EPA Refrigerant Rules in 2027: What a 608-Certified Technician Must Follow

Two sets of EPA rules for technicians in 2027

The Section 608 test checks what you know. The rules you work under come from two places in the Code of Federal Regulations, and in 2027 both apply at once. 40 CFR Part 82, Subpart F is the Clean Air Act Section 608 program that the test is built on. 40 CFR Part 84 holds the American Innovation and Manufacturing (AIM) Act rules for HFCs: leak repair and leak detection, reclaimed refrigerant and cylinders in Subpart C, and limits on which refrigerants new systems may use in Subpart B. All dates below were checked against the eCFR text current as of October 22, 2026 and the Federal Register on October 25, 2026.

Part 84 does not create a new card. It defines a "certified technician" as one certified under 40 CFR 82.161, so your Section 608 certification is the credential both sets of rules rely on.

Keeping the EPA 608 test and the job rules apart

EPA's Section 608 Test Topics page (last updated December 5, 2025) does not mention Part 84, and EPA has published nothing saying the 608 test covers it. Study Part 82 and the test topics for the exam, as the EPA 608 exam in 2027 guide explains, and treat Part 84 as on-the-job knowledge. EPA 608 prep for the Core and type tests follows the same split, with explanations tied to Part 82.

Part 82 duties that continue in 2027

None of these changed for 2027. EPA's regulatory updates page confirms that when HFC leak repair was removed from Part 82 in 2020, the other duties stayed in place for HFCs and other non-exempt substitutes:

• Certification for anyone who could violate the integrity of the refrigerant circuit (40 CFR 82.161)
• No venting of ozone-depleting or non-exempt substitute refrigerants during service, maintenance, repair or disposal (40 CFR 82.154(a))
• Evacuation to the Table 1 levels, or the small-appliance percentages, with certified recovery equipment before opening or disposing (40 CFR 82.156 and 82.158)
• The sales restriction: refrigerant is sold only to certified technicians and their employers, with narrow exceptions (40 CFR 82.154(c))
• Leak repair for ozone-depleting refrigerants in appliances with 50 or more pounds (40 CFR 82.157)
• Disposal records for appliances holding more than 5 and less than 50 pounds, kept three years (40 CFR 82.156(a)(3))

The EPA 608 numbers guide lists the evacuation levels and leak-rate triggers behind these duties.

HFC leak repair under 40 CFR Part 84, in force since January 1, 2026

Section 84.106 applies to appliances with a full charge of 15 pounds or more of an HFC, or of a substitute with a global warming potential above 53. It does not apply to residential and light commercial air conditioning and heat pumps, or to appliances that contain only an ozone-depleting refrigerant, which stay under Part 82.

The percentages match the Part 82 triggers in the Type II and Type III test topics. Only the charge size (15 pounds instead of 50) and the refrigerants covered differ. Those Part 82 triggers are the ones the EPA 608 flashcards planned for launch drill by appliance type.

What it means for the technician on site:

• Documentation after each service on a covered appliance. Anyone adding or removing refrigerant must give the owner or operator a record of the appliance, date, parts serviced, type of service, the technician's name, and the amount and type of refrigerant (84.106(b) and (l)(4))
• Leak inspections and repairs by a certified technician. Over the trigger rate, leaks must be found and repaired within 30 days (120 days if an industrial process shutdown is needed), with an initial and a follow-up verification test
• Paperwork for inspections and tests. The technician who performs a leak inspection or verification test must hand the owner documentation of the date, methods, leak locations and results (84.106(l)(5) and (l)(7))
• Follow-up inspections. After a repair, quarterly inspections for commercial and industrial process refrigeration with 500 pounds or more, and annual inspections for smaller systems and comfort cooling, until the leak rate stays under the trigger
• Chronic leakers. Appliances of 15 pounds or more that leak 125% of their full charge in a calendar year must be reported to EPA by March 1 of the next year

January 1, 2027: automatic leak detection deadline

Section 84.108 requires automatic leak detection (ALD) on commercial and industrial process refrigeration appliances with a full charge of 1,500 pounds or more of a refrigerant containing an HFC, or a substitute with a GWP above 53:

A system that senses refrigerant in air must detect 10 parts per million and alert at 100 parts per million. A system that monitors the appliance's conditions must alert at a loss of 50 pounds or 10% of the full charge, whichever is less. ALD must be audited and calibrated every year, and records are kept three years. EPA's fact sheet for the rule lists the same January 1, 2027 date.

ALD itself is not a Section 608 test topic, but leak detection is: EPA's Type II and Type III topics cover the signs of a leak, the preferred leak-test gases and pressurizing methods, which EPA 608 prep covers test by test.

January 1, 2027: installation limits under the Technology Transitions rule

Section 84.54(c) bars installing certain new systems that use higher-GWP refrigerants, and several limits start on January 1, 2027. The restriction applies to whoever installs the system and to its designer, owner or operator. Some field work counts as an installation, such as assembling a system for the first time from new or used parts, or raising a supermarket system's cooling capacity by more than 15%.

The supermarket limit is 1,400 because of EPA's May 26, 2026 final rule (effective July 27, 2026), which raised it from 150 or 300 until January 1, 2032. The same rule removed the installation deadline for residential and light commercial AC and heat pump systems whose components were made or imported before January 1, 2025, so that inventory may still be installed in 2027.

Reclaimed refrigerant and cylinders: the dates around 2027

• Since January 1, 2026: refrigerant sold as reclaimed may contain no more than 15% virgin HFC by weight, and certified reclaimers label containers to say so (84.112)
• February 14, 2027: reclaimers, distributors and wholesalers report 2026 sales of reclaimed HFCs for supermarkets, refrigerated transport and automatic commercial ice makers. This duty is theirs, not the technician's
• January 1, 2028: a used disposable cylinder that still holds HFC and will not be used again must go to a certified reclaimer, a refrigerant supplier, or a final processor that can remove the heel. The alternative is for a certified technician to evacuate it to 15 inches of mercury vacuum and give the final processor a signed statement (84.116). Small cans of 2 pounds or less that qualify for the vehicle AC exemption are excused from these disposal steps
• January 1, 2029: servicing and repair of supermarket systems, refrigerated transport and automatic commercial ice makers that contain HFC must use reclaimed refrigerant (84.112(e))

Supply is the background to all of this. HFC production and consumption are capped at 60% of the baseline from 2024 through 2028 and drop to 30% in 2029 (40 CFR 84.7).

Proposed, not final: the transport refrigeration exemption

On May 26, 2026, EPA proposed exempting all road and intermodal container transport refrigeration units from HFC leak repair, saying it never intended to cover them. Comments closed July 10, 2026. As of October 25, 2026, no final rule appears in the Federal Register, so the text of 84.106 in force today, which lists refrigerated transport appliances among those with a 10% trigger, is the rule to follow until EPA finalizes a change.

Using these EPA rules alongside your 608 prep

If you are still preparing for the test, keep the split clear: the EPA 608 practice questions and the EPA 608 study plan cover the Section 608 tests, and this page covers the job. If you have not chosen your type yet, the EPA 608 certification types guide maps equipment to Type I, II, III or Universal.

Full EPA 608 prep on Passy is marked "At launch" with no checkout open as of October 25, 2026, so it cannot be used yet. You can see what full EPA 608 prep will cover at launch and come back to these rules when you start work.