Washington State HFC Rules Still Apply Despite EPA R-410A Extension

HFC Rule 

Washington’s HFC rule addresses both new and existing equipment. For new equipment, it restricts the use of certain refrigerants based on the application and, in many cases, the refrigerant’s GWP. For example, beginning Jan. 1, 2026, Washington prohibited refrigerants with a GWP greater than 750 — including R-410A — in newly installed residential and nonresidential air conditioning equipment. Kimmel advised buyers to confirm with vendors that new equipment complies with the rule and obtain written verification whenever possible. 

For existing air conditioning and refrigeration equipment using high-GWP refrigerants, the rule establishes a refrigerant management program (RMP) aimed at reducing refrigerant leaks over the life of the equipment.  

“The goal of the RMP is to reduce refrigerant leakage in currently operating systems throughout their lifespan,” said Kimmel. “The program is not about making anyone replace non-leaking systems.” 

The RMP includes requirements for equipment registration, fees, leak inspections and repairs, recordkeeping, annual reporting, and technician service practices. The technician requirements apply to servicing equipment of any size, including systems containing less than 50 pounds of refrigerant.  

Kimmel advised facilities to verify that contractors are familiar with and comply with the rule. She also noted that Washington law prohibits the intentional release of refrigerants during servicing, repair, or disposal and requires refrigerant recovery in accordance with EPA Section 608 requirements. 

Facilities are required to participate in the RMP if they operate equipment containing 50 pounds or more of refrigerant in a single independent circuit, and that refrigerant has a GWP of 150 or greater. Facilities with equipment below those thresholds are exempt from the program. 

Kimmel noted that facilities are classified according to their largest piece of equipment, not the combined refrigerant charge of multiple systems. Equipment is grouped into three categories: 

• Large systems: 1,500 pounds or more of refrigerant, requiring monthly leak inspections. 

• Medium systems: 200 to 1,499 pounds, requiring quarterly inspections. 

• Small systems: 50 to 199 pounds, requiring annual inspections beginning in 2028. 

Regardless of equipment size, Kimmel stressed one requirement that applies across the board. “All leaks must be repaired within 14 days of discovery, and you must keep all records related to discovery and repair for five years,” she said. 

Leak Detection And Repair 

Prompt leak detection and repair are central to the RMP, which requires automatic leak detection (ALD) systems on certain large refrigeration systems. When properly installed and maintained, a compliant ALD system can take the place of routine scheduled leak inspections for that equipment. 

“ALDs, however, will not replace required leak inspections that have to be done to identify specific leak locations, nor will it replace the required leak inspections once a leak repair is complete,” said Kimmel. “So essentially, it’s only replacing those regularly scheduled inspections, not your verification test, follow-up verification tests — those still need to be done around the repair of leaks.” 

While leaks must generally be repaired within 14 days of discovery, the rule provides extensions in limited circumstances. For example, the deadline can be extended to 45 days if qualified technicians or replacement parts are unavailable, and in limited cases involving industrial process shutdowns, facilities may have up to 120 days to complete repairs. 

Once the repair has been completed, a verification test and full system leak inspection must be conducted to verify the leak has been fixed. If two repair attempts fail within the allowed timeframe, the owner must develop a retrofit or retirement plan for the equipment. Kimmel encouraged facilities to contact the state if they anticipate difficulty meeting the repair deadlines. 

The RMP also sets annual leak rate thresholds based on equipment type. For most air conditioning systems, leaking more than 8% of the refrigerant charge in a year triggers additional reporting and compliance requirements. Facilities must calculate leak rates using a 12-month rolling average and maintain accurate records of refrigerant added to and removed from each system. Leak rates exceeding the threshold must be reported to the Washington Department of Ecology within 30 days, along with follow-up documentation after repairs are completed.  

Kimmel noted that exceeding a leak threshold does not automatically mean a facility is out of compliance.  

“However, if you do not submit your leak reports in a timely manner, you do run the risk of being out of compliance.” 

No Rule Changes 

During the Q&A session, attendees asked how EPA’s revised Technology Transitions rule affects Washington state’s HFC rule, which requires most new residential HVAC systems to use lower-GWP refrigerants instead of R-410A. EPA’s revised rule allows contractors to continue installing eligible pre-2025 R-410A equipment until existing inventory is exhausted. 

According to Leonard Machut, fluorinated gas section manager at the Washington State Department of Ecology, the state’s requirements remain in effect.  

“Washington law, in this case, will supersede the recent federal actions to extend that. Also, just to clarify, this is for the installation of new R-410A systems. For everyone who has existing R-410A systems, you can continue to use and operate that equipment, as long as it’s meeting all the other requirements in the law,” Machut said. 

Another attendee asked whether the Department of Ecology planned to revise its rules to match EPA’s recent changes allowing installation of certain equipment manufactured or imported before Jan. 1, 2025, and Machut said the agency has no plans to do so.  

“The short answer is no,” he said. “We are not currently planning on making any changes related to the Technology Transitions rule that was recently passed by the EPA.” 

As implementation of the RMP continues, state officials repeatedly encouraged facility owners, operators, contractors, and service providers to contact the agency with questions before compliance issues arise. 

“We want to be a resource,” said Kimmel. “We’re here to help.”