California Air Resource Board (CARB) Regulations for Food Retailers
In the ever-changing regulatory environment, A-Gas aims to help California food retailers understand and plan for regulations that impact them.
California's Global Warming Solutions Act lays out a multi-year plan to reduce greenhouse gas emissions in the state, which includes the California Cooling Act (SB 1013). Among other requirements, the regulations prohibit specific refrigerants, require annual reporting into the Refrigerant Registration and Reporting System (R3), and outline two paths for compliance where companies must meet GWP limits on a food retailer's refrigerant usage or reduce their greenhouse gas emissions potential (GHGp) below 2019 levels.
Adding to the complexity, in 2022, California also passed State Bill 1206 (SB 1206), which went into effect on January 1, 2025, and Assembly Bill 663 (AB 663), which went into effect on October 1, 2025. SB 1206 prohibits the sale and distribution of bulk HFCs or HFC blends that exceed set GWP limits. However, reclaimed refrigerants are exempt from this requirement. AB 663 clarifies some grey areas in SB 1206, specifying the criteria that must be met for a refrigerant to qualify as a certified reclaimed refrigerant. You can learn more in this article.
The information below is intended to raise awareness of these regulations, and we recommend that you work with your internal regulatory teams to ensure you have the right plan for your organization.
Existing Food Retail Facility Requirements
Existing food retailers need to meet company-wide weighted-GWP average limits or reduce their greenhouse gas emission potential (GHGp). The company's size will determine those limits, reductions, and deadlines, the first of which is set for December 31, 2026.
New Food Retail Facility Requirements
New food retail facilities with more than 50 pounds of refrigerant will be required to only contain refrigerants with a GWP of 150 or less. They also must avoid the prohibited refrigerants outlined in the legislation.
In addition to new construction, these facilities also include:
An existing facility not previously used for retail food refrigeration, cold storage, or commercial refrigeration.
An existing facility that has undergone a significant replacement of its evaporators and compressor racks and condensers.
Annual Reporting & Registration
To ensure food retailers are meeting these requirements, they are required to submit annual reporting to the Refrigerant Registration and Reporting System (R3).
Reports should include the company-wide weighted-average GWP and GHGp by March 1 every year.
Food retail facilities with more than 50 pounds of refrigerant with a GWP of 150 or less must also register in the R3 system.
SB 1206 & AB 663: GWP Limits on Bulk HFCs
California SB 1206 and AB 663 outline a reduction of virgin HFCs and hydrocarbon blends by 2035. Specifically, the law limits the sale, distribution, or entrance into California commerce of bulk virgin HFCs or HFC blends based on the product’s GWP. Reclaimed products are not impacted.
Some HFO blends contain HFCs; therefore, those products may be affected.
For a full schedule of the GWP limits, deadlines, and products impacted with their associated GWPs, download our Be Reclaim Ready™ guide.
