California’s Refrigerant Management Program, run by the California Air Resources Board (CARB), applies to any facility with a stationary refrigeration system holding more than 50 pounds of high global warming potential (high-GWP) refrigerant. If you’re covered, you must register the facility through CARB’s online portal, inspect systems for leaks on a schedule tied to system size, repair any leak within 14 days, keep service records on site, and, for medium and large facilities, file an annual report and pay an implementation fee. Missing any of these obligations exposes you to civil penalties of up to $10,000 per day, with each day counted as a separate violation.
Which Facilities the Program Covers
The trigger is a single system holding more than 50 pounds of high-GWP refrigerant.1California Air Resources Board. Refrigerant Management Program Small residential units sit below that line, so the program mostly reaches supermarkets, cold storage warehouses, food processing plants, and similar commercial and industrial operations.
Covered facilities fall into three tiers, and the tier is set by the biggest single system on site, not by total refrigerant across the property:2Cornell Law Institute. California Code of Regulations Title 17 95383 – Registration Requirements for Facilities with Stationary Refrigeration Systems
- Large: at least one system with a full charge of 2,000 pounds or more.
- Medium: at least one system with a full charge of 200 pounds or more but less than 2,000 pounds.
- Small: systems with a full charge greater than 50 pounds but less than 200 pounds.
Your tier decides how often you inspect, whether you file annual reports, and how much you pay. Small facilities have far lighter obligations than large ones.
Leak Inspection Schedule by Tier
Inspection frequency scales with system size. Large facilities inspect indoor systems monthly. Outdoor components, or components not inside an enclosed building, must be inspected at least every three months using a calibrated leak detection device, a bubble test, or oil residue observation. Medium facilities inspect every three months using the same detection methods. Small facilities inspect once a year.3California Air Resources Board. Final Regulation Order – Management of High Global Warming Potential Refrigerants for Stationary Sources
Large and medium facilities can skip the manual inspection cycle by installing an automatic leak detection (ALD) system that meets CARB’s specifications and monitors the equipment continuously. Note that federal law now independently requires ALD on commercial and industrial process refrigeration appliances with a full charge of 1,500 pounds or more, so for very large systems ALD isn’t really optional.4U.S. Environmental Protection Agency. Automatic Leak Detection Requirements for Appliances Containing Refrigerants
Leak Repair: The 14-Day Rule
Once a leak is detected, you have 14 days to complete the repair, and a certified technician must do the work.5Cornell Law Institute. California Code of Regulations Title 17 95386 – Leak Repair Requirements for Facilities with Stationary Refrigeration Systems The technician needs a current, valid EPA certificate, and the contractor must hold a California C-38 (refrigeration) or C-20 (HVAC) license depending on the system type.6California Air Resources Board. RMP – Service Technicians and Contractors
When You Can Take Longer
The regulation allows an extension to 45 days in three situations:
- No certified technician is available within the 14-day period.
- Replacement parts are unavailable, documented by a written statement from the manufacturer or distributor.
- The repair requires shutting down an industrial process that would halt manufacturing.
A longer 120-day extension is available for industrial process refrigeration, but only when the facility is subject to California’s mandatory greenhouse gas reporting requirements, the system is used for industrial process refrigeration, the repair would force a production shutdown, and written records document all of these conditions.5Cornell Law Institute. California Code of Regulations Title 17 95386 – Leak Repair Requirements for Facilities with Stationary Refrigeration Systems Every extension has to be documented as it happens; retroactive paperwork will not survive an audit.
Two Verification Tests
The physical repair is not the end of the job. A verification test must be run immediately after the repair is complete, and a second test must be run after the system is back at normal operating conditions. If the system was evacuated during the repair, the follow-up test waits until it’s fully recharged and running normally. Skipping either test leaves you as exposed as if the repair itself were never performed.
Registration and Annual Reporting Through R3
Every covered facility, including small ones, must register through CARB’s Refrigerant Registration and Reporting System, known as R3.7California Air Resources Board. RMP – Registering and Reporting Registration asks for the following on each system:
- The type of high-GWP refrigerant used (such as R-22 or R-404A) and the system’s full charge.
- Facility location, contact person, phone number, and email address.
- A system identification number assigned by the facility owner.
- The company’s federal tax ID (EIN).
Have your service records, refrigerant purchase receipts, and equipment specs ready before you start. R3 asks for the total weight of each refrigerant type purchased during the previous calendar year, along with amounts removed, added, stored, and shipped to a reclaimer.8California Air Resources Board. Refrigerant Management Program R3 Worksheets – Documents to Assist Online Registration and Reporting The portal is accessible on CARB’s site.9California Air Resources Board. Refrigerant Registration and Reporting System (R3)
Annual reporting applies only to large and medium facilities. Small facilities register and inspect but do not file annual reports and do not pay implementation fees. This distinction trips people up. A small facility still has to register and complete its annual inspection; the reporting and fee obligations simply stop there.
The annual report covers the previous calendar year and must include every service event, leak inspection, and leak repair, along with refrigerant purchases and usage, and the name and EPA certification number of each technician who worked on the systems. You certify the data through the R3 dashboard, and the system generates the fee invoice.
Annual Fees
Fees are set by the largest system at the facility:10New York Codes, Rules and Regulations. California Code of Regulations Title 17 95384 – Implementation Fees for Facilities with Stationary Refrigeration Systems
- Large facilities (≥2,000 lbs): $370 per year.
- Medium facilities (200–2,000 lbs): $170 per year.
- Small facilities (<200 lbs): no fee.
These amounts have held steady at $370 and $170 since the program started. As of early 2026, CARB no longer accepts paper checks. All payments run through the R3 portal.
Records You Must Keep On Site
Service records, leak inspection logs, repair documentation, and refrigerant purchase invoices all have to be kept at the facility and available whenever CARB shows up.11Cornell Law Institute. California Code of Regulations Title 17 95389 – Recordkeeping Requirements for Facilities with Stationary Refrigeration Systems That includes anything supporting an extended repair deadline. If you claimed you couldn’t get parts or a technician, the written proof needs to be on file. Incomplete records are treated as their own violation, separate from whatever operational issue they’re supposed to document.
Penalties
Each day a required inspection, repair, registration, report, or fee payment sits past its deadline counts as a separate violation, and the same applies to inaccurate information in any of these submissions.12Cornell Law Institute. California Code of Regulations Title 17 95395 – Enforcement The math is unforgiving. A leak left unrepaired for 30 days past the deadline is 30 violations, not one.
Under California’s Health and Safety Code, CARB can pursue civil penalties of up to $10,000 per day per violation.13California Air Resources Board. Settlement Agreement – Consolidated Container Company LP Criminal penalties are also on the books: a misdemeanor conviction carries a fine of up to $5,000 per day or up to six months in county jail, with each day of violation a separate offense.14California Legislative Information. California Health and Safety Code 42400 CARB usually pursues civil settlement agreements for RMP violations, but the criminal option is available for egregious cases.
How Federal Rules Fit Alongside the RMP
The RMP layers on top of federal law, it does not replace it. EPA’s Section 608 regulations separately require technician certification, leak repair, and recordkeeping for anyone handling refrigerants in stationary equipment, and California specifically requires RMP technicians to hold a current EPA certificate.
Federal leak-rate thresholds also apply in parallel. California requires repair of any detected leak regardless of the annual rate, so in practice the state rule is stricter, but a system that crosses the federal annual leak-rate threshold picks up additional federal obligations on top of the RMP.15U.S. Environmental Protection Agency. Stationary Refrigeration Leak Repair Requirements
One scope note worth flagging: the RMP covers all ozone-depleting refrigerants regardless of GWP, in addition to high-GWP HFCs. Some substances fall under the RMP that operators wouldn’t expect if they were reading federal rules alone.
Separately, the federal AIM Act’s Technology Transition Rule imposes GWP limits on new refrigeration equipment manufactured or installed on or after January 1, 2026. Existing equipment installed before that date can keep operating and be serviced through its useful life, so the 2026 rule doesn’t force anyone out of their current systems. It does mean new installations after that date have to meet the applicable GWP cap, which for large remote condensing units and cold storage warehouses with charges of 200 pounds or more is 150, and for smaller units and the high-temperature side of cascade systems is 300.
If You’re Buying or Selling a Facility
Compliance obligations follow the equipment. When a facility with registered refrigeration systems changes hands, the new owner inherits everything, including any unresolved violations. CARB’s guidance is explicit: do not self-correct registration information if you take over a building and find errors in the existing R3 records. Contact RMP staff directly so the corrections can be made without creating a compliance problem for the new owner.16California Air Resources Board. Refrigerant Management Program Updates to the RMP Registration and Reporting Tool
If you’re on the buying side, request the seller’s RMP registration details, service records, and most recent annual report during due diligence. Walking into a facility with a lapsed inspection or an unrepaired leak means daily penalties can start accruing against you from day one.