Understanding 40 CFR Part 84: Your Guide to EPA Refrigerant Compliance
- Alliance Technical Group
- Dec 16, 2025
- 2 min read
Facilities with commercial, industrial, or institutional refrigeration systems face a January 2026 compliance deadline. Under 40 CFR Part 84, the EPA has established two regulations that may apply to stationary sources: the Technology Transitions Rule (Subpart B) and new monitoring/recordkeeping/reporting requirements (Subpart C).
With proposed changes to compliance deadlines and a January 2026 deadline coming up, facility stakeholders should know how these regulatory provisions affect their facilities.
This article breaks down both regulations and gives you actionable steps to meet EPA requirements.
Common EPA Refrigerant Compliance Challenges
Contractor Management Gaps
Most facilities rely on contractors for refrigeration maintenance, creating a compliance risk. Your facility remains responsible for EPA refrigerant compliance even when contractors perform the work. Unless you have explicit agreements, verification processes, and oversight mechanisms, you may have compliance gaps.
Integrating New Chemicals into Existing Programs
Facilities with existing refrigerant management programs must expand them to include HFC substitutes that were exempt under old rules. This means identifying newly regulated refrigerants, updating inventory systems, revising recordkeeping procedures, training staff, and modifying reporting protocols.
Understanding Which Rules Apply
Both Subpart B and Subpart C can apply to the same facility with different triggering criteria. A cold storage warehouse, for example, may be subject to equipment replacement timelines under Subpart B while simultaneously facing monitoring requirements under Subpart C.
How Alliance Offers Specialized Consulting
Most air quality consultants don't actively track 40 CFR Part 84. At Alliance, we're one of the few air consulting firms that actively follow these refrigerant regulations, tracking proposed changes and monitoring compliance deadlines.
Tracking EPA Regulation Updates
The EPA's proposed revisions highlight that refrigerant regulations continue to evolve. Our value is helping you comply with current requirements while keeping you informed about what's coming next, enabling proactive rather than reactive approaches.
Ready to ensure your facility's EPA refrigerant compliance? Schedule a consultation with our air quality specialists today.
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Kristine Davies
Project Director, Air Quality
| Christoff Orr Project Manager, Air Quality |