HVAC Refrigerant Rules: Leak Repair & Records (2026)

The EPA refrigerant rules an HVAC shop owner has to run in 2026: Section 608 certification, recovery, leak repair triggers, disposal records, and the new HFC rules.

Most refrigerant compliance problems in a small shop aren't about bad intent. They're about paperwork nobody owns: a tech's 608 card that was never copied, a recovery machine nobody checked, a 60-pound rooftop unit that keeps getting topped off with no leak rate on the invoice. When a commercial customer, a supplier, or EPA asks for records, "we did the work right" doesn't count unless you can show it.

This guide covers the federal refrigerant rules a 1–15 truck shop deals with every week: who has to be certified, who can buy refrigerant, how refrigerant has to come out of a system, when a leak has to be fixed, what disposal records you keep, and what the newer HFC rules under the AIM Act add starting in 2026. It ends with a shop checklist and a records table. If you're looking for the R-410A to A2L install dates, that's covered separately in the [HVAC refrigerant transition guide](/guides/hvac-refrigerant-transition-a2l-2026).

This is general information, not legal advice. It summarizes federal EPA rules as published in the Code of Federal Regulations in September 2026. Your state or city may add its own rules. Rules change, and the regulations have exceptions this guide doesn't cover. Read the regulation text linked in the Sources section, check current EPA guidance, and talk to an attorney before relying on this for a specific job.

The two rulebooks, in plain words

Two sets of federal rules cover refrigerant in the equipment your shop services:

• Section 608 rules (40 CFR Part 82, Subpart F). The long-standing rules under the Clean Air Act: technician certification, the refrigerant sales restriction, the venting ban, recovery and evacuation levels, recovery equipment standards, safe disposal, and leak repair. Since January 1, 2018, most of these apply to HFC and other non-exempt substitute refrigerants as well as ozone-depleting ones like R-22.
• AIM Act rules (40 CFR Part 84). The newer HFC rules. Subpart B is the technology transitions rule (the A2L install dates). Subpart C, "Management of Regulated Substances," is often called the Emissions Reduction and Reclamation rule. It was published October 11, 2024 (89 FR 82682) and took effect December 10, 2024. Its main requirements for service shops start January 1, 2026, and some start later.

One detail matters here. The Section 608 leak repair rule (82.157) now covers only appliances with 50 or more pounds of an ozone-depleting refrigerant (class I or class II, such as R-22). It doesn't cover appliances that contain only substitute refrigerants. HFC leak repair moved to the AIM Act rule (84.106), which has its own threshold and scope. Both are covered below.

Section 608 technician certification

Who needs it. Anyone who could reasonably be expected to open the refrigerant circuit while maintaining, servicing, repairing, or disposing of equipment has to pass an EPA-approved certification exam (82.161(a)). EPA's certification page describes a "technician" as someone who attaches or detaches hoses and gauges to measure pressure, or adds or removes refrigerant.

The four types:

For a residential and light commercial shop, Type II is the minimum for anyone on a split system. Universal is the simplest standard to hire and train to. EPA says Section 608 credentials don't expire.

Apprentices. An apprentice can work without certification only if they're closely and continually supervised by a certified tech (82.161(a)(2)). "Apprentice" has a specific meaning: the person must be registered as an apprentice with the U.S. Department of Labor's Office of Apprenticeship (or a recognized State Apprenticeship Council), and apprentice status only lasts two years from first registration (82.152). A new helper who isn't in a registered program is not an "apprentice" under this rule. Get them certified early. The [90-day technician onboarding plan](/guides/hvac-technician-onboarding-90-day-plan-2026) is a good place to schedule it.

What the shop keeps on file. The rule says certified technicians must keep a copy of their certificate at their place of business, and keep it until three years after they stop working as a technician (82.161(a)(4)). In practice, the shop should hold a copy of every tech's card, including techs who have left, for at least three years after they leave.

Who can buy refrigerant

Under the sales restriction (82.154(c)), refrigerant for stationary equipment can generally be sold only to:

• a technician certified under Section 608, or
• a business that employs at least one certified technician and gives the seller proof of that.

EPA's sales restriction page says only Section 608 certified technicians can buy refrigerant meant for stationary AC and refrigeration equipment. Section 609 (auto AC) certification doesn't count. Sellers must keep invoices showing the buyer's name, the date, and the quantity for three years, plus the proof-of-certified-employee documents they collect (82.154(c)(3)).

What this means for your shop: keep your supplier accounts current with at least one active 608 card on file. If the only certified tech on the account leaves, update it before the next order.

Selling or passing on used refrigerant. Used refrigerant can't be sold for use as a refrigerant unless a certified reclaimer has reclaimed it (82.154(d)). The AIM Act rule says the same for HFCs: recovered HFC refrigerant can only be sold or transferred to a new owner if it has been reclaimed to spec, or if it's going to a reclaimer or for destruction (84.104(a)). You can put recovered refrigerant back into the same system, or into another appliance owned by the same owner, without reclaiming it (82.156(h)). You can't sell it to the next customer.

No venting, and use certified recovery equipment

Venting ban. Nobody servicing, repairing, or disposing of an appliance may knowingly vent refrigerant (82.154(a)). The only exceptions are listed exempt substitutes, such as CO2, nitrogen, water, and some hydrocarbons in specific uses, plus "de minimis" releases that happen during good-faith recovery when all the required practices are followed. Releasing refrigerant after you've recovered it is also a violation.

Recovery equipment. Recovery or recycling equipment has to be certified by an EPA-approved testing organization for the type of refrigerant and appliance (82.154(b), 82.158). Certified machines carry a label naming the testing organization and the appliance category, along with the date of manufacture and serial number (82.158(h)). A few rules to know:

• Use the machine according to the manufacturer's directions (82.156(g)).
• System-dependent (passive) recovery can't be used on appliances holding more than 15 pounds unless it's a permanently attached pump-out unit (82.156(e)).
• Nobody may alter a certified machine's design in a way that affects its performance without getting it recertified (82.158(b)).

Shop habit: photograph the certification label on every recovery machine and keep it with your equipment list. If a machine's label is missing or unreadable, don't send that machine out.

Evacuation levels before you open a system

Before opening or disposing of an appliance (other than small appliances and vehicle AC), the tech must recover the refrigerant, including the liquid, to the levels in Table 1 of 82.156 and confirm that level was reached before opening. The tech can evacuate the whole appliance or just the part being serviced if it can be isolated.

For recovery equipment made on or after November 15, 1993 (which is essentially every machine in service today):

Small appliances (5 pounds or less, factory-sealed): recover 90% of the refrigerant if the compressor works, 80% if it doesn't, or pull the unit to 4 inches Hg vacuum (82.156(b)).

Exceptions. For repairs that aren't "major" (major means removing a compressor, condenser, evaporator, or auxiliary heat exchange coil, or leaving an opening larger than 4 square inches open for more than 15 minutes), a medium- or high-pressure appliance only has to be at 0 psig or lower before opening. If leaks make the Table 1 levels impossible, isolate and evacuate what you can, and never go above 0 psig. The full rule is 82.156(a)(1)–(2).

Leak repair: which systems, what trigger, what deadline

There are now two parallel leak repair rules. Which one applies depends on the refrigerant and the size of the system.

Ozone-depleting refrigerant (R-22 and similar), 50 lb or more: 82.157

Applies to appliances with a full charge of 50 or more pounds of a class I or class II refrigerant (or a blend containing one). Legally, the duty belongs to the owner or operator (your customer), but your techs create most of the records they need.

Trigger leak rates (per 12-month period):

• Comfort cooling (chillers, commercial splits, packaged rooftop units) and other appliances: 10%
• Commercial refrigeration (supermarkets, restaurants, cold storage): 20%
• Industrial process refrigeration: 30%

HFCs and other high-GWP refrigerants, 15 lb or more: 84.106 (from January 1, 2026)

Applies as of January 1, 2026 to appliances with a full charge of 15 or more pounds of an HFC, or of a substitute with a global warming potential above 53. It doesn't apply to appliances containing only an ozone-depleting refrigerant (those stay under 82.157). It also doesn't apply to equipment in the residential and light commercial air conditioning and heat pump subsector (84.106(a)(3)).

The trigger rates are the same percentages: 10% for comfort cooling, refrigerated transport, and other appliances; 20% for commercial refrigeration; 30% for industrial process refrigeration. The rule also says repairs must be done by a certified technician.

What this means for a shop: a typical house on a split system is outside both leak repair rules (too small for 82.157, and in the excluded subsector for 84.106). The rules start to matter for commercial comfort cooling and walk-in, restaurant, and grocery refrigeration with 15+ pounds of HFC. Where "light commercial" ends and commercial comfort cooling begins isn't defined in the leak repair section itself. If you service commercial RTUs, splits, or chillers with 15+ pounds, check current EPA guidance for how your equipment is classified.

What both rules require once a system is over the trigger

The steps are nearly identical under 82.157 and 84.106:

1. Calculate the leak rate every time refrigerant is added, unless the addition comes right after a retrofit or new install, or qualifies as a seasonal variance.
2. Repair within 30 days of adding refrigerant to an appliance that's over the trigger (120 days if an industrial process shutdown is needed). A certified tech must do a leak inspection to find the leaks.
3. Verification tests. Run an initial verification test within the repair window, and a follow-up test within 10 days of the successful initial test (or within 10 days of the system reaching normal operating conditions if it was evacuated).
4. Or retrofit or retire. If the owner chooses not to repair, or the repair fails, they must write a signed, dated retrofit or retirement plan within 30 days and finish it within one year, unless they're granted more time.
5. Leak inspections afterward. Comfort cooling appliances over the trigger get a leak inspection once a year until the owner can show a full year under the trigger rate. Commercial and industrial refrigeration of 500 pounds or more gets one every quarter.
6. Extensions are possible in limited cases, for example when parts aren't available. The owner has to document the reason and request the extension from EPA within the repair window.

What your techs must hand the customer

This is the part that lands on your invoice. Under both rules, anyone who adds or removes refrigerant from a covered appliance must give the owner or operator documentation at the end of the service that includes:

• the identity and location of the appliance
• the date of the work
• the part(s) worked on and the type of work done on each
• the name of the person doing the work
• the amount and type of refrigerant added (or, for disposal, removed)

The owner also records the full charge and the leak rate with the method used. Many commercial customers will ask your tech to provide these. Build them into your invoice template.

Techs who do leak inspections must give the owner the inspection date, method(s), the location of each leak found, and a certification that all visible and accessible parts were inspected. Techs who do verification tests must give the dates, the leaks tested, the test type, and the results.

Shop habit: for every commercial unit over 15 pounds, add fields for "full charge (lb)," "refrigerant added (lb, type)," "leak rate and method," and "leak locations" to the work order. Make them required fields in your software. A plain-language [SOP](/guides/hvac-sops-operations-manual-2026) for "refrigerant added on a commercial unit" keeps this consistent across techs.

Disposal records (82.155 and 82.156)

Small appliances (window units, dehumidifiers, and the like). Whoever recovers refrigerant for disposal must evacuate to the small-appliance levels above using certified equipment. The final processor (a scrap yard or landfill) must either recover any remaining refrigerant itself or get a signed statement or contract saying it was already recovered. A signed statement includes the name and address of the person who recovered it and the date. The final processor keeps those statements for three years (82.155). If you hand scrap units to a recycler, expect to be asked to sign one, and keep your own copy.

Appliances over 5 and under 50 pounds (most residential and light commercial split systems and packaged units). When your techs recover refrigerant to dispose of the appliance, the tech must keep records for three years showing (82.156(a)(3)):

• company name, appliance location, date of recovery, and type of refrigerant recovered, for each appliance
• total quantity of refrigerant recovered from all disposed appliances each calendar month, by type
• quantity sent for reclamation or destruction, who it went to, and the date

This is the record most small shops don't keep. The simplest fix is one monthly log per shop, fed from the change-out work orders, plus the receipts when you turn recovered cylinders in to your supplier or a reclaimer.

AIM Act rules on reclaimed refrigerant and cylinders

Beyond leak repair, Part 84, Subpart C adds these requirements. Dates are from the current regulation text:

• Reclaimed means reclaimed (from January 1, 2026). Refrigerant can't be sold or labeled as "reclaimed" if the HFC portion contains more than 15% virgin HFC by weight. Certified reclaimers must label containers and keep records certifying this (84.112(a)–(d)). This is mostly a reclaimer's job, but it tells you what a legitimate "reclaimed" cylinder should say.
• Reclaimed refrigerant for servicing some equipment (from January 1, 2029). Servicing and repair of HFC equipment in supermarket systems, refrigerated transport, and automatic commercial ice makers must use reclaimed refrigerant that meets the 15% standard (84.112(e)). Residential and light commercial AC isn't on that list in the current text.
• Disposable cylinders (from January 1, 2028). If you're done with a disposable cylinder that held an HFC and was used in servicing, repair, or installation, it must go somewhere that removes the heel (the leftover refrigerant): a certified reclaimer, a final processor able to remove heels, or a refrigerant supplier able to do so (84.116). Plan now for where your empties will go.

EPA has proposed changes to parts of the AIM Act rules. For example, a May 26, 2026 proposal would exclude road and intermodal transport refrigeration units from the HFC leak repair requirements. Proposals aren't final. Check the current regulation text before changing how you operate.

Shop compliance checklist

People

• Every tech who connects gauges or adds or removes refrigerant holds a 608 card of the right type (Type II minimum for split systems; Universal preferred).
• A copy of every card is on file at the shop, including techs who've left.
• Uncertified helpers work only if they're registered DOL apprentices (within two years of registering) and are closely and continually supervised. Otherwise, get them certified first.

Purchasing

• Each supplier account has a current 608 card or proof of a certified employee on file.
• Recovered refrigerant is never resold. It goes back into the same owner's equipment or to a reclaimer.

Equipment

• Every recovery machine has a readable certification label, photographed and on your equipment list.
• Machines are used per the manufacturer's directions and aren't modified.
• No passive (system-dependent) recovery on systems over 15 pounds.

On the job

• No venting, ever, including after recovery.
• Techs pull the required evacuation level and confirm it before opening a system.
• Work orders for commercial units of 15+ lb capture refrigerant added, full charge, leak rate and method, leak locations, and verification tests, and a copy goes to the customer.

Disposal

• Monthly log of refrigerant recovered from disposed 5–50 lb appliances, by type.
• Receipts kept for every cylinder turned in for reclamation or destruction.
• Signed recovery statements kept for scrap small appliances.
• A plan for disposable-cylinder heels before January 1, 2028.

What records to keep, and for how long

A simple rule for your shop: keep every refrigerant-related work order, log, and receipt for at least three years, and keep tech certification copies for three years after the tech leaves. Digital copies are fine. Both leak repair rules allow electronic or paper records.

Related guides and tools

• [HVAC Refrigerant Transition: R-410A to A2L](/guides/hvac-refrigerant-transition-a2l-2026): install dates, the May 2026 change, and A2L training.
• [HVAC SOPs: How to Build an Operations Manual](/guides/hvac-sops-operations-manual-2026): turn this checklist into one-page SOPs.
• [HVAC Technician Onboarding: 90-Day Plan](/guides/hvac-technician-onboarding-90-day-plan-2026): schedule 608 certification in a new hire's first weeks.
• [Free HVAC business calculators](/tools). No email needed.

Sources

• eCFR, 40 CFR Part 82, Subpart F (Recycling and Emissions Reduction), current text retrieved September 2026 (sections 82.152, 82.154, 82.155, 82.156, 82.157, 82.158, 82.161)
• eCFR, 40 CFR Part 84, Subpart C (Management of Regulated Substances), current text retrieved September 2026 (sections 84.102, 84.104, 84.106, 84.112, 84.116)
• Federal Register, 89 FR 82682 (Oct. 11, 2024), Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under the American Innovation and Manufacturing Act of 2020 (effective Dec. 10, 2024)
• Federal Register, proposed rule (May 26, 2026), Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration Units From the Hydrofluorocarbon Leak Repair Requirements
• U.S. EPA, Section 608 Technician Certification Requirements
• U.S. EPA, Refrigerant Sales Restriction
• U.S. EPA, Stationary Refrigeration Leak Repair Requirements