EPA Proposes 608 Requirement on HFCs

Towards the end of last year the Environmental Protection Agency proposed a new rule that would modify the current Refrigerant Sales Restriction. As it is today if you wish to purchase CFC or HCFC refrigerants such as R-12, R-22, or R-502 you would need to either be 609 or 608 certified with the Environmental Protection Agency. The goal of this was to prevent O-Zone damaging refrigerants such as CFCs/HCFCS out of the hands of laymen and to have them only be controlled by the fully trained technicians. This would prevent unnecessary leaks of chlorine into the environment and if there was a leak the person could be held accountable.

If you wanted to purchase or handle some of the newer alternative refrigerants such as R-134a, R-410A,  R-404A you would not need to be certified with the EPA. These refrigerants are known as HFCs and they do NOT contain chlorine and do not effect the O-Zone layer. That being said, HFCs are not perfectly friendly to the environment either. They have been found to have a high Global Warming Potential and when an HFC is leaked it gets trapped in the atmosphere and actively contributes to Global Warming.

The new proposed rule by the EPA would modify the current section 608 in the Federal Clean Air Act. The current rule reads that all refrigerants under class 1 and class 2 are strictly monitored and only 608 and 609 technicians can purchase and use.  Class 1 and 2 refrigerants include CFCs and HCFC refrigerants like R-12 and R-22. The EPA has proposed removing the words ‘Class 1’ and ‘Class 2’ from the restriction and replacing it with the word ‘Refrigerant.’ The full proposed rule can be found by following this link to the EPA’s site.

An excerpt is also posted below:

“To extend the sales restriction, EPA is proposing to remove references to class I and class II substances where appropriate in these provisions and to replace them with the term refrigerant, which EPA is proposing to amend in § 82.152 to include substitutes. To avoid confusion, EPA is proposing to add a provision specifically noting that the sales restriction does not apply to substitutes that are exempt from the venting prohibition. EPA is also proposing to amend the purpose and scope statements at § 82.150, both of which describe the sales restriction as only affecting class I or class II ODS. EPA is proposing to add the term substitutes to these purpose and scope statements to clarify that the sales restriction, as well as the other provisions of the rule, would apply to ODS and substitute refrigerants.”

This is a BIG change. If this proposed rule passes that means no more can the do-it-yourselfer purchase one or two cylinders of refrigerant to work on their home unit. If this rule passes that means the same record keeping requirements that are done for CFCs/HCFCS would have to be kept on HFCs and all other refrigerants. (Many of you may already be doing this though.)

To the EPA’s credit they did make a small exception for automotive applications. Non certified people will still be able to purchase refrigerant but only in two pound or less containers. On top of the two pound requirement the refrigerant can will also have to have a self sealing valve to reduce leaks. So, if you’re one of those guys who still likes to work on their own car than you are still in luck… for now.


It’s hard to say what impact this will have on the industry if the rule passes. On one hand it will damage the hands on do-it-yourselfer crowd who like to save money and tackle the projects on their own. On the other hand it will only help the HVAC business and contractors as with each year the ability to purchase refrigerant gets narrowed down to only an exclusive few. I can definitely see the markup on refrigerants moving much higher over the new few years after this rule passes.