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EPA Requirements for Purchasing Refrigerants in the United States
Last updated: August 16, 2026
Refrigerant sales in the United States are regulated under the Clean Air Act. The rules apply to in-person and online sales, and they cover many ozone-depleting refrigerants as well as non-ozone-depleting substitutes such as HFCs and HFOs.
For most full-size cylinders, a seller must verify that the purchaser is properly certified or is buying on behalf of an employer that employs a properly certified technician. The type of certification must match the intended application.
Important: Placing an online order does not remove certification requirements. EPA states that online sellers are subject to the same verification and recordkeeping rules as in-person sellers.
Who May Purchase Refrigerant?
Stationary HVAC and Refrigeration: Section 608
EPA generally allows the following purchasers to buy refrigerant intended for stationary refrigeration and air-conditioning equipment:
- A technician who holds the appropriate EPA Section 608 certification
- An employer of a Section 608-certified technician
- An authorized representative of that employer when the required documentation is provided
Only Section 608-certified technicians may purchase refrigerants intended for stationary equipment. A Section 609 certification alone does not authorize the purchase of stationary refrigerants such as R-22.
Motor Vehicle A/C: Section 609
Technicians certified under Section 609—and qualifying employers or authorized representatives—may purchase refrigerants found acceptable for motor vehicle air-conditioning applications. Section 609 addresses MVAC service, not stationary HVAC or commercial refrigeration.
What Documentation May Be Requested?
For a technician purchase, the seller may request a clear copy of the Section 608 or Section 609 certification card or certificate. When a company purchases on behalf of an employee, the seller may request:
- Evidence that the company currently employs a properly certified technician
- A copy of that technician’s certification
- The name of the company or purchasing account
- Identification of people authorized to purchase or receive refrigerant for the company
The seller is responsible for determining that a person claiming to represent a refrigerant purchaser is authorized. A company should notify its supplier if the certified technician used for the account is no longer employed.
Small-Can MVAC Exception
EPA provides a limited exception for small cans of non-exempt substitute refrigerant intended for MVAC use. Containers designed to hold two pounds or less may be sold without technician certification when they use the required unique fitting and a self-sealing valve.
This exception does not apply to full-size cylinders and does not authorize a Section 609-certified purchaser to buy refrigerant intended for stationary equipment. The product must still be acceptable and appropriate for the vehicle being serviced.
Online Refrigerant Sales
EPA’s online-sales guidance is direct: the same purchaser-verification and recordkeeping requirements apply online. A compliant checkout process should not rely only on a customer checkbox. The seller must verify certification or qualifying employer documentation and retain the required records.
For a professional online store, a typical verification workflow includes:
- The customer places an order and identifies the intended application.
- The customer submits a Section 608 or Section 609 certificate, or employer documentation.
- The seller verifies that the certification category matches the refrigerant’s intended use.
- The seller retains the required purchaser and transaction records.
- The order is released for compliant shipment after verification.
Seller Recordkeeping Requirements
EPA requires refrigerant vendors to retain invoices showing:
- The purchaser’s name
- The date of sale
- The quantity of refrigerant purchased
If someone other than the technician completes the purchase, the seller must also retain the documentation demonstrating that the buyer employs at least one certified technician. EPA states that these records must be kept for three years from the date of sale.
EPA’s current retailer guidance also explains when copies of technician certifications or reseller statements should be kept. Sellers should review the official page when designing record-retention procedures.
Purchases for Resale
A wholesaler or distributor purchasing refrigerant for resale is treated differently from a service technician buying it for use. The upstream seller remains responsible for establishing that the buyer falls within an allowed category. EPA recommends obtaining a signed statement that refrigerant purchased for resale will ultimately be sold to certified technicians.
Used Refrigerant Cannot Be Sold as New Product
EPA prohibits the sale of used refrigerant for use in another owner’s appliance unless the refrigerant has been reclaimed by an EPA-certified reclaimer. Recovered refrigerant may have contamination or mixed composition and should be handled through an appropriate reclaimer or distributor.
Buyer Checklist Before Ordering
- Confirm whether the refrigerant is for stationary equipment or MVAC service.
- Confirm that your Section 608 or Section 609 basis matches that application.
- Prepare a clear certification copy or employer documentation.
- Verify the equipment nameplate and exact refrigerant designation.
- Review container size, shipping limitations and delivery requirements.
- Do not ask another person to use a certification unrelated to your employment or work.
Frequently Asked Questions
Can a company purchase refrigerant if the owner is not certified?
Generally, yes, if the company currently employs a properly certified technician and provides the seller with acceptable evidence. An authorized representative may complete the transaction under the company’s qualifying account.
Can a Section 609 technician buy R-22?
Not for stationary equipment. EPA specifically explains that Section 609 technicians may not purchase R-22; stationary refrigerant purchases require the appropriate Section 608 basis.
Can full-size R-134a or R-1234yf cylinders be sold without certification?
The small-can MVAC exception is limited to containers designed to hold two pounds or less that meet the fitting and self-sealing requirements. Full-size cylinders remain subject to the sales restriction.
Do online sellers have to verify certification?
Yes. EPA states that online refrigerant sales have the same verification and recordkeeping requirements as in-person sales.
How long must sales records be kept?
EPA requires the applicable refrigerant-sales records to be kept for three years from the date of sale.
Cool Gas Depot provides refrigerants for professional HVAC, automotive A/C and commercial refrigeration applications. Review our EPA Requirements page and prepare the appropriate certification documentation before ordering.
Legal notice: This article is educational, not legal advice. EPA rules, interpretations and state requirements can change. Consult the current regulations, official EPA guidance and qualified counsel when designing a compliance program.
R-22 Refrigerant
R-1234yf Refrigerant