Meraki Group LLC (Board decision, February 20, 2026)
In re Meraki Group LLC (EAB CAA Appeal No. 26-01C): late HFC-import reporting settlement approved
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This is citable Board precedent from 2026, and it may have been appealed since. Ezel checks how it stands today and answers your situation, with citations.
Plain-English summary
Meraki Group LLC imported bulk HFC blends, including R-410A and R-407C, through eight shipments between November 2022 and October 2025. EPA alleged that Meraki failed to submit required advance notification reports on time for those shipments, including one report submitted after importation. Meraki accepted a $9,000 civil penalty, certified that it had completed and submitted all required reports, and waived its right to contest the alleged violations or appeal the Final Order. The EAB ratified the settlement and ordered compliance with its terms.
Decision snapshot
- Cited authorities: American Innovation and Manufacturing Act; Clean Air Act § 113; 40 C.F.R. parts 13, 19, 22, 84, and 98; 42 U.S.C. §§ 7413 and 7675
- Outcome: The Expedited Settlement Agreement was ratified, and Meraki was ordered to pay a $9,000 civil penalty.
- Key point: Importers of regulated HFCs must submit advance notification reports within the deadlines applicable to the shipment’s transport mode.
Full text (EPA EAB public release)
F I L E D
Feb 20, 2026
Clerk, Environmental Appeals Board
ENVIRONMENTAL APPEALS BOARD INITIALS ________________________
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
)
In re Meraki Group LLC ) Docket No. CAA-2026-8729
)
)
)
FINAL ORDER
February 20, 2026
Before Environmental Appeals Judges Aaron P. Avila and Ammie Roseman-Orr.
Order of the Board by Judge Roseman-Orr:
Pursuant to 40 C.F.R. § 22.18(b)–(c) of the EPA’s Consolidated Rules of Practice
Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits, 40 C.F.R. Part 22, the attached Expedited Settlement Agreement resolving this matter is incorporated by reference into this Final Order and is hereby ratified.
The Respondent is ORDERED to comply with all terms of the Expedited Settlement
Agreement, effective immediately.
So ordered.
ENCLOSURE 1
EXPEDITED SETTLEMENT AGREEMENT
ENVIRONMENTAL APPEALS BOARD
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
)
In re: )
) Docket No. CAA-2026-8729
Meraki Group LLC )
)
)
)
EXPEDITED SETTLEMENT AGREEMENT
A. JURISDICTION
-
This is an expedited administrative penalty assessment proceeding brought for alleged
violations of the American Innovation in Manufacturing Act of 2020 (“AIM Act”), 42 U.S.C.
§ 7675, which governs the import of hydrofluorocarbons (“HFCs”), under Section 113(d) of the Clean Air Act (“CAA”), 42 U.S.C. § 7413(d), which authorizes the United States Environmental Protection Agency (“EPA”) to bring administrative civil enforcement actions. -
This expedited settlement agreement (“Agreement”) is entered into under Section 113(d) of
the CAA, 42 U.S.C. § 7413(d), and the Consolidated Rules of Practice Governing the Administrative Assessment of Penalties and the Revocation/Termination or Suspension of Permits, 40 C.F.R. Part 22. -
Complainant is the United States Environmental Protection Agency. On the EPA’s behalf,
Acting Director Sparsh S. Khandeshi, Air Enforcement Division, is delegated the authority to settle civil administrative penalty proceedings under Section 113(d) of the CAA. -
Respondent is Meraki Group LLC (“Meraki”) and is a “person” as defined below and
identified further in Table 1 of the Expedited Settlement Agreement (“ESA”) Attachment 1. -
Complainant and Respondent (together, the “Parties”), having agreed that settlement of this
action is in their mutual interest, consent to the issuance of the attached final order (“Final Order” or “Order”) ratifying this Agreement before taking testimony and without adjudication of any issues of law or fact herein, and Respondent agrees to comply with the terms of this Agreement and Final Order. Furthermore, Complainant has determined, and Respondent does not dispute, that settlement of this action is in the public interest. 6. The EPA and the United States Department of Justice jointly determined that this matter, although it involves alleged violations that occurred more than one year before the initiation of this proceeding, is appropriate for an administrative penalty assessment. 42 U.S.C.
§ 7413(d). -
The Environmental Appeals Board is authorized to ratify this Agreement, which
memorializes a settlement between Complainant and Respondent. 40 C.F.R. §§ 22.4(a)(1) and 22.18(b). -
The ratification of the Final Order, incorporating this Agreement, simultaneously commences
and concludes this proceeding. 40 C.F.R. § 22.13(b).B. GOVERNING LAW -
This proceeding arises under the AIM Act, 42 U.S.C. § 7675, and Section 113 of the CAA,
42 U.S.C. § 7413, and the regulations promulgated thereunder, which impose limits on HFC production and consumption. -
The EPA is authorized to enforce the AIM Act and any regulation promulgated thereunder
utilizing the federal enforcement authorities established by Section 113 of the CAA, 42
U.S.C. § 7675(k)(1)(C). Section 113 of the CAA authorizes the Administrator of the EPA to
assess a civil administrative penalty of not more than $25,000 per day of violation. 42 U.S.C.
§113(a)(3)(A), (d)(1). Pursuant to the Federal Civil Penalties Inflation Adjustment Act of
1990, Pub. L. 101-410, as amended, and its implementing regulation, the Civil Monetary
Penalty Inflation Adjustment Rule, codified at 40 C.F.R. Part 19, the statutory maximum
civil administrative penalty has subsequently been raised to $59,114 per day of violation. 40
C.F.R. § 19.4, Table 1. -
The EPA regulations at 40 C.F.R. Part 84, Subpart A, implement the AIM Act requirement to
phase down HFC production and consumption. 1 -
The regulations at 40 C.F.R. Part 84, Subpart A, apply to any person who imports a regulated
substance. 40 C.F.R. § 84.1(b). -
The regulations at 40 C.F.R. § 84.5(b)(1) state that “[n]o person may import bulk regulated
substances, either as a single component or a multicomponent substance, except . . . [i]f the
importer of record possesses at the time they are required to submit reports to EPA pursuant
to § 84.31(c)(7), and expends at the time of ship berthing for vessel arrivals, border crossing
for land arrivals such as trucks, rails, and autos, and first point of terminus in U.S.
jurisdiction for arrivals via air, consumption or application-specific allowances in a quantity
equal to the exchange-value weighted equivalent of the regulated substances imported,
whether present as a single component or a multicomponent blend.”
1
The regulations at 40 C.F.R. Part 84, Subpart A were amended on September 18, 2023. If a version of the regulations was different in 2022 from the current version of the regulations, it is cited as “2022” in this Agreement.
2
14. Pursuant to 40 C.F.R. § 84.31(a), “any person who … imports, … regulated substances”
must comply with specified reporting requirements.
-
The regulations at 40 C.F.R. § 84.31(c)(7) provide that the importer of record of imported
regulated substances must submit an advance notification report for each shipment of
regulated substances imported no later than 10 days prior to the date of importation if
arriving by marine vessel and no later than 5 days if arriving by non-marine vessel. -
The regulations at 40 C.F.R. § 84.31(c)(7) (2022) 2 provided that a person importing a
regulated substance, or their agent, was required to submit an advance notification report for
each shipment of regulated substances imported no later than 14 days before importation. -
The definitions, listed at 40 C.F.R. Part 84, Subpart A, include:
a) An “allowance” is defined as a “limited authorization for the production or consumption
of a regulated substance established under subsection (e) of Section 103 in Division S,
Innovation for the Environment, of the Consolidated Appropriations Act, 2021 (Pub. L.
116-260) (the AIM Act). An allowance allocated under subsection (e) of Section 103 in
Division S of the AIM Act does not constitute a property right.” 40 C.F.R. § 84.3.b) “Bulk” is defined as “a regulated substance of any amount that is in a container for the
transportation or storage of that substance such as cylinders, drums, ISO tanks, and small
cans. A regulated substance that must first be transferred from a container to another
container, vessel, or piece of equipment in order to realize its intended use is a bulk
substance. A regulated substance contained in a manufactured product such as an
appliance, an aerosol can, or a foam is not a bulk substance.” 40 C.F.R. § 84.3.c) “Consumption allowances” are “a limited authorization to produce and import regulated
substances; however, consumption allowances may be used to produce regulated
substances only in conjunction with production allowances.” 40 C.F.R. § 84.3.d) “Exchange value” is defined as the “value assigned to a regulated substance in
accordance with AIM Act subsections (c) and (e), as applicable, and as provided in
Appendix A to 40 C.F.R. Part 84.” 40 C.F.R. § 84.3.e) “Exchange value equivalent” is defined as “the exchange value-weighted amount of a
regulated substance obtained by multiplying the mass of a regulated substance by the
exchange value of that substance.” 40 C.F.R. § 84.3.f) “Import” is defined as “to land on, bring into, or introduce into, or attempt to land on,
bring into, or introduce into, any place subject to the jurisdiction of the United States,
regardless of whether that landing, bringing, or introduction constitutes an importation
within the meaning of the customs laws of the United States. Offloading used regulated
2
40 C.F.R. § 84.31(c)(7) (and other sections) has since been modified, effective September 18, 2023 (See 88 Fed. Reg. 46,836, 46,897 (July 20, 2023)); see also footnote 1, supra.
3
substances recovered from equipment aboard a marine vessel, aircraft, or other aerospace
vehicle during servicing is not considered an import.” 40 C.F.R. § 84.3.
g) “Importer” is defined as “any person who imports a regulated substance into the United
States. ‘Importer’ includes the person primarily liable for the payment of any duties on
the merchandise or an authorized agent acting on his or her behalf. The term also
includes: (1) [t]he consignee; (2) [t]he importer of record; (3) [t]he actual owner; or (4)
[t]he transferee, if the right to draw merchandise in a bonded warehouse has been
transferred.” 40 C.F.R. § 84.3.
h) “Person” is defined as “any individual or legal entity, including an individual,
corporation, partnership, association; state, municipality, political subdivision of a state,
Indian tribe; any agency, department, or instrumentality of the United States; and any
officer, agent, or employee thereof.” 40 C.F.R. § 84.3.
i) “Regulated substance” is defined as “a hydrofluorocarbon listed in the table contained in
subsection (c)(1) of the AIM Act and a substance included as a regulated substance by
the Administrator under the authority granted in subsection (c)(3).” 40 C.F.R. § 84.3.
- A current list of regulated substances, their chemical formulas, and their exchange values can
be found in Appendix A to 40 C.F.R. Part 84. See 40 C.F.R. § 84.3. -
The regulated substances at issue in this matter are assigned the following exchange values:
HFC Chemical Formula or Blends Exchange Value
R-410A 50% HFC-125, 50% HFC-32 2,087.5 R-407C 52% HFC-134a, 25% HFC-125, 23% HFC-32 1,773.9 40 C.F.R. Part 84, Appendix A.C. ALLEGED VIOLATIONS OF LAW -
The EPA alleges that Meraki violated 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7)
(2022) by failing to timely submit advance notification reports for the shipments of regulated
substances identified in Tables 1a and 1b of ESA Attachment 1 by the day specified by 40
C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7) (2022).D. TERMS OF AGREEMENT -
For the purpose of this proceeding, as required by 40 C.F.R. § 22.18(b)(2), Respondent:
a. admits that the EPA has jurisdiction over the subject matter alleged in this
Agreement;
b. admits the facts stipulated in Table 1 of ESA Attachment 1;4c. consents to the assessment of a civil penalty as stated in Table 3 of ESA
Attachment 1 and below;
d. waives any right to contest the alleged violations of law set forth in Section C of
this Agreement; and
e. waives its right to appeal the Final Order accompanying this Agreement. -
By signing this Agreement, respondent waives any rights or defenses that respondent has or
may have for this matter to be resolved in federal court, including but not limited to any right
to a jury trial, and waives any right to challenge the lawfulness of the final order
accompanying the expedited settlement agreement. -
For the purpose of this proceeding, Respondent:
a. agrees that this Agreement states a claim upon which relief may be granted
against Respondent;
b. acknowledges that this Agreement constitutes an enforcement action for purposes
of considering Respondent’s compliance history in any subsequent enforcement
actions related to the Respondent;
c. certifies that it completed the corrective action as set forth in Table 4 of ESA
Attachment 1;
d. waives its right to request a hearing, any right to contest the allegations in this
Expedited Settlement Agreement and Final Order and its right to appeal this
Expedited Settlement Agreement and Final Order;
e. consents to personal jurisdiction in any action to enforce this Agreement or Final
Order, or both, in an appropriate United States District Court; and
f. waives any rights it may possess at law or in equity to challenge the authority of
the EPA to bring a civil action in an appropriate United States District Court to
compel compliance with the Agreement or Final Order, or both, and to seek an
additional penalty for noncompliance with the Agreement or Final Order and
agrees that federal law shall govern in any such civil action.E. TERMS OF PAYMENT -
Respondent agrees to pay a civil penalty in the amount of $9,000 (“Assessed Penalty”),
which is stated in Table 3 of ESA Attachment 1, within thirty (30) calendar days after the
date the Final Order ratifying this Agreement is filed with the Clerk of the Environmental
Appeals Board (“Filing Date”). Respondent shall pay the Assessed Penalty and any interest,
fees, and other charges due using any method, or combination of appropriate methods, as
provided on the EPA website: https://www.epa.gov/financial/makepayment. For additional
instructions see: https://www.epa.gov/financial/additional-instructions-making-payments-
epa. -
When making a payment, Respondent shall:
a. Identify every payment with Respondent’s name and the docket number of this Agreement, CAA-2026-8729, 5b. Concurrently with any payment or within 24 hours of any payment, Respondent
shall serve proof of such payment (electronic correspondence is preferred) to the
following person(s):Tommie Madison, Clerk of the Environmental Appeals Board U.S. Environmental Protection Agency, Headquarters 1200 Pennsylvania Avenue, NW Mail Code 1103M Washington, DC 20460-0001 [email protected] Ethan Thompson, Attorney Advisor U.S. Environmental Protection Agency, Headquarters 2.2226 J, William Jefferson Clinton Building South 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Mail Code 2242A [email protected] U.S. Environmental Protection Agency Cincinnati Finance Center Via electronic mail to: [email protected] “Proof of payment” means, as applicable, a copy of the check, confirmation of credit card or debit card payment, or confirmation of wire or automated clearinghouse transfer, and any other information required to demonstrate that payment has been made according to EPA requirements, in the amount due, and identified with the appropriate docket number and Respondent’s name. -
Interest, Charges, and Penalties on Late Payments. Pursuant to 42 U.S.C. § 7413(d)(5), 31
U.S.C. § 3717, 31 C.F.R. § 901.9, and 40 C.F.R. § 13.11, if Respondent fails to timely pay
any portion of the Assessed Penalty per this Agreement, the entire unpaid balance of the
Assessed Penalty and all accrued interest shall become immediately due and owing, and the
EPA is authorized to recover the following amounts.a. Interest. Interest begins to accrue from the Filing Date. If the Assessed Penalty is paid in full within thirty (30) days, interest accrued is waived. If the Assessed Penalty is not paid in full within thirty (30) days, interest will continue to accrue until any unpaid portion of the Assessed Penalty as well as any interest, penalties, and other charges are paid in full. Per 42 U.S.C. § 7524(c)(6), interest will be assessed pursuant to 26 U.S.C. § 6621(a)(2), that is the IRS standard underpayment rate, equal to the Federal short-term rate plus 3 percentage points. 6b. Handling Charges. The United States’ enforcement expenses including, but not
limited to, attorneys’ fees and costs of handling collection.c. Late Payment Penalty. A ten percent (10%) quarterly non-payment penalty. -
Late Penalty Actions. In addition to the amounts described in the prior Paragraph, if
Respondent fails to timely pay any portion of the Assessed Penalty per this Agreement, the
EPA may take additional actions. Such actions the EPA may take include, but are not limited
to, the following.a. Refer the debt to a credit reporting agency or a collection agency, pursuant to 40 C.F.R. §§ 13.13 and 13.14. b. Collect the debt by administrative offset (i.e., the withholding of money payable by the United States government to, or held by the United States government for, a person to satisfy the debt the person owes the United States government), which includes, but is not limited to, referral to the Internal Revenue Service for offset against income tax refunds, pursuant to 40 C.F.R. Part 13, Subparts C and H. c. Suspend or revoke Respondent’s licenses or other privileges, or suspend or disqualify Respondent from doing business with the EPA or engaging in programs the EPA sponsors or funds, pursuant to 40 C.F.R. § 13.17. d. Request that the Attorney General bring a civil action in the appropriate district court to enforce the Final Order and recover the full remaining balance of the Assessed Penalty, in addition to interest and the amounts described above, pursuant to 42 U.S.C. § 7413(d)(5). In any such action, the validity, amount, and appropriateness of the Assessed Penalty and Final Order shall not be subject to review. -
Allocation of Payments. Pursuant to 31 C.F.R. § 901.9(f) and 40 C.F.R. § 13.11(d), a partial
payment of debt will be applied first to outstanding handling charges, second to late penalty
charges, third to accrued interest, and last to the principal that is the outstanding Assessed
Penalty amount. -
Tax Treatment of Penalties. Pursuant to 26 U.S.C. §ௗ162(f), penalties, interest, and other
charges paid pursuant to this Agreement shall not be deductible for purposes of federal taxes. -
By signing this Agreement, Respondent certifies that the information it has supplied
concerning this matter was at the time of submission true, accurate, and complete for each
such submission, response, and statement. Respondent acknowledges that there are
significant penalties for submitting false or misleading information, including the possibility
of fines and imprisonment for knowing submission of such information, under 18 U.S.C.
§ 1001. -
By signing this Agreement, Respondent acknowledges that this Agreement and Order,
including identifying information such as name, federal tax ID number, mailing and e-mail
7
address, will be available to the public when the Agreement and Certificate of Service are
filed and uploaded to a searchable database and agrees that this Agreement does not contain
any confidential business information or other personally identifiable information. -
By signing this Agreement, the undersigned representative of Complainant and the
undersigned representative of Respondent each certify that they are fully authorized to
execute and enter into the terms and conditions of this Agreement and has the legal capacity
to bind the party they represent to this Agreement. -
By signing this Agreement, Respondent agrees to acceptance of the Complainant’s: (a)
digital or an original signature on this Agreement; and (b) service of the fully executed
Agreement on the Respondent by mail or by e-mail. Respondent understands that the mailing
or e-mail address may be made public when the Agreement and Certificate of Service are
filed and uploaded to a searchable database. Complainant agrees to acceptance of the
Respondent’s digital or an original signature on this Agreement. -
Each party shall bear its own attorney’s fees, costs, and disbursements incurred in this
proceeding.F. EFFECT OF AGREEMENT AND ATTACHED FINAL ORDER -
In accordance with 40 C.F.R. § 22.18(c), completion of the terms of this Agreement and
Final Order resolves only Respondent's liability for federal civil penalties for the violation(s)
identified in Section C of this Agreement. -
This Agreement constitutes the entire agreement and understanding of the Parties and
supersedes any prior agreements or understandings among the Parties with respect to the
subject matter hereof. -
The terms, conditions, and compliance requirements of this Agreement may not be modified
or amended after it is ratified except upon the written agreement of both parties, and approval
of the Environmental Appeals Board. -
Any violation of this Agreement or Order may result in a civil judicial action for an
injunction, or civil penalties of up to $124,426 per day per violation (with each kilogram a
separate violation), or both, as provided in Section 113(b)(2) of the Act, 42 U.S.C.
§ 7413(b)(2), as well as criminal sanctions as provided in Section 113(c) of the Act, 42
U.S.C. § 7413(c). The EPA may use any information submitted under this Agreement in an
administrative, civil judicial, or criminal action. -
Nothing in this Agreement shall relieve Respondent of the duty to comply with all applicable
provisions of the Act and other federal, state, or local laws or statutes, nor shall it restrict the
EPA’s authority to seek compliance with any applicable laws or regulations, nor shall it be
construed to be a ruling on, or determination of, any issue related to any federal, state, or
local permit.840. Nothing herein shall be construed to limit the power of the EPA to undertake any action
against Respondent or any person in response to conditions that may present an imminent
and substantial endangerment to the public health, welfare, or the environment. -
The EPA reserves the right to revoke this Agreement and settlement penalty if and to the
extent that the EPA finds, after signing this Agreement, that any information provided by
Respondent was materially false or inaccurate at the time such information was provided to
the EPA, and the EPA reserves the right to assess and collect any and all civil penalties for
any violation described herein. The EPA shall give Respondent notice of its intent to revoke,
which shall not be effective until received by Respondent. -
Respondent and Complainant agree to the Environmental Appeals Board issuance of the
attached Final Order ratifying the Agreement.9The foregoing Agreement In the Matter of Meraki Group LLC, Docket No. CAA-2026-8729 is Hereby Stipulated, Agreed, and Approved.
COMPLAINANT:
Digitally signed by
SPARSH SPARSH KHANDESHI
KHANDESHI Date: 2026.02.13
17:07:46 -05'00'
Signature
Sparsh S. Khandeshi, Acting Director
Air Enforcement Division
Office of Civil Enforcement
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
10
The foregoing Agreement In the Matter of Meraki Group LLC, Docket No. CAA-2026-8729, is Hereby Stipulated, Agreed, and Approved.
FOR RESPONDENT:
02/09/2026
_____ __________ Signature Date
Printed Name: ____
ZHANPENG Ma __________
Title: ___Managing
___Partner
__________________
Address: ___5462
___82nd St.
__Elmhurst,
___ NY
_11373
______ _____________________
81-1841228
Federal Tax Identification Number: ___________
11
EXPEDITED SETTLEMENT AGREEMENT ATTACHMENT 1
AMERICAN INNOVATION AND MANUFACTURING ACT
OFFSITE COMPLIANCE MONITORING ACTIVITY FACTS, ALLEGED
VIOLATIONS, PENALTY, AND CORRECTIVE ACTION FORM
Table 1a – Offsite Compliance Monitoring Activity or Inspection Stipulated Facts
Offsite Compliance Monitoring Activity Docket Number: CAA-2026-8729
Date: November 12, 2025
Person/Importer Name (“Respondent”): Entry Information: See below
Meraki Group LLC
Importer Number: 81-184122800
Respondent Address: Inspector Name: Jessica Cordasco
5462 82nd St. Email Address: [email protected]
Elmhurst, New York 11373
Subject Regulated Substances: See below Arrival Dates: See below
Table 1b – Summary of Regulated Substance Shipments
Advanced Days
HFC/HFC Importation Notification Mode of Advance
Entry Number
Blend Date 1 Report Filing Transport Notification
Date Reports Late
NIK01271893 R-410A 10/26/2025 10/24/2025 Marine Vessel 8 NIK01230618 R-410A 08/14/2025 08/07/2025 Marine Vessel 3 NIK01102015 R-407C 11/20/2024 11/18/2024 Marine Vessel 8 NIK01016306 R-410A 06/24/2024 06/20/2024 Marine Vessel 6 NIK00959407 R-410A 04/02/2024 04/02/2024 Marine Vessel 10 NIK00891535 R-410A 11/30/2023 11/27/2023 Marine Vessel 7 Change in Reporting Requirements. See 40 C.F.R. § 84.31(c)(7) and 40 C.F.R. § 84.31(c)(7)
(2022).
NIK00765713 R-407C 05/11/2023 05/02/2023 Marine Vessel 5 NIK00686810 R-410A 11/19/2022 11/18/2022 Marine Vessel 13
1
This is the "Arrival Date” per the Customs and Border Protection (“CBP”) Government Client Manifest Capability (“GCMC”) Entry Summary. Table 2 – Description of Alleged Violations
The EPA alleges that:
x the importer of record failed to timely submit advance notification reports for the
import of regulated substances in violation of 40 C.F.R. § 84.31(c)(7), for the
shipments identified by the entry numbers listed in Tables 1a and 1b.
Table 3 – Civil Penalty
Complainant and Respondent agree upon the following civil penalty for settlement
purposes: $9,000, where:
Number of Violations * Violation Type Penalty Amount = Penalty
7 * $1,000 (Late advance reporting) + 1 * $2,000 (Failure to provide any advance
reporting 2) = $9,000
Violation Type Total
Penalty
Amount
Late advance reporting (40 C.F.R. § 84.31(c)(7)) $1,000
Failure to provide any advance reporting (40 C.F.R. § 84.31(c)(7)) $2,000
Late quarterly reports (40 C.F.R. § 84.31(c)(1)) $2,500
Incomplete or inaccurate quarterly reporting (40 C.F.R. § 84.31(c)(1)) $3,000
Failure to submit quarterly reports (40 C.F.R. § 84.31(c)(1)) $3,500
Late annual reports (40 C.F.R. § 84.33(a); 40 C.F.R. § 84.60(a)) $10,000
Incomplete or inaccurate annual reporting (40 C.F.R. § 84.33(a); 40 $10,000
C.F.R. § 84.60(a))
Failure to submit annual reports (40 C.F.R. § 84.33(a); 40 C.F.R. § $15,000
84.60(a))
Failure to maintain records (40 C.F.R. § 98.3(g)) $5,000
Late annual GHG reports (40 C.F.R. § 98.3(b)) $10,000
Incomplete or inaccurate annual GHG reporting (40 C.F.R. § 98.3(b); $10,000
40 C.F.R. § 98.3(h))
Failure to submit annual GHG reports (40 C.F.R. § 98.3(b)) $15,000
2
Where an importer submits a report after the date of importation, the EPA considers the importer to have failed to submit an advance import report under 40 C.F.R. § 84.31(c)(7).
2
Table 3 – Civil Penalty
HFC EV 3 Percentage HFC EV
Multiplier HFC–152 53
< 1,300 20% HFC–41 92
1,300 5,000 30% HFC–152a 124
! 5,000 10,000 40% HFC–143 353
>10,000 15,000 50% HFC–32 675
HFC–245ca 693
Percentage HFC–365mfc 794
TT Product GWP 4 Multiplier HFC–245fa 1,030
< 1,300 20% HFC–134 1,100
1,300 5,000 30% HFC–236cb 1,340
> 5,000 10,000 40% HFC–236ea 1,370
>10,000 15,000 50% HFC–134a 1,430
HFC–43–10mee 1,640
ODS Percentage HFC–227ea 3,220
Multiplier HFC–125 3,500
Any ODS listed as a 40% HFC–143a 4,470
class I or class II HFC–236fa 9,810
controlled substance in HFC–23 14,800
40 C.F.R. Part 82,
whether on its own or
in a blend
Table 4 – Corrective Action
Respondent has completed and submitted all reports to EPA.
3
EVs are found in Appendix A of 40 C.F.R. Part 84.
4
Id.
3
CERTIFICATE OF SERVICE
I certify that copies of the foregoing “Expedited Settlement Agreement” and “Final
Order” in the matter of Meraki Group LLC, Docket Number CAA-2026-8729, were sent to the following persons on February 20, 2026, in the manner indicated:
By E-mail:
Ethan Thompson, Attorney Advisor
Air Enforcement Division
[email protected]
Zhanpeng Ma, Managing Partner
Meraki Group LLC
[email protected]
Digitally signed by
TOMMIE MADISON
Date: 2026.02.20
11:54:37 -05'00'
Tommie Madison
Clerk of the Board
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