EPA Refrigerant Sales Restriction

Quick Facts

What the Sales Restriction Does

The sales restriction in 40 CFR 82.154(c) limits who can buy refrigerant. Its purpose is to make sure the people handling refrigerant know how to recover it and avoid venting. Without it, anyone could top up a leaking system indefinitely.

For class I and class II refrigerants (CFCs and HCFCs such as R-22), the restriction has been in place since the 1990s. EPA’s 2016 update extended it to non-exempt substitutes, such as HFCs (R-410A, R-134a, R-404A) and many HFO blends, from 1 January 2018.

Who May Buy

In general, refrigerant for use in stationary appliances may be sold only to:

• Technicians certified under Section 608 (or Section 609 for MVAC refrigerant), or
• Employers who employ at least one certified technician, buying for that technician’s work, or
• Buyers for resale, such as distributors and wholesalers, who then sell only to eligible buyers.

There are specific provisions for appliance manufacturers and for refrigerant bought for use in production. The precise wording is in 82.154(c).

Key Exemptions

Small MVAC Cans

Containers of two pounds or less of non-exempt substitute refrigerant for motor vehicle air conditioning are exempt, provided the container has a unique fitting and, if manufactured or imported on or after 1 January 2018, a self-sealing valve meeting the performance criteria in 82.154(c)(2). This is why DIY car AC cans are still sold in auto-parts stores.

Exempt Substitutes

Some substitutes are exempt from the venting prohibition for particular end uses. Exempt substitutes in those uses aren’t subject to the same sales restriction. The list is limited and end-use specific, so check 82.154 rather than assuming.

Pre-Charged Appliances and Components

Fully assembled, pre-charged appliances such as window ACs can be sold to anyone. There are specific provisions for split-system components that come pre-charged, such as some mini-split line sets, where the seller or buyer must meet stated conditions about certified installation. Read 82.154(c) for the current requirements.

What Sellers Must Check

Refrigerant sellers must verify that a buyer is eligible. In practice wholesalers:

• Ask for a copy of the technician’s certification card, and often keep it on file.
• Record the employer if an employee is buying on behalf of a business.
• Obtain a statement from buyers purchasing for resale.

If you’ve lost your card, see EPA 608 Card Lookup and Replacement.

Online Sales

The restriction applies to online sellers too. Listings for refrigerant in containers above 2 lb (or MVAC cans without the required valve) are generally subject to the same certification checks. Sellers that skip verification risk enforcement.

Why It Appears on the Exam

The sales restriction is a Core topic. Typical questions ask:

• Which refrigerants are covered and since when.
• Who can buy and who must verify.
• The 2 lb MVAC exemption and self-sealing valve date.
• Whether venting rules and sales rules apply to HFCs (they do, unless exempt).

The EPA 608 Core Study Guide covers the venting ban that sits alongside the sales restriction.

The Bigger Picture: AIM Act Rules

Separate from Subpart F, EPA’s AIM Act rules in 40 CFR Part 84 are phasing down HFC production and restricting high-GWP HFCs in new equipment. Those rules affect which refrigerants are available, but they aren’t the same as the sales restriction. ACHR News has reported that the AIM Act requirements will not be on the 608 exam.

Common Misunderstandings

Practise the Rule

Sales restriction questions appear in the EPA 608 Core Practice Test (2027 Question Bank). Each explanation points to 82.154 so you can read the source text.

Practical Tips for Buying Refrigerant

• Carry proof. Keep a photo or PDF of your certification card on your phone. Most wholesalers will also keep a copy on file.
• Open an account. Wholesalers often set up a trade account linked to your certification and employer, which speeds up later purchases.
• Buying for your employer. If you’re buying on the company account, the business must employ a certified technician who will use the refrigerant.
• Name changes. If your card shows a former name, carry supporting documents or ask your program to reissue it.

If you can’t find your card, contact the program that tested you before your next order.

For Homeowners

The sales restriction means homeowners generally can’t buy refrigerant for home AC or heat pumps. That’s intentional: adding refrigerant without finding and fixing the leak just releases more to the atmosphere. A certified technician should diagnose the leak, repair it where possible, then charge the system. Homeowners can still buy exempt small MVAC cans for car AC, provided the cans meet the 2 lb and self-sealing valve conditions.

For Sellers

If you sell refrigerant, build verification into your process:

1. Ask for proof of certification for any restricted refrigerant sale.
2. Record the certification number and program.
3. For business buyers, record which certified technician they employ.
4. For resale buyers, obtain a written statement that they’ll resell only to eligible buyers.
5. Keep records in line with your obligations under Subpart F.

Penalties

Selling or buying refrigerant in violation of the sales restriction is a Clean Air Act violation. EPA has brought enforcement actions against online sellers that sold restricted refrigerant without checking certification. Refer to EPA enforcement information for current penalty amounts rather than outdated figures.

Records Sellers Keep

Sellers need to verify that buyers are certified or otherwise allowed to buy, and they commonly keep a copy of the buyer’s certification or the relevant documentation. If you buy regularly from one wholesaler, they will usually keep your card on file so you don’t have to show it every time.