EPA Section 608 certification

Who needs to be certified

Under 40 CFR 82.161, anyone who “could be reasonably expected to violate the integrity of the refrigerant circuit” while maintaining, servicing, repairing or disposing of an appliance must pass a test from an EPA-approved certification program. EPA’s certification requirements page spells out what counts as technician work:

• Attaching and detaching hoses and gauges to measure pressure.
• Adding refrigerant to, or removing it from, an appliance.
• Any other activity that opens the circuit of a small appliance or an MVAC-like appliance (other than disposal).

Apprentices are exempt while a certified technician closely and continually supervises them, and both share responsibility for compliance. People who only dispose of small appliances, MVACs and MVAC-like appliances do not need certification.

The four certification types

A small appliance (40 CFR 82.152) is fully manufactured, charged and hermetically sealed in a factory with 5 lb of refrigerant or less. Examples in the definition are refrigerators and freezers, room and window units, portable ACs, PTAC heat pumps, dehumidifiers, under-counter ice makers, vending machines and water coolers. A split system charged in the field is Type II work no matter how small its charge.

Pressure classes

The pressure classes are defined by the refrigerant’s liquid saturation pressure at 104°F, in absolute pressure:

The same classes set the recovery evacuation levels. R-454B and R-32 are not named in the definitions, so classify them from their saturation pressure; the R-454B and R-32 profiles print the PT data.

How the test works

EPA writes the question bank and releases it only to approved certifying programs. Each test must draw at least 25 questions from the core group and at least 25 from each technical group for the type (82.161(c)). Appendix D adds the rules programs must follow:

• Universal is 100 questions: 25 core plus 25 each for Types I, II and III. It can be taken at once or built from passing scores on separate Type I, II and III tests.
• Type II, Type III and Universal are closed-book, proctored tests in a secure setting. Proctors check photo ID and make sure no notes or training materials are used. A Type I test taken as part of Universal is closed-book too.
• Type I alone may be offered in a mail-in format. Mail-in Type I tests cannot be used toward Universal. EPA’s page puts it this way: core tests taken open book cannot be used for Universal, and the core must be taken proctored to earn Universal.
• Passing score: 70% on the closed-book tests, 84% on mail-in Type I.
• The card: programs must issue a wallet card within 30 days of the test. It shows the program, your name, the type and a unique number. EPA does not issue cards itself.

Programs are encouraged to offer tests in other languages or allow a translator. You can ask for an oral test by writing to the program at least 30 days before the exam and explaining why. EPA’s 608/609 overlap page notes that Section 608 training classes are voluntary; only passing the test is required.

Since January 1, 2018, programs other than federal ones must publish an online list of technicians they certified on or after January 1, 2017, with name, city, type and date. Technicians can opt out.

Certificates do not expire

EPA states that “Section 608 Technician Certification credentials do not expire.” The rule reserves EPA’s right to require recertification later through a Federal Register notice. The current text of 82.161 contains no recertification requirement.

Keep a copy of your certificate at your place of business, and keep it until three years after you stop working as a technician. EPA can require you to demonstrate proper recovery at your place of business. A certificate can be revoked or suspended for failing to do that or for breaking the subpart, and a technician whose certificate is revoked must recertify before working on appliances again.

The sales restriction

Under 40 CFR 82.154(c), refrigerant may be sold only to a certified technician, to an employer who shows proof of employing at least one, for resale to certified buyers, or to appliance manufacturers. Since January 1, 2018 this applies to non-exempt substitutes (HFCs and HFOs) as well as CFCs and HCFCs.

The exception is small MVAC cans: 2 lb or less, with a unique fitting and, if made on or after January 1, 2018, a self-sealing valve. EPA’s sales restriction page says only Section 608 technicians can buy refrigerant intended for stationary equipment. Section 609 technicians cannot buy it in any container size, and that includes R-22.

Sellers must keep invoices showing the buyer, the date and the quantity for three years.

What changed in 2018 and after

The 2016 update to Subpart F brought substitutes into the program from January 1, 2018. Certification, the sales restriction, recovery levels and certified recovery equipment now apply to HFCs such as R-410A and to HFO blends.

Some substitutes are exempt from the venting prohibition and the subpart in listed end uses (82.154(a)(1)). These include CO2, nitrogen and water in any application, ammonia in commercial or industrial process refrigeration and absorption units, and R-290, R-600a and R-441A in specific self-contained equipment.

The leak repair rules went the other way. Since April 10, 2020, 40 CFR 82.157 applies only to appliances with 50 lb or more of an ozone-depleting refrigerant. Leak repair for HFC appliances now falls under the AIM Act: 40 CFR 84.106 applies from January 1, 2026 to appliances with 15 lb or more, excluding residential and light commercial AC and heat pumps. See EPA leak repair rules and AIM Act refrigerant rules.

Recordkeeping that falls on technicians

• Certificate: keep a copy at your place of business (82.161(a)(4)).
• Disposal of 5 to 50 lb appliances: since January 1, 2018, technicians who recover refrigerant to dispose of an appliance with a full charge of more than 5 and less than 50 lb must keep records for three years. The records cover company name, location, date and refrigerant type per appliance, monthly totals by type, and what was sent for reclamation or destruction, to whom and when (82.156(a)(3)).
• ODS appliances of 50 lb or more: whoever adds or removes refrigerant must give the owner or operator documentation of the service (82.157(b)). Technicians who do leak inspections or verification tests must document them too.

Section 609 for vehicle AC

Servicing motor vehicle air conditioning for payment or barter requires certification under Section 609 (40 CFR part 82 subpart B), not 608. EPA says 609 programs train and test on MVAC recycling equipment under SAE standards, and their tests differ from the 608 tests.

MVAC-like appliances, such as farm and construction equipment with open-drive compressors and 20 lb or less of refrigerant, can be serviced with either 609 or 608 Type II certification. EPA recommends 609 for them. Buses using R-22 are not MVACs; they are high-pressure equipment under Type II.

Is A2L training required?

Not as a separate federal certification. 82.161 defines its four types by kind of appliance, and the same Type I or Type II card covers R-454B and R-32 equipment.

EPA’s SNAP listing for A2L refrigerants in residential and light commercial AC (Appendix W) says, in its Further Information column, that “only technicians specifically trained in handling flammable refrigerants should service” the equipment. It also says personnel should get training and follow practices consistent with Annex HH of UL 60335-2-40, 3rd edition. In the 2023 SNAP rule, EPA explains that statements in that column “are not binding for use of the substitute under the SNAP program,” though it encourages users to follow them.

What is binding under that listing are the equipment markings. They include a label reading “To Be Repaired Only By Trained Service Personnel” and red PMS #185 or RAL 3020 marks at the service ports.

OEMs go further. Rheem’s R-454B instructions say servicing shall be done only by qualified personnel trained by a training organization or manufacturer accredited to teach national competency standards, with that competence “documented by a certificate.” So A2L training is an OEM and industry requirement, not an EPA one. What the job needs on A2L systems is covered in the A2L refrigerants guide.