HomeGuides › California CARB R3 reporting
California, on top of federal

California CARB refrigerant reporting (R3)

If you service refrigeration in California, the federal AIM Act isn't the whole story. California's Refrigerant Management Program (RMP) — administered by the California Air Resources Board (CARB), with registration and reporting through the R3 system — is a separate, stricter regime that stacks on top of the federal rules. Here's who's covered, what you owe, and how it differs from federal, with CARB citations.

The key point: it's both, not either. A California facility can be subject to the federal AIM Act (15-lb HFC threshold) and CARB's RMP (50-lb high-GWP threshold) at the same time. CARB compliance does not replace federal compliance — you do both.

Who's covered

Any facility with a stationary refrigeration system containing over 50 pounds of high-GWP refrigerant is subject to the RMP. 17 CCR §95380 et seq. "High-GWP" here means a refrigerant with a global warming potential of 150 or more — a broader net than a first glance suggests, since it covers the common HFC blends. The threshold is measured by the largest single system at the facility, not the cumulative total across all systems.

Facility categories

Your duties scale with the size of your largest system.

CategoryLargest system (high-GWP charge)Annual report?
SmallOver 50 lbs to under 200 lbsRegister only — no annual report
Medium200 lbs to under 2,000 lbsYes — annual report
Large2,000 lbs and aboveYes — annual report + additional monitoring

Your duties under RMP

Register in R3

Register each affected facility in CARB's Refrigerant Registration & Reporting (R3) system. There is no fee for Small facilities.

Inspect for leaks

RMP systems must be regularly inspected for leaks; the frequency varies by system size (for example, large non-enclosed systems every 90 days or less). Enclosed systems must use an automatic leak detection system that meets spec. §95385

Repair within 14 days

Fix any detected leak within 14 days of detection (special provisions apply if it genuinely can't be). This is a detect-and-repair duty, not only a federal-style annualized-rate trigger.

Keep 5 years of records

Keep service records on site for at least 5 years per unit — leak inspections, installation/calibration/audits of leak-detection systems, refrigerant purchases, and shipments. §95397

The R3 annual report

Medium and Large facilities must file an annual report to CARB through R3 by March 1, covering the prior calendar year. The report generally includes refrigeration-system information, service and leak-repair records (dates, cause of each leak, repair descriptions, verification-test results, and the technician's name and EPA certification number), and refrigerant purchase/use information (amounts purchased, charged, recovered, held in inventory, and shipped for reclamation or destruction).

You file it yourself. The R3 report is submitted by the facility (or its agent) directly in CARB's R3 tool. No software submits to CARB on your behalf — good records are what make that filing painless.

CARB RMP vs the federal AIM Act

 Federal (AIM Act §84.106)California (CARB RMP)
Charge threshold≥ 15 lbs HFC (GWP > 53)> 50 lbs high-GWP (GWP ≥ 150), largest system
Repair window30 days after exceeding the leak-rate trigger14 days after detecting a leak
Recordkeeping3 years5 years
Reporting to the agencyRecords kept on site (no routine submission)Annual report to CARB via R3 (Medium/Large)
RegistrationNoneRegister each facility in R3

They overlap but don't line up — a California shop typically satisfies the federal duties and the CARB duties, tracking to the stricter of the two on any given point.

What to do now (California shops)

  1. Check the 50-lb line. Identify any facility whose largest system holds over 50 lbs of high-GWP refrigerant — that facility is in RMP scope.
  2. Register in R3 and note your facility category (Small / Medium / Large).
  3. Run your inspection schedule per §95385, and repair detected leaks within 14 days.
  4. Keep 5 years of records — and keep them in a form you can hand to CARB and the EPA.
  5. Calendar March 1 if you're Medium or Large, and file the R3 annual report for the prior year.
  6. Don't forget federal. The AIM Act 15-lb rule still applies — see the 15-lb rule guide and how to calculate the leak rate.
LeakClock keeps the records both regimes want. Every service event, leak-rate calculation, repair, and test is logged per appliance, retained, and printable as an audit binder — the same records that make your CARB R3 filing and a federal EPA audit straightforward. Start a 14-day free trial →

Related guides

See all compliance guides → · Free leak-rate calculator →

Records that satisfy CARB and the EPA

from $19/mo. Every appliance, calculation, repair, and deadline logged and retained — audit binder on a button.

Start free trial