January 1, 2026: When Refrigerant Leaks can Trigger Mandatory System Retirements
There's been significant confusion in the market about AIM Act’s Emissions Reduction & Reclamation (ER&R) program requirements. Many operators we speak with believe they can defer thinking about Automatic Leak Detection (ALD) for their existing facilities until January 1, 2027. This is a critical misunderstanding.
While the specific ALD mandate for existing systems is indeed in 2027, enforcement for a series of profoundly impactful “retrofit or retire” requirements begins much sooner: January 1, 2026. These rules create a direct financial risk, as they can trigger mandatory, multi-million-dollar refrigeration system replacements.
The bottom line is this: starting in 2026, if your systems leak persistently, you will be forced to either retrofit them with a new, low-GWP gas or retire them entirely. And as we’ll see, a retrofit isn’t a realistic option. The best way — and really, the only way — to avoid this disruptive and costly mandate is by implementing "whole-system" ALD now.
What Triggers a Mandatory Retrofit or Retirement?
The numbers don't lie. Retail grocers are operating under unprecedented pressure, with inflation continuing to erode profit margins across the board. Traditional refrigeration operations and maintenance approaches that worked in previous budget cycles simply won't cut it anymore. The status quo of reactive maintenance, manual inspections, and energy-inefficient operations has become a luxury most operators can no longer afford.
Starting January 1, 2026, the EPA’s HFC management rules establish a new process for addressing refrigerant leaks in appliances with a full charge of 15 or more pounds of an HFC refrigerant.
The operator must calculate the appliance’s leak rate every time refrigerant is added. If that calculation shows the leak rate exceeds the legal threshold — for example, 20% for commercial refrigeration — a strict countdown clock for action begins.
The process involves two key steps:
Mandatory Repair: Once an appliance is found to be leaking above the threshold, the owner has 30 days to repair the leak(s). The success of the repair must be confirmed with both an initial and a follow-up verification test.
Mandatory Retrofit or Retirement Plan: The requirement to create a formal "retrofit or retirement plan" is only triggered if the initial 30-day repair effort fails to bring the appliance's leak rate back below the threshold. At that point, the owner has 30 days to create a plan and must complete the full appliance retrofit or retirement within one year.
Bottom Line: From the moment a leak is discovered on an appliance, an operator could be legally required to create a full retirement plan in as little as 30 days if the initial repair attempt fails. Once that requirement is triggered, the retirement plan must be fully implemented within the following one year. This means a single unsuccessful repair can start a roughly 13-month, non-negotiable countdown to a mandatory system replacement.
Don’t let your refrigeration systems end up as scrap metal before their time!
Debunking the Myth: Retrofits Aren't a Realistic Option
Many operators who are familiar with California's regulations might ask, "Can't I just do a simple R-448A/R-449A retrofit to achieve compliance?"
Source: Oak Ridge National Laboratory
The answer is an unequivocal no. While the AIM Act does not explicitly mandate what refrigerant a retrofitted appliance must use, its structure makes the choice clear. The stringent leak management and repair rules only apply to appliances using a refrigerant with a GWP greater than 53. Therefore, the only practical way to retrofit an appliance and avoid these ongoing requirements is to use a refrigerant with a GWP of 53 or less. Refrigerants like R-448A have a GWP well over 1,300.
A true gas changeout to a sub-53 GWP refrigerant is not a simple "drop-in" procedure. It’s a complex, invasive, and expensive process that involves a full system shutdown, pumping out the old HFC gas, removing all the old oil, replacing seals and gaskets, adding a new type of oil compatible with the new gas, charging the system with the new gas, and then carefully recommissioning and tuning it over time to ensure stability.
So, what sub-53 GWP refrigerants are even available? The list is short and consists primarily of natural refrigerants like CO₂ (R-744) and propane (R-290). These are not HFC substitutes; they are fundamentally different substances that require entirely different system architectures. They operate at vastly different pressures and have unique safety considerations (e.g., flammability for propane, high pressure for CO₂).
It is simply not technically or financially feasible to retrofit a legacy HFC system to run safely and efficiently on a natural refrigerant. Therefore, if this requirement is triggered, the AIM Act will effectively force you to replace the appliance entirely.
The Reality of “Retiring Appliance”
When the AIM Act says you must "retire an appliance," it means a full rip-and-replace project. This is a massive undertaking for any grocery retailer (and a capital planning disaster).
Consider the implications:
Massive Capital Cost: A full system replacement can cost millions of dollars per site. This is an unbudgeted, reactive expense that diverts capital from strategic priorities like store remodels or technology upgrades.
Significant Business Interruption: These projects require extensive store downtime, leading to lost sales and customer disruption.
Project Management Capacity Strain: Managing a single replacement is a major capital project. Now imagine this trigger being hit across multiple sites in your portfolio simultaneously. The internal project management burden becomes immense.
Delayed Priorities: The capital and attention required for these forced replacements will inevitably divert resources from other strategic priorities, such as store remodels or technology upgrades.
This isn't a distant threat. For an appliance that is found to be leaking more than 20% when refrigerant is added on or after January 1, 2026, the 30-day countdown for mandatory repairs begins immediately. The time to plan is now.
How to Avoid Mandatory System Retirements
The strategy is simple: Do not hit the 20% leak rate threshold.
The only way to ensure this is to catch leaks early and repair them promptly. This is precisely where relying on periodic manual leak inspections fails. For the largest systems (500+ lbs), these follow-up inspections are required quarterly. For the many systems with 15 to 499 lbs of refrigerant, the requirement is only once per year, leaving a vast window for major leaks to occur undetected. A major leak can occur and vent a significant portion of a system's charge long before a technician ever shows up. Furthermore, many leading retailers have found that the quality of manual inspections can vary widely, and consistent, airtight documentation—which is essential for proving compliance—is a constant challenge.
The most effective way to catch leaks early is to implement "whole-system" ALD. This technology provides the 24/7 monitoring needed to identify leaks when they are small and manageable. Our customers have noted that the cost of a few extra service calls to investigate potential leaks (Axiom systems had a 9% false-positive leak alert rate in 2024) is trivial compared to the catastrophic costs and compliance penalties of a missed major leak, especially a leak that contributes to a mandatory system retirement.t scales linearly with site count and offers no compliance or operational advantages.
The Bottom Line: Act Now to Avoid Being Forced to Act Later
Starting on January 1, 2026, the AIM Act will force you to "rip and replace" refrigeration systems that leak persistently. This regulation transforms chronic leaks from an operational headache into a major financial liability.
You have a brief window to get ahead of this. By taking proactive steps in 2025, you can prevent this trigger from ever being pulled. The single most effective step you can take is to implement "whole-system" ALD across your facilities now. It’s the best insurance policy against multi-million-dollar mandatory system replacements you can’t afford to ignore.
And as a bonus, there are a bunch of other benefits to implementing whole-system ALD, including predictive maintenance insights, significant energy savings, and a compelling ROI that can turn a compliance requirement into a competitive advantage.
To see how much various AIM Act compliance options, including “whole-system” ALD, cost for a portfolio like yours, check out our analysis here: Let's Talk About Cost: 2026 AIM Act Compliance Options.
Ready to evaluate solutions? Learn more about the important questions you should ask your ALD vendor.