant
  • Medium: Over 200 and under 2,000 pounds of refrigerant
  • Large: Over 2,000 pounds of refrigerant

Any system that contains 50 pounds or less of high-GWP refrigerant falls under different regulations. 

No matter the size, all facilities must follow these best practices.

Follow the proper inspection schedule

All RMP-regulated systems must undergo a regular leak inspection. However, only certified technicians with specific training may handle refrigerants. This extra restriction was implemented to further prevent any accidental refrigerant leak. The frequency of the inspections varies for different refrigerant systems depending on their refrigerant management program category.

  • Large: Non-enclosed or seasonal systems must be inspected every 90 days. Enclosed systems must use automatic leak detection that falls under RMP specifications. Any large systems operating after January 2012 should have an automatic leak detection system installed if the equipment is housed in a fully enclosed structure.
  • Medium: Systems with automatic leak detection do not require periodic inspections. Those that do not must have one every 90 days or less.
  • Small: Must have system inspections at least once every 365 days. There are none required for automatic leak detection systems that meet RMP specifications.

Promptly repair any detected leaks

Any refrigerant leak must be repaired within 14 days of detection unless the repair is technically infeasible without a process unit shutdown. You may also delay a repair if you prove that the emissions emitted by the repair would be higher than repairing the leak within the 14-day window.

If you cannot make the 14-day deadline, you must repair the leak by the end of the next time the unit is shut down for any reason. If fixing the leak fails, the facility is responsible for creating a retrofit and retirement plan for the unit. 

Retire refrigeration assets as needed

In the event of a failed repair, a plan to retire a leaky system must be established and completed within six months. Documentation regarding this action plan must be kept at your facility. You also need to retire or retro-lift a unit if it exceeds its acceptable leak rate for two consecutive quarters. The acceptable leak rate will vary based on the type of refrigeration system and refrigerant used.

If you need to install new equipment, the new unit must have an automatic leak detection functionality. You must also register the new unit with CARB within 30 days of installation. 

Keep detailed reports and records around refrigerant tracking

All large and medium facilities must submit annual reports on their refrigeration and air conditioning systems by March 1st each year. These reports must include leak inspection and repair history and refrigerants purchased.

Small facilities aren’t required to submit annual reports. However, they still need to report on the same information. However, executive officers will occasionally request reports. If you receive a request, you must submit your report within 60 days of the request.

Alongside reporting requirements, you must also retain records of this information for five years.

What are the upcoming CARB regulations?

As mentioned, HFC restrictions will extend further in 2024. However, these are just some of the new regulations coming in the near future.


  • Refrigerants with a GWP greater than or equal to 2,200 will not be allowed in new units.
  • Chains with more than 20 locations or collectively using more than 50 pounds of refrigerant must reduce their average global warming impact to 2,500 GWP or cut their greenhouse gas emissions by 25%.
  • Chains must maintain an average GWP of 2,500 or less.


  • Chains with more than 20 locations or that collectively use more than 50 pounds of refrigerant must meet an average GWP of 1,400 or less or cut their greenhouse gas emissions by 55%


  • Chains with fewer than 20 locations or that collectively use more than 50 pounds of refrigerant must meet an average GWP of 1,400 or less or cut their greenhouse gas emissions by 55%.
  • There will be a ban on the sale of gas-powered furnaces and water-heating appliances.

What is a Refrigerant Management Program?

A refrigerant management program (RMP) is a guideline of best practices regarding handling greenhouse gas refrigerants. It highlights leak detection, inspection, repair, reporting, and reduction standards for facilities to follow. Such a program helps organizations to reduce environmental impact, ensure compliance, and potentially save costs while promoting environmental responsibility.

How Can You Ensure CARB Compliance

Ensuring CARB compliance is a top priority of facilities managers to avoid penalties, improve facility sustainability, and protect the environment. There are specific requirements that facilities must follow to ensure compliance with RMP regulations. The primary goals of the RMP are to help any companies that use industrial process refrigeration to:

1. Cut back on emissions of any refrigerants with heightened global warming potential (high-GWP).

2. Lower emissions.

3. Verify that there has been a notable reduction in GHG emissions. 

To meet these goals, facilities must have detailed and meticulous recordkeeping. As a result, many companies rely on facility management software to help them with asset management.

More Refrigerant Regulation Resources


Our ServiceChannel platform can support companies looking to ensure that refrigeration and air conditioning assets in their facility comply with CARB regulations.

We provide advanced asset management features so you can ensure that your stationary refrigeration units are always in optimal condition. Plus, ServiceChannel provides data analytics crucial for monitoring and ensuring CARB compliance.

Learn more about how our software can assist facility managers in this effort by scheduling a demo.

CARB Refrigeration Regulations FAQs

What refrigerants are being phased out?

Several refrigerants are gradually being phased out. These refrigerants include:

  • HFCs
  • HFC-blends
  • R-410A
  • R-404A
  • R-134A
  • R-407C
  • R-22

Which substances are regulated by a refrigerant compliance program?

All ozone-depleting substances (ODS) are regulated by a refrigerant compliance program. The following refrigerants are considered ODSs.

  • Chlorofluorocarbons
  • HFCs
  • Carbon tetrachloride
  • Methyl bromide
  • Halons
  • Hydrobromofluorocarbons
  • Chlorobromomethane
  • Methyl chloroform

The entire list of ODS substances extends beyond these examples. Please visit the EPA’s website for the complete list.

Is R-410A legal in California?

California banned R-410A and all other refrigerants with a GWP greater than 2,500 in October 2022. R-410A will remain available for older units needing repairs for the next few decades. However, no new units can be designed to use this refrigerant. It will be phased out when the legacy units are all done.

What refrigerant is exempt from the EPA recovery mandate?

Natural refrigerants such as carbon dioxide, nitrogen, ammonia, and water are exempt from the EPA recovery mandate. Stationary refrigeration systems that use these substances are at much less risk of CARB violations. 

Is R-32 refrigerant legal in California?

Currently, R-32 is legal in California. Its GWP is 675, which is below the current limit of 750. However, please watch for CARB updates to see if their threshold dips below 675. If that happens, R-32 will be phased out.

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