If you attach gauges to a refrigerant circuit for a living, you need EPA Section 608 certification. Get Universal: it's a 100-question, closed-book, proctored test with a 70 percent passing score, and the card never expires. The harder part isn't the test. It's the record-keeping, and the HFC leak repair and reclaim rules that started phasing in on January 1, 2026.
This guide covers who needs certification, what each type covers, how the test is built and scored, the evacuation levels you're tested on and held to, the sales restriction, what records techs and shops must keep, and what the AIM Act rules actually require. Everything was checked against the eCFR text of 40 CFR Parts 82 and 84 (current as of October 14, 2026) and EPA's own pages. Regulations change, so treat EPA and the eCFR as the final word, not this page.
100
Questions on the Universal test: 25 core plus 25 each for Types I, II and III
15 lb
Charge size where HFC leak repair rules start, from Jan 1, 2026 (residential and light commercial AC excluded)
Who needs EPA 608 certification
The rule is in 40 CFR 82.161: any person who could reasonably be expected to violate the integrity of the refrigerant circuit during maintenance, service, repair or disposal of an appliance must pass a certification exam from an approved program1. EPA's own definition of a technician includes someone attaching and detaching hoses and gauges to measure pressure2. So if you put gauges on, add or recover refrigerant, or open the circuit any other way, you need it.
Since January 1, 2018, that applies to appliances containing any ozone-depleting refrigerant (like R-22) or any non-exempt substitute, which includes HFCs like R-410A and the A2L refrigerants R-454B and R-321. BLS sums it up for the trade: EPA requires nearly all HVAC technicians to be certified in proper refrigerant handling3.
Who doesn't need it. People who only dispose of small appliances, motor vehicle AC or MVAC-like appliances. Apprentices, while closely and continually supervised by a certified tech; the supervisor and the apprentice share responsibility for compliance1. Motor vehicle AC service falls under Section 609, which is a separate certification.
The four certification types
| Type | What it covers (40 CFR 82.161(a)) | Who needs it |
|---|---|---|
| Type I | Maintaining, servicing or repairing small appliances: factory-sealed, five pounds of refrigerant or less | Appliance techs: window units, refrigerators, dehumidifiers, vending machines |
| Type II | Maintaining, servicing, repairing or disposing of medium-, high- and very high-pressure appliances, except small appliances and MVACs | Residential and light commercial HVAC, most commercial refrigeration |
| Type III | Maintaining, servicing, repairing or disposing of low-pressure appliances | Techs on low-pressure centrifugal chillers |
| Universal | All three | Most HVAC techs; employers usually expect it |
Universal costs little extra effort and covers anything a tech might run into, from a window unit to a chiller. A residential HVAC tech needs Type II at minimum.
How the test is built and scored
EPA keeps a bank of questions and releases it only to approved certifying programs. Every test draws at least 25 questions from the core group and at least 25 from each relevant technical group1. The test standards in Appendix D spell out the result4:
| Test | Core questions | Technical questions | Total | Passing score |
|---|---|---|---|---|
| Type I (proctored) | 25 | 25 | 50 | 70% |
| Type I (mail-in) | 25 | 25 | 50 | 84%, can't count toward Universal |
| Type II | 25 | 25 | 50 | 70% |
| Type III | 25 | 25 | 50 | 70% |
| Universal | 25 | 75 (25 per type) | 100 | 70% |
Type II, Type III and Universal tests are closed-book and proctored in a secure setting, and proctors must check photo ID4. Universal can be earned in one sitting or through a series of tests; ask your program how it handles a section you need to retake. EPA adds that a core test taken open book can't be used for Universal; the core must be proctored2. Programs must report results within 30 days and issue a wallet card within 30 days of the test4. A test can be given orally if requested in writing at least 30 days ahead, and programs are encouraged to offer other languages or allow a translator1.
What's on it. Appendix D lists the core areas (environmental impact of CFCs, HCFCs and substitutes; laws and regulations; the changing industry outlook) and the technical areas for each type (leak detection, recovery techniques, safety, shipping and disposal)4. EPA's test topics page breaks these down further. The core is where people who know the work but not the rules lose points: study the venting prohibition, evacuation levels, leak repair thresholds, recovery cylinder rules and dates.
Where to take it. Use a program on EPA's list of approved certifying programs. Many trade schools, supply houses and associations host proctored sessions, and many programs offer remote proctoring. EPA doesn't set the fee; each program does, so check with yours.
The evacuation levels you're tested on (and held to)
Before opening or disposing of an appliance, you must evacuate it to the levels in Table 1 of 40 CFR 82.156, using certified recovery equipment5. For recovery equipment made on or after November 15, 1993:
| Appliance | Required vacuum (inches Hg) |
|---|---|
| Very high-pressure appliance | 0 |
| High-pressure, under 200 lb charge | 0 |
| High-pressure, 200 lb or more | 10 |
| Medium-pressure, under 200 lb | 10 |
| Medium-pressure, 200 lb or more | 15 |
| Low-pressure appliance | 25 mm Hg absolute |
For small appliances, recover 90 percent of the refrigerant if the compressor runs or 80 percent if it doesn't (with post-1993 equipment), or pull the appliance to 4 inches of mercury vacuum5. Leaking components are evacuated to the lowest level reachable without substantially contaminating the refrigerant, never above 0 psig.
Does EPA 608 certification expire?
No. EPA says Section 608 technician certification credentials do not expire2. The regulation reserves EPA's right to require recertification by notice in the Federal Register1; it hasn't done so. EPA can require a tech to demonstrate proper recovery procedures at their place of business, and failing to do so, or breaking the rules, can lead to revocation or suspension, after which the tech must recertify.
Buying refrigerant: the sales restriction
Section 608 certified techs can buy ozone-depleting and substitute refrigerant for stationary equipment. An employer can buy if it gives the wholesaler written evidence that it employs at least one properly certified tech. Section 609 techs can buy only MVAC refrigerant, in any container size. The restriction doesn't cover equipment or components that come pre-charged. Wholesalers must keep invoices with the buyer's name, date and quantity6. Expect your supply house to ask for your card or your company's proof.
Records techs and shops must keep
Here's what the current rules require, by situation:
| Situation | What's required | Rule |
|---|---|---|
| Every certified tech | Copy of certificate at place of business, kept until 3 years after leaving the trade | 40 CFR 82.161(a)(4) |
| Disposing of appliances with more than 5 and less than 50 lb (most residential splits) | Tech keeps 3 years: company, appliance location, date, refrigerant type recovered; monthly totals by type; quantities sent for reclamation or destruction, to whom and when | 40 CFR 82.156(a)(3) |
| Servicing ODS appliances with 50 lb or more | Give the owner an invoice showing refrigerant added; owner keeps service records 3 years | 40 CFR 82.166(j), (k), (m) |
| Servicing HFC appliances with 15 lb or more (not residential or light commercial AC), from Jan 1, 2026 | Owner records for each service: appliance, date, parts serviced, type of service, who did it, amount and type of refrigerant added, full charge, leak rate and method. Techs who do leak inspections and verification tests must hand the owner documentation | 40 CFR 84.106(b), (l) |
| Small appliance disposal | The final processor recovers the refrigerant or keeps a signed statement that it was recovered, for 3 years | 40 CFR 82.155 |
The practical version for any shop: log refrigerant added and recovered on every job, per unit and per tech, with the tech's 608 number. It covers every row above and it's useful data on chronic leakers. In TradesWork, techs log each charge and recovery on the phone (refrigerant, ounces, cylinder, unit), the log exports with the tech's EPA 608 number, and when a unit crosses its leak-rate threshold, TradesWork opens a leak case with a 30-day repair date.
The AIM Act rules: what changed for service work
The American Innovation and Manufacturing Act of 2020 directs EPA to phase down HFCs, manage HFC emissions and reuse, and move new equipment to lower-GWP refrigerants. The new-equipment part (Technology Transitions) is covered in our A2L refrigerants guide. The service part is the Emissions Reduction and Reclamation (ER&R) rule, published October 11, 20247 and codified at 40 CFR Part 84, Subpart C8.
Jan 1, 2018
608 rules extended to substitutes
Technician certification, evacuation and disposal record-keeping apply to HFCs and other non-exempt substitutes, not just CFCs and HCFCs.
Oct 11, 2024
ER&R rule published
HFC leak repair, automatic leak detection, reclaim standards, cylinder heel recovery, records and reporting.
Jan 1, 2026
HFC leak repair starts; reclaim purity rule
Leak repair for appliances with 15 lb or more of an HFC or a substitute with GWP above 53, excluding residential and light commercial AC and heat pumps. Reclaimed refrigerant may not contain more than 15% virgin HFC by weight. New 1,500 lb-plus commercial and industrial refrigeration systems need automatic leak detection.
May 26, 2026
TRU exclusion proposed
EPA proposed excluding road and intermodal transport refrigeration units from leak repair, regardless of charge size.
Jan 1, 2027
Automatic leak detection on existing systems
1,500 lb-plus commercial and industrial refrigeration systems installed from Jan 1, 2017 through 2025 must have automatic leak detection.
Jan 1, 2028
Disposable cylinder heels
Used disposable cylinders must go to a reclaimer or a supplier or final processor that removes the heel, or a certified tech evacuates the heel to 15 in. Hg and signs a statement.
Jan 1, 2029
Reclaimed HFCs for some servicing
Servicing and repair must use reclaimed refrigerant in supermarket systems, refrigerated transport and automatic commercial ice makers.
HFC leak repair: what it covers
The thresholds match the older ozone-depleting refrigerant rule, but at a much smaller charge size85:
| Ozone-depleting refrigerants (40 CFR 82.157) | HFCs and substitutes over 53 GWP (40 CFR 84.106) | |
|---|---|---|
| Applies to appliances with | 50 lb or more | 15 lb or more |
| In effect | Since Jan 1, 2019 (ODS only since Apr 10, 2020) | Since Jan 1, 2026 |
| Commercial refrigeration | 20% leak rate | 20% leak rate |
| Industrial process refrigeration | 30% leak rate | 30% leak rate |
| Comfort cooling and other appliances | 10% leak rate | 10% leak rate (also refrigerated transport) |
| Residential and light commercial AC and heat pumps | Covered only at 50 lb or more | Excluded |
| Repair deadline once over the rate | 30 days (120 if an industrial shutdown is needed) | 30 days (120 if an industrial shutdown is needed) |
Under 84.106, the owner calculates the leak rate every time refrigerant is added; a certified technician must find the leaks and do the repair; and both an initial and a follow-up verification test are required, the follow-up within 10 days of a successful initial test or of the system returning to normal operating conditions8. If the repair doesn't get the leak rate under the threshold, the owner needs a retrofit or retirement plan.
Refrigerant-containing appliances used for the residential and light commercial air conditioning and heat pump subsector.
For a residential service shop, that exclusion means day-to-day work on split systems hasn't changed. If you service commercial refrigeration, chillers or larger comfort cooling, you'll be the one producing the leak inspection and verification documentation the owner relies on.
Reclaim and cylinders
Two pieces reach every tech, and one reaches only some:
- Reclaimed refrigerant purity (from Jan 1, 2026). Refrigerant sold as reclaimed may not contain more than 15% virgin HFC by weight, and reclaimers must label containers to say so8.
- Disposable cylinder heels (from Jan 1, 2028). When you're done with a used disposable cylinder, send it to a certified reclaimer, a supplier or a final processor that removes the heel, or evacuate the heel yourself to 15 inches of mercury vacuum and give the final processor a signed statement with your name, address and the date8.
- Reclaimed HFCs for servicing (from Jan 1, 2029). Required only for supermarket systems, refrigerated transport and automatic commercial ice makers8. Not residential AC.
What hasn't changed: the certification types, the test, the venting prohibition, and the requirement to recover refrigerant before opening or disposing of equipment.
EPA 608 checklist for shop owners
- Every tech who opens a refrigerant circuit holds 608 certification (Universal recommended) or is an apprentice under close supervision
- A copy of each tech's card on file, including techs who left in the last three years
- New hires verified against the certifying program's online list
- Refrigerant added and recovered logged per job, per unit, per tech, with the 608 number
- Disposal records kept three years for 5 to 50 lb appliances
- Commercial customers with 15 lb-plus HFC equipment get leak inspection and verification test documentation from you
- Full charge recorded for every 15 lb-plus commercial unit you maintain
- Recovery machines, vacuum pumps and cylinders ready for A2L refrigerants
- A plan for disposable cylinder heels before Jan 1, 2028
- Someone checks EPA's HFC pages for rule changes at least twice a year
Bottom line
EPA 608 certification is straightforward: get Universal, pass the proctored test with 70 percent, keep your card on file, and it never expires. What changed in 2026 is the paperwork around commercial HFC equipment of 15 pounds and up, not the work on residential split systems. Keep a clean refrigerant log, know which of your customers' equipment falls under the new leak repair rules, and plan for the 2028 cylinder change now.
Footnotes
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40 CFR 82.161, Technician certification (eCFR, current as of Oct 14, 2026). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.161 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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U.S. EPA, Section 608 Technician Certification Requirements (last updated July 15, 2026). https://www.epa.gov/section608/section-608-technician-certification-requirements ↩ ↩2 ↩3
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U.S. Bureau of Labor Statistics, Occupational Outlook Handbook, HVAC mechanics and installers, How to Become One. https://www.bls.gov/ooh/installation-maintenance-and-repair/heating-air-conditioning-and-refrigeration-mechanics-and-installers.htm ↩
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40 CFR Part 82, Subpart F, Appendix D, Standards for Becoming a Certifying Program for Technicians (test content, grading, proof of certification). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F ↩ ↩2 ↩3 ↩4
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40 CFR Part 82, Subpart F: 82.155 (safe disposal), 82.156 (evacuation levels, Table 1, disposal records), 82.157 (leak repair, ODS), 82.166 (records). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F ↩ ↩2 ↩3
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U.S. EPA, Refrigerant Sales Restriction. https://www.epa.gov/section608/refrigerant-sales-restriction ↩
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U.S. EPA, Regulatory Actions for Managing HFC Use and Reuse (Emissions Reduction and Reclamation rule). https://www.epa.gov/hfcs/regulatory-actions-managing-hfc-use-and-reuse ↩ ↩2
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40 CFR Part 84, Subpart C: 84.106 (leak repair), 84.108 (automatic leak detection), 84.112 (reclamation), 84.116 (disposable cylinders). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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Federal Register, Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration, proposed rule, May 26, 2026. https://www.federalregister.gov/documents/2026/05/26/2026-10388/phasedown-of-hydrofluorocarbons-excluding-road-and-intermodal-container-transport-refrigeration ↩
