The regulatory landscape for facility management just shifted significantly. As of January 1, 2026, the EPA’s AIM Act requirements have officially expanded, bringing a much larger range of equipment under federal scrutiny.

The Shift from 50lbs to 15lbs

For years, the “magic number” for refrigerant compliance was 50 pounds. If your equipment held less than that, you were largely off the hook for intensive leak rate calculations. That has changed. According to a recent report by Facilities Dive:

“A federal rule… lowers the threshold for appliances that must comply with greenhouse gas restrictions from 50 pounds of hydrofluorocarbons (HFC) refrigerant charge to 15 pounds.”

Why This Matters for Facility Managers

This isn’t just a minor tweak; it’s a massive expansion of scope. Smaller HVAC units and reach-in freezers that were previously ignored now require:

• Mandatory Leak Rate Calculations: Every time you add refrigerant, you must calculate the leak rate.
• 30-Day Repair Windows: If a leak is detected above the threshold, you have only 30 days to fix it.
• Retrofit or Replace: If repairs fail, you have one year to overhaul or retire the system.

The “Patchwork” Problem

One of the biggest hurdles cited in the article is the lack of integrated data. Many facilities use one system for maintenance (CMMS) and another for environmental compliance. Steven Blumenfeld of Trakref notes that this creates a “patchwork of disconnected systems,” making it incredibly difficult to maintain the auditable records the EPA requires.

Our Take: Start with an Asset Audit

If you haven’t already, your first step should be “boots on the ground.” You cannot comply with what you haven’t tracked.

1. Tag Every Asset: Ensure every unit with over 15lbs of charge is tagged and logged.
2. Centralize Your Data: Move away from spreadsheets. Manual tracking will lead to missed deadlines and potential EPA fines.
3. Train Your Techs: Ensure your service contractors know that the 15lb rule is now active and that they must provide leak rate data for every service call.

Is your facility prepared for an EPA audit under these new rules? We recommend reviewing your inventory immediately to identify high-risk units.