Reporting Resources for the Emissions Reduction & Reclamation Rule

On this page:  

• Instructions for Reporting
• Summary of ER&R Reporting Requirements
• ER&R Reporting Forms

Instructions for Reporting

EPA’s Emissions Reduction and Reclamation (ER&R) final rule (40 CFR Part 84, Subpart C) under subsection (h) of the American Innovation in Manufacturing (AIM) Act establishes requirements to minimize the release of certain hydrofluorocarbons (HFCs) and their substitutes from equipment, and to maximize the amount of HFCs reclaimed. The rule includes reporting requirements for the following:

• Owners and operators of certain refrigerant-containing appliances,
• Refrigerant reclaimers, distributors, and wholesalers,
• Entities involved with performing first fill or servicing of fire suppression equipment, or recycling fire suppressants. 

EPA provides reporting forms to assist entities in fulfilling these requirements. These Microsoft Excel-based reporting forms must be submitted to EPA through EPA’s electronic reporting platform, HAWK. To submit a report through HAWK, you will first need to register.

Registration

Registration for ER&R reporting must be done through EPA’s online reporting platform. Reporters must register via the Central Data Exchange (CDX), to access the HAWK reporting platform. For instructions on how to register for a CDX account and complete ER&R reporting, please refer to the instructions in the slides from EPA’s webinar on ER&R reporting. More detailed user guides with additional information will be available soon.

Report Submission Calendar

The Figure below provides an overview of the reporting deadlines for the ER&R rule. 

Summary of ER&R Reporting Requirements

Leak Repair

Beginning January 1, 2026, owners or operators of refrigerant-containing appliances with a charge size of 15 pounds or more of refrigerant that contains an HFC or certain HFC substitutes (those with a global warming potential above 53) are required to submit reports when certain scenarios occur during the leak repair process. In these scenarios, owners or operators of these appliances must electronically submit a report to the Agency per the requirements at 40 CFR 84.106(m). A user guide will be available soon with additional information on these types of reports, including instructions for filling out the required forms and the data required.

EPA requires reports to be submitted during the leak repair process if any of the following scenarios occur:

• Requests to extend the time to complete appliance repair.
• Requests to extend the time to complete a retrofit or retirement plan.
• Requests seeking relief from the obligation to retrofit or retire an appliance.
• Chronic leak reports for appliances that leak more than 125% in a calendar year. 
• Notification regarding purged refrigerants.

Reclamation

The reporting requirements in 40 CFR 84.112(f) apply to reclaimers, distributors, and wholesalers of reclaimed refrigerants that (1) contain an HFC; and (2) are sold or distributed for the purpose of servicing and/or repair of refrigerant-containing equipment in the three subsectors: supermarket systems, refrigerated transport, and automatic commercial ice makers. 

Reclaimers, distributors, and wholesalers who meet those conditions must submit two annual reports containing the information specified in 40 CFR 84.112(f)(1) and 40 CFR 84.112(f)(2), by the following deadlines: 

• February 14, 2027, covering activity from January 1 through December 31, 2026.

• February 14, 2028, covering activity from January 1 through December 31, 2027. 

Fire Suppression

Certain entities are required to maintain and provide data on HFCs in the fire suppression sector per the requirements at 40 CFR 84.110(g)(1). These include entities (e.g., equipment manufacturers, distributors/installers, recyclers/reclaimers) that initially charge equipment, service (e.g., recharge) equipment, and/or recycling of HFCs.

Beginning in 2027, covered entities must submit data electronically each year by February 14 on the prior year’s activity (i.e., from January 1 through December 31 of the prior year).

ER&R Reporting Forms

The current version of each ER&R reporting form is available for download in the table below. Visit the Resources for Managing HFC Use and Reuse  page for more information to help companies and other stakeholders understand and comply with the ER&R reporting requirements.