EPA Section 608 has 4 certification types and the credential does not expire once earned. What changed on 1 January 2026 is the equipment covered: leak repair rules now reach HFC appliances with a charge of 15 pounds or more, where the old rules started at 50 pounds of ozone-depleting refrigerant.
The short version
Certification is the easy part. A technician passes an EPA-approved test once and holds the credential for a working lifetime, because Section 608 technician certification credentials do not expire.
The part that catches service companies is everything around it. Who may buy a cylinder. What the customer's equipment obliges you to check. Which records exist if an inspector asks for them next year.
Those rules changed in 2026, and they changed in the direction of smaller equipment, which is exactly the size a commercial kitchen runs.
A walk-in cooler that was outside the leak rules in 2025 can be inside them in 2026.
Which 608 type does each technician need?
Four types, and the split is by the equipment, not by seniority.
| Type | Covers | In a commercial kitchen that means |
|---|---|---|
| Type I | Servicing small appliances | Undercounter units, some ice machines, sealed systems charged at the factory |
| Type II | Servicing or disposing of high-pressure and very high-pressure appliances, except small appliances and vehicle air conditioning | Walk-ins, reach-ins, remote condensing units, most of the kitchen |
| Type III | Servicing or disposing of low-pressure appliances | Rare in food service, common in large building chillers |
| Universal | All types of equipment | The practical answer for a technician who goes anywhere |
A technician who only ever opens sealed undercounter equipment can work on Type I. The moment they touch a walk-in, they need Type II. Most service companies train to Universal and stop having the conversation.
Who is allowed to buy the refrigerant?
This is the rule that surprises owners, because it governs purchasing rather than wrenching.
For stationary equipment, only Section 608 certified technicians can purchase refrigerant. An employer can also buy, as the employer of a certified technician, by giving the wholesaler written evidence that it employs one. A Section 609 credential, the vehicle air conditioning certification, does not allow the purchase of refrigerant for stationary equipment at any container size.
The wholesaler keeps an invoice showing the name of the purchaser, the date of sale and the quantity of refrigerant purchased. That invoice is a record of your company, held by somebody else, and it is the first place a question about refrigerant volumes will land.
The practical consequence for a growing service company: the letter naming your certified technicians at each supplier has to be current. A technician leaves, the letter is stale, and a purchase gets refused on a Saturday with a walk-in down.
What changed on 1 January 2026?
Two sets of rules now run in parallel, and the newer one reaches much smaller equipment.
| Ozone-depleting refrigerant, the older rules | HFC and substitutes, from 1 January 2026 | |
|---|---|---|
| Charge that triggers the rules | 50 pounds or more | 15 pounds or more, for refrigerants above a global warming potential of 53 |
| Commercial refrigeration leak rate | 20 percent a year | 20 percent a year |
| Comfort cooling and other appliances | 10 percent a year | 10 percent a year |
| Industrial process refrigeration | 30 percent a year | 30 percent a year |
| After the threshold is passed | Repair within 30 days, or a retrofit or retirement plan within 30 days completed inside a year | Repair and verify, plus leak inspections on a schedule set by charge size |
The thresholds did not move. The population of covered equipment did. A kitchen walk-in on an HFC blend with a 20 pound charge sat outside the 50 pound rule and sits inside the 15 pound one.
Residential and light commercial air conditioning and heat pump appliances are excluded from the newer leak repair requirements. Transport refrigeration has been the subject of a proposed exemption, so a service company working on road units should check the current status rather than assume either way.
What the inspection schedule looks like once a system leaks
Exceeding the leak rate is the event that starts the obligations. After that, the charge size sets the rhythm.
- 15 to 500 pounds, commercial refrigeration: annual leak inspections
- 500 pounds and above: quarterly inspections, unless qualifying automatic leak detection is fitted
- Every covered appliance: leaks repaired, then verified by follow-up tests
- Chronic leakers: an appliance that leaks 125 percent or more of its full charge in a calendar year is reported to EPA by 1 March of the following year
Read that last line twice. It is a reporting duty that falls on the owner or operator of the equipment, which is your customer, and the only party who holds the service history that proves the number is you.
What the service company has to be able to produce
Nothing in the rules asks for a particular software. They ask for facts that have to be retrievable later, per piece of equipment rather than per customer.
- Which technician holds which certification type, and the certificate itself
- Written evidence at each supplier that your company employs a certified technician
- Refrigerant added and recovered per visit, per appliance, with the date
- The full charge of the appliance, because every leak rate is a percentage of it
- Leak repairs with the verification test that followed them
- For a system on a retrofit or retirement plan, the plan and the dates in it
A service company that records refrigerant quantities in the notes box of a job can answer a question about one visit. It cannot add up a calendar year for one walk-in across 9 visits and 3 technicians, and that total is the number the rules are written around.
That is an equipment record problem rather than a compliance problem. The charge, the refrigerant type and every quantity added belong on the asset, not on the customer and not in a notes field.
Roopairs runs a product tour where you can see equipment records, service history per asset and job documentation in one place.
Keeping a crew current without a spreadsheet
The credential does not expire, which removes the renewal problem and creates a quieter one: nobody looks at the file again. Three things still move.
People move. A technician leaves and takes a certification number off the roster, and the supplier letter that names them is now wrong. New hires arrive uncertified and work under supervision while they test.
Equipment moves. A customer replaces an R-404A rack with a CO2 system and the technician who serviced it last year needs different training, not a different certificate.
Rules move. The 2026 change arrived with a compliance date and reconsideration requests in the same quarter. Somebody has to own the question of what applies today.
What service companies in the trade say
“We worked closely with the staff on setting up the system to meet our specific needs.” — Mel Rinehart, Rino Beverage Service
Also worth reading
- Refrigeration Service Management Software: How to Choose
- Equipment Records for Leased and Customer-Owned Equipment
- Technician Notes That Are Worth Reading Next Time
Frequently asked questions
Does EPA 608 certification expire?
No. Section 608 technician certification credentials do not expire. A technician passes an EPA-approved test once and holds the credential. What expires in practice is the paperwork around it, such as the letter at a supplier naming the certified technicians your company employs.
Which EPA 608 type do I need for a walk-in cooler?
Type II, which covers servicing and disposal of high-pressure appliances other than small appliances and vehicle air conditioning. Type I covers small appliances only. A technician who works across a whole kitchen is usually trained to Universal, which covers all types.
Can an uncertified technician buy refrigerant?
Not for stationary equipment. Only Section 608 certified technicians can purchase it, and an employer can purchase as the employer of a certified technician by giving the wholesaler written evidence of that employment. A Section 609 vehicle credential does not allow it at any container size.
What charge size do the HFC leak rules apply to?
From 1 January 2026, leak repair requirements apply to appliances with a charge of 15 pounds or more containing an HFC or certain substitutes with a global warming potential above 53. Residential and light commercial air conditioning and heat pump appliances are excluded.
What is the leak rate threshold for commercial refrigeration?
20 percent of the full charge over a 12 month period. Industrial process refrigeration is 30 percent and comfort cooling and other appliances are 10 percent. The percentage is of the appliance's full charge, which is why the full charge has to be recorded on the equipment itself.
Who reports a chronic leaker to EPA?
The owner or operator of the appliance, by 1 March of the following year, when it leaks 125 percent or more of its full charge in a calendar year. The service company usually holds the records that produce the number, which is why the reporting duty lands in a conversation with the customer.
What records should a service company keep per appliance?
Full charge, refrigerant type, every quantity added and recovered with its date and technician, leak repairs with the verification test that followed, and any retrofit or retirement plan. Held on the equipment record rather than the customer, because every threshold is calculated per appliance.
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