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.
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.
Your duties scale with the size of your largest system.
| Category | Largest system (high-GWP charge) | Annual report? |
|---|---|---|
| Small | Over 50 lbs to under 200 lbs | Register only — no annual report |
| Medium | 200 lbs to under 2,000 lbs | Yes — annual report |
| Large | 2,000 lbs and above | Yes — annual report + additional monitoring |
Register each affected facility in CARB's Refrigerant Registration & Reporting (R3) system. There is no fee for Small facilities.
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
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 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
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).
| Federal (AIM Act §84.106) | California (CARB RMP) | |
|---|---|---|
| Charge threshold | ≥ 15 lbs HFC (GWP > 53) | > 50 lbs high-GWP (GWP ≥ 150), largest system |
| Repair window | 30 days after exceeding the leak-rate trigger | 14 days after detecting a leak |
| Recordkeeping | 3 years | 5 years |
| Reporting to the agency | Records kept on site (no routine submission) | Annual report to CARB via R3 (Medium/Large) |
| Registration | None | Register 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.
from $19/mo. Every appliance, calculation, repair, and deadline logged and retained — audit binder on a button.
Start free trial