EPA 608 requirements for HVAC companies: certification and records

EPA 608 requirements for HVAC companies come down to four duties. Every technician who could open a refrigerant circuit needs Type I, II, III or Universal certification from an EPA-approved certifying program. Each tech keeps a copy of that certificate at your place of business. Uncertified apprentices work only under close, continual supervision. And refrigerant may be sold only to a certified tech or a company that employs one.

On top of that, since January 1, 2026, a separate EPA leak repair rule covers many commercial and industrial systems holding 15 pounds or more of an HFC or HFC substitute with a GWP above 53, though not residential or light commercial AC. LMS Advisor, our top pick for running the training side, does not issue 608 cards (no LMS can). What it does is run the company routine around them: a prep course, proctored practice exams in the Test Center, and an annual refrigerant handling refresher assigned with a due date, so the overdue report shows who is behind.

Who needs EPA 608 certification?

Anyone on your payroll who might break into a refrigerant circuit. The rule at 40 CFR 82.161 says "any person who could be reasonably expected to violate the integrity of the refrigerant circuit during the maintenance, service, repair, or disposal of appliances" must pass a certification exam. That covers installers who braze line sets, service techs who put gauges on a system, and whoever recovers refrigerant before a unit is scrapped. It usually does not cover a CSR, a dispatcher or a helper who only carries equipment.

The rule has been broad for years. EPA's certification requirements page notes that it covers technicians handling ozone-depleting refrigerants and, after January 1, 2018, substitute refrigerants too. So the R-410A and R-454B techs are in scope, not only the ones still working on old R-22 equipment.

Type I, II, III and Universal

Certification is by equipment type, so the card has to match the work the tech does:

• Type I: small appliances, such as window units, domestic refrigerators and dehumidifiers.
• Type II: high-pressure and very high-pressure appliances, which covers most residential split systems, heat pumps and commercial rooftop units (small appliances and motor vehicle AC excluded).
• Type III: low-pressure appliances, mostly centrifugal chillers.
• Universal: all of the above.

A residential service company can run on Type II, while chiller work needs Type III. A tech with only a Type I card should not be sent to recover refrigerant from a rooftop unit, and that mismatch is one of the first things to look for when you audit your roster.

Registered apprentices under close supervision

There is one exemption, and it is narrower than many shops assume. Under 82.161, apprentices are exempt "provided the apprentice is closely and continually supervised by a certified technician" while doing work that could release refrigerant. The definition in 40 CFR 82.152 matters here: an apprentice is a person "currently registered as an apprentice" with the U.S. Department of Labor's Office of Apprenticeship or a recognized State Apprenticeship Council.

So a new hire you call an apprentice is not automatically covered. If they are not in a registered program, they need their own card before they touch a refrigerant circuit. And "closely and continually" means the certified tech is on that job, not two stops away on the phone. EPA's Section 608 questions and answers repeat the point: apprentices can work before certification "if they are closely and continuously supervised by a technician that has the appropriate section 608 certification(s)." The supervisor's card has to cover the equipment type as well.

How do technicians get EPA 608 certified?

By passing a test from an EPA-approved certifying program. EPA does not issue certification cards. The card comes from the EPA-approved certifying organization that ran the test, and EPA keeps a list of approved Section 608 certifying programs (last updated August 20, 2026 when we checked).

Closed-book tests, photo ID and a 70 percent pass mark

The program standards sit in Appendix D to Subpart F of Part 82. The Type II, Type III and Universal tests are closed-book. Proctors "are required to verify the identity of individuals taking the test by examining photo identification." The passing score is 70 percent, with 84 percent for a mail-in Type I test. Certifying programs keep the names, scores, dates and locations of every test indefinitely.

Can the EPA 608 exam be taken online?

Yes, through some programs. EPA's program list notes that some programs "offer remote or online testing." As of September 2026 it shows ESCO Institute and Mainstream Engineering with "Remote testing available" and SkillCat with "Online testing only," among others. The remote exam is still run and proctored by that program. A practice quiz in your own LMS, however well proctored, is preparation, not certification.

How do you verify a technician's EPA 608 certification?

Ask for the card, note the issuing program, then check that program's public list. Since January 1, 2018, 82.161 has required certifying programs (other than federally run ones) to publish online a list of technicians they certified on or after January 1, 2017, updated at least annually. The list shows the name, city, certification type and date. Technicians can opt out, so a missing name is a reason to ask, not proof of fraud.

1. Get a copy of the card at hire. Front and back, with the certification type, certification number and the program's name.
2. Check the program's public list. Search by name and city. Techs certified before 2017 may not appear, so for them the card itself is the evidence.
3. Match the type to the job. Record Type I, II, III or Universal on the employee file, and dispatch accordingly.
4. Handle lost cards through the issuer. EPA does not issue cards, so a replacement comes from the certifying organization named on the original card.

EPA's requirements page also says Section 608 credentials "do not expire." That makes the one-time check at hire the most important step. Nobody will prompt you later.

What records do HVAC companies and technicians have to keep?

Most of the 608 paperwork belongs to specific people: the tech, the certifying program, the equipment owner. Here is who owns what, as of September 2026.

Role	Requirement	Source
Technician	Pass a certification exam for the equipment type they work on	40 CFR 82.161
Technician	Keep a copy of the certificate at the place of business, until three years after they stop working as a technician	40 CFR 82.161
Apprentice	Work only under close and continual supervision of a certified tech, and be registered with DOL or a recognized state council	40 CFR 82.161, 82.152
Certifying program	Publish an online list of certified techs and keep test records indefinitely	40 CFR 82.161, Appendix D
Refrigerant seller	Sell only to certified techs or companies that employ them	EPA Q&A
Owner or operator of 15 lb+ HFC equipment (not residential or light commercial AC)	Leak repair duties and three years of records from January 1, 2026	40 CFR Part 84 fact sheet

Certificate copies at the place of business

82.161 says technicians "must keep a copy of their certificate at their place of business" and "must maintain a copy of their certificate until three years after no longer operating as a technician." In practice the company keeps the file. Store a scanned copy in your HR or document system and set your retention so it survives the tech leaving. Our training records retention table lines this up against other US rules if you are writing one policy for everything.

Service invoices and leak inspection records

For larger systems the tech also owes the customer paperwork. EPA's recordkeeping summary for stationary refrigeration says technicians servicing appliances with 50 or more pounds of ozone-depleting refrigerant must give the owner an invoice showing the amount of refrigerant added, plus records of leak inspections and verification tests. Owners of those systems keep servicing records with the date, type of service and quantity added. For disposal of appliances holding 5 to 50 pounds, the technician keeps recovery records such as location, date, refrigerant type and monthly totals.

Refrigerant purchases

The sales restriction is the one that hits the counter. EPA's Q&A says it is a violation "to sell, distribute, or offer for sale or distribution a refrigerant for use in an appliance, unless the recipient is, or employs, a certified technician." Distributors will ask for a card.

What changed on January 1, 2026?

A new leak repair program under the AIM Act started. It lives in 40 CFR Part 84, Subpart C, not in the 608 rules, but it lands on the same techs. EPA's leak repair fact sheet from January 2026 sets out the scope.

HFC leak repair at 15 pounds

The rule covers appliances with a full charge of 15 pounds or more of an HFC or HFC substitute with a GWP above 53. Leak rate thresholds are 30 percent for industrial process refrigeration, 20 percent for commercial refrigeration and 10 percent for comfort cooling. "Beginning January 1, 2026, owners or operators and certified technicians must comply."

Residential and light commercial AC is not covered

This is the part many articles get wrong. The fact sheet says: "Refrigerant-containing appliances used in the residential and light commercial air conditioning and heat pumps subsector are not covered under these requirements." A 5-ton split system in a house or a small office is outside this rule no matter the charge. A supermarket rack, a walk-in cooler system or a large comfort cooling chiller with 15 pounds or more of HFC can be inside it.

Owner records for three years

Owners or operators keep the required records for three years, according to the fact sheet. Your techs create much of the source data (charge added, leak inspection results, verification tests), so train them to write it down the same way on every call.

How to build an internal 608 compliance routine

None of this is hard. It slips because nobody owns it, and because a card that never expires never forces a second look. Here is the routine we would set up for a contractor with several branches:

1. Collect a copy of every tech's 608 card at hire, before their first call.
2. Record the certification type and certifying program on the employee file.
3. Check new hires against the certifying program's public list.
4. For each apprentice, confirm DOL or state registration and name the certified supervisor.
5. Store card copies at the place of business and keep them three years after a tech leaves.
6. Train every tech yearly on recovery, the venting prohibition and your job paperwork.
7. List which customer systems fall under the 2026 leak repair rule.
8. Give owners the refrigerant added and leak inspection records the rules call for.
9. Review the whole roster once a year, branch by branch.

Steps 1 to 5 are HR and dispatch work. Step 6 is where training software earns its place, and it is the step that usually lives in someone's head. For the wider picture of running tech training across locations, see our guide to HVAC technician training software for contractors with many branches.

How to run 608 training in LMS Advisor

LMS Advisor is our platform, so weigh that, but here is how we would set up the training side of a 608 routine in it. The card itself stays with the certifying program and your HR file. LMS Advisor handles the preparation, the refreshers and the evidence that they happened.

• Prep before the real exam. A 608 prep course with required blocks and a lesson minimum time, followed by practice exams in the Test Center. Build them from question pools, and use image hotspot items that ask a tech to tap the right port or valve on a photo.
• Closed-book practice that is actually closed-book. Native proctoring adds fullscreen lockdown, ID photo capture, webcam snapshots and AI face monitoring, so a practice score means something before you pay for the certifying exam.
• Annual refresher. A recovery and venting course assigned to every tech with a due date and a mandatory flag. It issues a course certificate with a 12-month validity, which shows an expiring-soon status in the last 30 days (see certificates and compliance).
• By branch. Branches and groups mirror your locations, and the overdue report and CSV, Excel or PDF exports show who is late where.
• Techs without email. Phone login by one-time code over SMS or WhatsApp, and lessons in Spanish through course translations.

The limits, plainly: LMS Advisor is not an EPA-approved certifying program and cannot issue 608 cards, it has no ready-made 608 course (you bring or build the content), and we would keep scanned cards in your HR or document system rather than the LMS. If you want a certifying program with its own course library, SkillCat or ESCO fit that job better. See our HVAC training software page for the full setup, or book a demo and we will build a sample refresher with you.

Frequently asked questions

Does EPA 608 certification expire?

No. EPA's certification requirements page says Section 608 credentials do not expire. That is why the company check at hire matters, and why many contractors add their own yearly refresher on recovery and venting rules.

Can an uncertified apprentice work on refrigerant circuits?

Only a registered apprentice, and only under close and continual supervision by a technician with the right 608 certification. The apprentice must be currently registered with the Department of Labor's Office of Apprenticeship or a recognized State Apprenticeship Council. An unregistered helper needs their own card first.

How do I look up a technician's EPA 608 certification?

Check the public list published by the certifying program named on the card. Programs have had to publish lists of techs certified on or after January 1, 2017, though techs can opt out. For older certifications, the card and the issuing program are your evidence.

Is the EPA 608 test open book?

The Type II, Type III and Universal tests are closed-book and proctored, with photo ID checks and a 70 percent passing score. A mail-in Type I test has an 84 percent passing score.

Does the 2026 leak repair rule apply to residential AC?

No. EPA's January 2026 fact sheet says appliances in the residential and light commercial air conditioning and heat pumps subsector are not covered. The rule applies to other appliances with 15 pounds or more of HFC refrigerant, such as commercial refrigeration and larger comfort cooling systems.

Can LMS Advisor issue EPA 608 certification cards?

No, only EPA-approved certifying programs can certify technicians. LMS Advisor runs your prep course, proctored practice exams and annual refresher, and shows by branch who has completed them. The 608 exam itself is taken with a certifying program such as ESCO, Mainstream Engineering or SkillCat.