3 Refrigerant Environmental Regulations and Compliance

Environmental goals and refrigerants

U.S. refrigerant rules aim both to protect the stratospheric ozone layer and to reduce climate-warming emissions. Chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) can deplete ozone. Many hydrofluorocarbons (HFCs) do not deplete ozone, but have high global-warming potential. Federal requirements therefore address ozone-depleting substances and certain substitutes, with different rules applying to different refrigerants and equipment. State and local requirements may be stricter.

The main federal programs

Two federal programs are central to the requirements for stationary refrigeration and air-conditioning equipment.

Clean Air Act Section 608

Clean Air Act Section 608 regulates stationary refrigeration and air-conditioning equipment. It requires technician certification for covered work, prohibits intentional venting of most refrigerants during service, and sets recovery, leak-repair, sales, and recordkeeping requirements. Its rules generally cover ozone-depleting refrigerants and non-exempt substitutes, including HFCs.

American Innovation and Manufacturing Act

The American Innovation and Manufacturing (AIM) Act addresses HFCs through a phasedown, sector-specific restrictions on HFC use, and rules intended to reduce emissions and increase reclamation. These programs mostly affect companies that manufacture or import refrigerants or place equipment on the market. The AIM Act’s refrigerant-management rules also create leak-repair and recordkeeping duties for owners, operators, and technicians.

Technician responsibilities

Technicians generally need Section 608 certification when their work could reasonably be expected to release refrigerant. Examples include attaching or detaching gauges or hoses and adding or removing refrigerant. Type I, II, and III certifications cover specified equipment; Universal certification covers all types. A closely and continually supervised apprentice may qualify for an exemption. Technicians must keep a copy of their certification at their place of business.

During service, technicians must recover refrigerant rather than intentionally vent it, using appropriate recovery equipment and following applicable evacuation and service procedures. A narrow de minimis exception covers small releases during good-faith recovery efforts, such as normal hose connection and disconnection; it does not allow deliberately emptying a system. Certain specific substitute refrigerants and uses have separate exemptions, so an exemption should not be assumed without checking the applicable rule.

Recovered refrigerant generally cannot be sold for reuse unless it has been reclaimed by an EPA-certified reclaimer. Reuse may be allowed in equipment belonging to the same owner, subject to applicable requirements.

Which leak rules apply

Leak-repair rules do not apply universally. Under Section 608, leak-repair provisions apply to appliances with a full charge of $50$ pounds or more of CFC or HCFC refrigerant. Those provisions do not apply under Section 608 to equipment containing only HFC substitutes.

A separate AIM Act rule, effective January 1, 2026, covers certain appliances with $15$ pounds or more of HFC or specified HFC-substitute refrigerant. Exceptions include residential and light-commercial air-conditioning and heat-pump equipment. Applicability depends on the refrigerant, equipment, and rule; technicians should confirm which requirements apply.

Leak thresholds and required action

Under both relevant leak-repair programs, the applicable threshold depends on equipment type: $30\%$ for industrial process refrigeration, $20\%$ for commercial refrigeration, and $10\%$ for comfort cooling and other covered categories. The exact covered equipment, calculation methods, deadlines, and exceptions differ by program.

Under the AIM Act rule, owners or operators of covered appliances generally must calculate the leak rate when refrigerant is added, subject to limited exceptions. If the rate exceeds the applicable threshold, they generally must identify and repair leaks within $30$ days, or within $120$ days when an industrial-process shutdown is required, and conduct verification tests. If repair is not chosen or does not resolve the excess leak, a retrofit or retirement plan may be required.

For example, when a technician adds refrigerant to a covered commercial refrigeration appliance subject to the AIM Act rule, the owner or operator must calculate the leak rate. If it exceeds the commercial-refrigeration threshold, the leak must be addressed within the regulatory timeline, with required verification and documentation. Topping off the system alone does not replace those duties.

Records and reporting

Recordkeeping requirements depend on the equipment and refrigerant. Technicians must keep proof of Section 608 certification at their place of business. When servicing appliances containing $50$ pounds or more of ozone-depleting refrigerant, technicians must provide the owner with an invoice showing the amount added and documentation of required leak inspections and verification tests.

When disposing of appliances containing $5$ to $50$ pounds of refrigerant, technicians must record the recovery location and date, refrigerant type, monthly quantities recovered, and quantities transferred for reclamation or destruction. These records must be kept for $3$ years.

Owners or operators of Section 608 appliances containing $50$ pounds or more of ozone-depleting refrigerant must retain required service and leak-repair records. Under the AIM Act leak-repair rule, owners or operators of applicable appliances generally must keep required records for $3$ years.

A report to EPA is required when a covered appliance leaks $125\%$ or more of its full charge in a calendar year. Under Section 608, the report is due March 1 of the following year; under the AIM Act rule, it is due March 1 of the subsequent year.

A practical service record can include appliance identification and location, refrigerant type, service date, quantities recovered and added, leak locations, repairs performed, verification results, and where recovered refrigerant was sent. Organized records help owners meet their duties and help technicians document compliance.

Applying the requirements

For stationary equipment, technicians need to determine which rules apply to the refrigerant and appliance, hold the required certification, recover rather than intentionally vent refrigerant, and document regulated work. Section 608’s ozone-depleting-substance leak rules and the AIM Act’s HFC leak rules have different coverage. Because thresholds, exceptions, and deadlines matter, confirm the applicable federal rule and check for stricter state or local requirements before acting.