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California Air Resource Board (CARB) Regulations for Food Retailers

What you need to know about the requirements as a food retailer 

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 is still in the rulemaking process. 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.

The information below is to provide awareness of these regulations, and we recommend 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.

Learn More on CARB's Website

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.
Read the Final Regulation Order

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 also need to register in the R3 system.

Access the R3 System Website

SB 1206: GWP Limits on Bulk HFCs

California SB 1206 outlines 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 HFC gases, therefore, those products may be impacted. 

For a full schedule of the GWP limits, deadlines, and products impacted with their associated GWPs, download our CA SB 1206 Fact Sheet.


A "retail food facility" covers any facility that sells food and uses at least one retail food refrigeration unit/system with more than 50 pounds of refrigerant with a GWP of 150 or greater. Supermarkets, grocery stores, and many larger convenience stores all fit into this category. Read more information on CARB's website.

As of January 1, 2022, refrigerants with a GWP of 150 or greater are prohibited in new refrigeration equipment containing more than 50 pounds of refrigerant. See the full list of prohibited refrigerants outlined in the legislation and more details on CARB's website.

Companies with existing systems that have more than 50 pounds of refrigerant with a GWP of 150 or greater will need to meet company-wide HFC-reductions by the end of 2026. There are two paths to compliance:

  1. Reduce the company weighted-average GWP
  2. Reduce the greenhouse gas emission potential (GHGp)

CARB has a fact sheet that outlines how to calculate the weighted-average GWP and GHGp. 

You can see the full list of prohibited refrigerants and their effective prohibition dates on the CARB website.

The R4 Program, or the Refrigerant Recovery, Reclaim, and Reuse Program, outlines the requirements for refrigerant reclaimers and AC equipment manufacturers in California. It mandates that AC and VRF manufacturers need to use certified reclaimed refrigerants.  

A-Gas offers R4 Certified, which is certified reclaimed R410A, to meet the needs of equipment manufacturers that must comply with these California requirements