New EPA Refrigerant Regulations – 6 Compliance Requirements to Know

September 13, 2017 / by Elizabeth Ortlieb

Elizabeth Ortlieb

New EPA refrigerant regulations go into effect on January 1, 2018. Is your property and personnel prepared? Find out now.  

Here are the top, refrigerant management compliance requirements with a January 1, 2018, compliance date:

1. You have a new, refrigerant disposal recordkeeping requirement.

new epa refrigerant refulations

Disposing an HVAC appliance containing between 5 and 50 lbs of ozone-depleting or HFC refrigerant?

Think twice before carelessly throwing it away.

Because this act isn’t as trivial as you think: You must keep records of proper refrigerant recovery and disposal.   

Yes, starting January 1, 2018, technicians disposing of appliances with 5-50 lbs of controlled refrigerant (which is the size of a small house unit or walk-in freezer, by the way) must keep records of the disposal.

The records, which must be kept for three years, must include,

  • The company name, location of the appliance, date of recovery, and type of refrigerant recovered for each appliance;
  • The total quantity of refrigerant, by type, recovered from all disposed appliances in each calendar month; and
  • The quantity of refrigerant, by type, transferred for reclamation and/or destruction, the person to whom it was transferred, and the date of transfer

Keep in mind that, per EPA 608, a person who could be reasonably expected to violate the integrity of the refrigerant circuit during maintenance, service, repair, or disposal of appliances containing controlled refrigerant must have an EPA refrigerant license (i.e., Type I, Type II, Type III, or Universal), which leads us to the next update… 


2. Only personnel with an EPA refrigerant license can handle HFCs and other non-exempt substitutes.

epa refrigerant license

Technicians maintaining, servicing, or repairing appliances with any non-exempt substitute refrigerant, such as HFCs, must have the proper EPA 608 certification(s). This is in addition to the current, technician certification requirement which applies to Class I and Class II refrigerant.

All EPA 608 certified technicians must keep a copy of their certificate at their place of business, and they also must maintain a copy of their certification until three years after no longer operating as a technician.


3. Evacuation level requirements extend to appliances with non-exempt substitute refrigerants.

evacuation level requirements

Before opening or disposing of appliances, certified technicians must (1) evacuate non-exempt substitute refrigerant to the proper evacuation levels specified in the EPA refrigerant management regulations and (2) use certified recovery and/or recycling equipment, per 40 CFR 82.156.

Proper Evacuation Levels for EPA 608 National Refrigerant Management - Chart .png

(See #1 for the new, disposal recordkeeping requirements for some of the most widely-used HVAC appliances.)


4. The sale of HFC refrigerant is also restricted to certified technicians. epa refrigerant management

As of January 1, 2018, the sale of substitute refrigerant is restricted to certified technicians (which is an addition to the sales restriction now on ODS refrigerant).


5. And those who sell or distribute HFCs must keep record of the invoices. 

epa refrigerant management

Persons who sell or distribute, or offer to sell or distribute, any class I or class II refrigerant, or, starting on January 1, 2018, any non-exempt substitute refrigerant must keep invoices that indicate the name of the purchaser, the date of sale, and the quantity of refrigerant purchased.


6. When disposing of a small appliance, evacuation level requirements apply to non-exempt substitute refrigerants (e.g., HFCs). 


Persons recovering refrigerant from a small appliance, MVAC, or MVAC-like appliance for the purposes of disposal of these appliances must evacuate refrigerant to proper evacuation levels found in 40 CFR 82.156(b) using proper recovery equipment.

Wondering what a small appliance means in terms of EPA 608?

A small appliance means “any appliance that is fully manufactured, charged, and hermetically sealed in a factory with five (5) pounds or less of refrigerant, including, but not limited to, refrigerators and freezers (designed for home, commercial, or consumer use), medical or industrial research refrigeration equipment, room air conditioners (including window air conditioners, portable air conditioners, and packaged terminal air heat pumps), dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.”


That concludes our top 6 compliance requirements you need to know now for the update to EPA 608, the national refrigerant management program.

It’s our job to help you prepare for the new EPA refrigerant regulations coming into effect soon.

That’s why we’ve built Trakref, the most comprehensive refrigerant management compliance software on the market. Learn more at

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(Back by popular demand—Prepare your workforce now for the EPA 608 Update!)

p.s., Download this post as a PDF to share with your workforce: 

EPA 608 2018 Checklist Preview - Trakref Free Download.png


If you enjoyed this article, you might want to check out our other articles on this topic and more: 

What 2018 Has in Store for Your Building and HVAC Equipment

5 Things to Know About the Update to EPA Section 608

What You're Missing from the Court Decision on HFC Bans

Topics: HVAC/R, Compliance Reporting, Industry Insights, Refrigerant Compliance, Refrigerant Management

Elizabeth Ortlieb

Written by Elizabeth Ortlieb

With an extensive background in public affairs and communications, Elizabeth serves as the Policy & Content Manager at Trakref, where she tracks HVAC/R policy trends and provides updates to multi-level stakeholders. Email the author at