EPA compliance & who may buy

Who may lawfully buy refrigerant

Under the Clean Air Act and the regulations at 40 CFR Part 82, refrigerant is a restricted sale. For stationary air-conditioning and refrigeration equipment, a buyer must fall into one of these groups:

• A technician certified under EPA Section 608 — Type I, Type II, Type III or Universal.
• The employer of a certified technician, buying for that technician’s use.
• A reseller who will only sell on to one of the parties above, and who provides a resale certificate.
• A purchaser buying for an equipment manufacturer or an approved research use that qualifies under the rule.

For motor-vehicle air conditioning — which for us means R-134a going into a car, truck or fleet vehicle — the relevant credential is EPA Section 609. The two certifications are not interchangeable: 609 does not authorise stationary work, and 608 does not authorise MVAC service.

What we ask you for

Once, at your first order:

1. A legible image or PDF of your certification card, front and back, showing your name, the certifying body and the certification type.
2. For employer purchases: the certified technician’s name and card, plus a short written statement that the refrigerant is for their use.
3. For resale accounts: a state resale certificate and a signed statement that you will sell only to certified technicians or their employers.

After that, your account is flagged as verified and later orders clear without you re-uploading anything. Median review time is under two hours during business hours.

Records we are required to keep

40 CFR 82.166 requires a distributor to retain evidence that each sale was made to a qualifying buyer, and to keep those records for three years. We hold, for that period: the certification document you supplied, the name and address of the purchaser, the date and quantity of each sale, and the refrigerant type.

If the EPA audits you and asks for proof of purchase, email us and we will send your full purchase history the same day. We treat the records as ours to maintain and yours to call on.

The venting prohibition

Section 608(c) makes it unlawful to knowingly vent, release or dispose of refrigerant into the atmosphere during the maintenance, service, repair or disposal of appliances. That applies to HCFCs, HFCs and their substitutes. Recovery is not optional and the civil penalties are substantial.

Two narrow exceptions exist: de minimis releases associated with good-faith recovery attempts, and refrigerants that EPA has specifically exempted. Neither is a licence to open a system to atmosphere.

The AIM Act and the HFC phasedown

The American Innovation and Manufacturing Act directs EPA to cut US production and consumption of hydrofluorocarbons by 85% against a historical baseline, on a stepped schedule running to 2036. Practical consequences you will feel:

• High-GWP products get tighter and pricier. R-404A (GWP 3,922) is the clearest example — allocation-limited, and moving.
• New equipment has moved to A2L. New residential A/C and heat pumps are built for R-454B or R-32, which is why A2L tooling is no longer optional for a service business.
• Reclaimed refrigerant matters more. Recovered and reclaimed product does not draw on the production allowance, so recovering properly is now commercially sensible as well as legally required.

A2L refrigerants and safe practice

R-32 and R-454B carry an ASHRAE 34 classification of A2L: lower toxicity, mildly flammable. They will not propagate a flame as readily as a hydrocarbon, but they will burn under the right conditions. Working with them requires:

• Recovery machines, gauges, vacuum pumps and leak detectors rated for flammable refrigerants.
• Ventilation at the work area and control of heat, sparks, static and open flame.
• Charging only into equipment nameplated for that specific A2L refrigerant.
• Storage of cylinders upright, secured, capped, away from heat and ignition sources.

Reclaimed R-22

Production and import of virgin HCFC-22 in the United States ended on 1 January 2020 under the Montreal Protocol phase-out schedule. Servicing existing equipment with recovered, recycled or reclaimed R-22 remains lawful. Our R-22 is reclaimed to AHRI 700 purity by a certified reclaimer, and the batch analysis ships with the cylinder.

Anyone offering “new” or “virgin” R-22 in the US today is selling you something that cannot legally be what it claims to be.

Hazardous materials transport

Refrigerant cylinders are DOT-regulated hazardous materials in transport. Every shipment leaves here packaged, marked, labelled and documented to 49 CFR by trained personnel. That is also why we ship ground only, never by air, and cannot deliver to PO boxes, APO/FPO addresses, or outside the contiguous United States.

Disclaimer

This page summarises federal requirements as we understand them in order to explain our own process. It is not legal advice, it is not exhaustive, and state and local requirements may add obligations on top. You are responsible for compliance in your own jurisdiction. Where this page and the regulation disagree, the regulation wins.

Primary sources worth bookmarking: 40 CFR Part 82 Subpart F (refrigerant management), 40 CFR 82 Subpart B (MVAC), the EPA Section 608 technician certification programme, and 49 CFR Parts 171–180 (hazardous materials transport).