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Refrigerant Sales Restriction Q&A

General Questions on the Sales Restriction

Who is responsible for verifying a technician’s certification?

Any person servicing, installing or disposing of stationary appliances (except the disposal of small appliances) must be a section 608 certified technician. Selling refrigerant to an individual or company that is not complying with this requirement could result in enforcement action against you or your company.

The seller of the refrigerant is responsible for verifying that the buyer either 1) is a certified technician, or 2) employs a certified technician. By the “seller of the refrigerant” EPA means the person or entity selling, distributing, or offering refrigerant for sale or distribution.

For transactions where there is more than one entity acting as the seller and/or distributor (for example one party handling sales and one party handling the distribution), all sellers and distributors are responsible for verifying a technician’s certification.

Can a person that is not a certified technician place orders and/or sign for orders of refrigerant on behalf of a co-worker that is a certified technician?

Yes, purchasers of refrigerants may provide the seller with evidence that they employ a certified technician, such as a copy of the certification card and a list of those authorized to buy refrigerant or accept delivery of refrigerant.

For example, an office manager for a company that employs section 608 certified technicians can use the company’s account to purchase refrigerant for the technicians to use. 

Regardless of who purchases or picks of up the refrigerant, any person servicing, installing or disposing of stationary appliances (except the disposal of small appliances) must be a section 608 certified technician.

What records must sellers of refrigerant keep?

Refrigerant vendors must maintain invoices that indicate the name of the purchaser, the date of sale, and the quantity of refrigerant purchased. The record does not need to include the technician's certification number (Section 609 technician certification cards may not have a certification number). In addition, if somebody other than the technician is completing the transaction (for example, an employer or coworker is sent to pick up refrigerant on the technician’s behalf) the seller must keep the documentation provided by the buyer that demonstrates that the buyer employs at least one certified technician.

These records must be kept for three years from the date of sale.

Do records need to be kept for small cans of motor vehicle air-conditioning (MVAC) refrigerant that are equipped with self-sealing valves?

No. There is an exception from the recordkeeping requirements for small cans (two pounds or less) of non-exempt substitute refrigerant (for example, R-134a) for use in an MVAC that are equipped with a self-sealing valve that automatically closes and seals when not dispensing refrigerant.

Do I need a technician certification to sell refrigerant?

No. However, sellers should understand the requirement to check that the purchasers of refrigerant are, or employ, certified technicians. They should also understand the recordkeeping requirements for refrigerant sales.

I am a refrigerant wholesaler that sells refrigerant to another refrigerant distributor. What records do I need to keep?

Because the onus is on you, the person selling, distributing, or offering refrigerant for sale or distribution, to ensure compliance with the refrigerant sales restriction, EPA recommends that you keep sufficient records to establish that the purchaser of the refrigerant is going to resell it to certified technicians. 

You are required to keep invoices that indicate the name of the purchaser, the date of sale, and the quantity of refrigerant purchased. These records must be kept for three years from the date of sale.

How do I recognize a valid section 608 or section 609 technician certification card?

Prior to January 1, 2018, section 608 technician certification cards were required to include: the name of the certifying program; the date the organization became an approved certifying program; the name of the person certified; the type of certification; a unique number for the certified person; and the following text:

[Name of person] has been certified as a [Type I, Type II, Type III, and/or Universal, as appropriate] technician as required by 40 CFR part 82, subpart F.

After January 1, 2018, newly issued section 608 technician certification cards must include:  the name of the certifying program; the date the certifying program received EPA approval; the name of the person certified; the type of certification; a unique number for the certified person (that does not include a technician's social security number), and the following text:

[Name of person] has successfully passed a [Type I, Type II, Type III and/or Universal—as appropriate] exam on how to responsibly handle refrigerants as required by EPA's National Recycling and Emissions Reduction Program.

Pre-January 1, 2018, cards are still valid and refrigerant distributors can accept either type. Technicians do not need to obtain a replacement card with the new language. 

EPA-approved Section 609 training and certification programs must provide individuals (who have completed training and testing) with proof of certification with a unique number for each certified technician, including a certificate, a wallet-sized card, or a display card. Some early Section 609 certification cards do not have the unique identification number printed on the card, but these are still valid.

What should I do if I believe a certification card is fraudulent?

If the card appears to be forged or is issued by an entity that was not an EPA approved certification provider that the time the card was issued, you should refuse the sale. For section 608 certifications, EPA maintains lists of approved and formerly approved certifying organizations.

Cards from certifying programs that are no longer approved are still valid, provided they were issued during the period in which the certifying program was approved.

You can also report a suspected violation.

Can I sell refrigerant that is not suitable for use in MVAC systems to a 609-certified technician?

No. Regulations under Section 609 of the Clean Air Act specifically address the servicing of MVACs. Therefore, 609 certified technicians may only purchase refrigerant that is acceptable for use in MVACs.

 More information is available on the following topics:

Online Sale of Refrigerants

What are the requirements for someone that sell refrigerants online?

The online sale of refrigerant is subject to the same recordkeeping and technician certification verification requirements as in-person refrigerant sales.

There are two records that refrigerant vendors (including online vendors) must maintain. You must keep invoices that indicate the name of the purchaser, the date of sale, and the quantity of refrigerant purchased. In addition, if somebody other than the technician is completing the transaction (for example, an employer or coworker is purchasing refrigerant on the technician’s behalf) the seller must keep the documentation provided by the buyer that demonstrates that the buyer employs at least one certified technician.

These records must be kept for three years from the date of sale.

When advertising refrigerants online, clearly stating that the refrigerant is subject to a sales restriction and that only certified technicians can legally purchase the refrigerant can minimize the chance that an unqualified person will attempt to purchase the refrigerant. However, the online vender must still verify, and maintain documentation indicating that the purchaser is or employs a certified technician.

Does EPA allow the online sale of used refrigerant?

No. EPA prohibits the sale of used refrigerant for use in an appliance unless that refrigerant has been reclaimed by an EPA certified reclaimer.  

If you have used refrigerant that you do not need for your own appliances, EPA recommends that you contact an EPA certified reclaimer or your local refrigerant distributor. Depending on the type and condition of the used refrigerant, some reclaimers may pay you for it. 

EPA maintains a list of EPA certified reclaimers.

Are online sales of used appliances that are charged with refrigerant allowed?

Yes. EPA’s regulations allow for the sale of refrigerant contained in a used appliance that is sold or offered for sale together with a fully assembled refrigerant circuit.

Used components of an air-conditioner or refrigeration appliance (for example, a condensing unit) cannot contain used refrigerant when sold.