EPA Refrigerant Recovery Rules

No one maintaining, servicing, repairing or disposing of an appliance may knowingly vent or otherwise release refrigerant into the environment (40 CFR 82.154(a)(1)). The Clean Air Act ban took effect on July 1, 1992, for CFCs and HCFCs, and on November 15, 1995, for their substitutes (Clean Air Act section 608(c), as described in EPA's 2016 rule, 81 FR 82272). The ban covers CFCs, HCFCs and non-exempt substitutes, which includes HFCs such as R-134a and R-410A. Venting refrigerant after it has been recovered, for example by emptying a recovery cylinder, is also a violation (40 CFR 82.154(a)(3)).

A short list of substitutes is exempt, but only in specific end-uses. These include carbon dioxide, nitrogen and water in any application, ammonia in commercial or industrial process refrigeration and absorption units, and certain hydrocarbons in listed equipment. Outside the listed end-uses, the ban applies to them too (40 CFR 82.154(a)(1)).

You also may not service or dispose of an appliance without following the required practices, and without recovery equipment certified for that refrigerant and appliance type (40 CFR 82.154(b)).

Small releases made during a good-faith attempt to recover or recycle refrigerant are called de minimis and are not violations. A release counts as de minimis only when you are doing everything else right: following the evacuation and disposal practices, using certified recovery equipment, being properly certified, and following the reclamation requirements. For ozone-depleting refrigerants, you must also be following the leak repair practices (40 CFR 82.154(a)(2)).

A typical example is the small amount lost when you disconnect hoses fitted with the low-loss fittings that certified recovery equipment must have (40 CFR 82.158(d)(7)). Deliberately purging a hose with refrigerant or cracking a valve to 'see what's in there' is not de minimis.

Before opening or disposing of an appliance other than a small appliance or MVAC, you must recover the refrigerant, including all liquid, to the level in Table 1. You must use certified recovery equipment and verify the level before opening (40 CFR 82.156(a)). You may evacuate just the part being serviced if its refrigerant can be isolated to a system receiver. The level depends on the pressure class, the charge size, and when your recovery equipment was made.

• Leaky appliances: if leaks make the Table 1 level unattainable, or reaching it would badly contaminate the refrigerant, isolate leaking from non-leaking parts where possible. Evacuate the non-leaking parts to Table 1, and the leaking parts to the lowest level you can reach without contaminating the refrigerant, never above 0 psig (40 CFR 82.156(a)(2)).
• Non-major repairs not followed by evacuation to the atmosphere: evacuate medium-, high- and very high-pressure appliances to no higher than 0 psig before opening. Pressurize low-pressure appliances to no higher than 0 psig, using heat rather than nitrogen where the rule requires it (40 CFR 82.156(a)(1)).
• Oil changes: evacuate or pressurize to no higher than 5 psig before opening, or drain the oil into a system receiver brought to that pressure (40 CFR 82.156(a)(1)(iii)).
• A major repair means removing the compressor, condenser, evaporator or an auxiliary heat exchange coil, or uncovering an opening of more than 4 square inches of flow area for more than 15 minutes (40 CFR 82.152).

Small appliances are products fully manufactured, charged and hermetically sealed at the factory with 5 pounds or less of refrigerant (40 CFR 82.152). Recovery from them is measured as a percentage of the charge (40 CFR 82.156(b)):

Self-contained recovery equipment has its own means, usually a compressor, to remove refrigerant without help from the appliance. System-dependent, or 'passive', equipment relies on components in the appliance, such as its own compressor or the pressure in the system (40 CFR 82.152).

System-dependent equipment may not be used on appliances with a full charge of more than 15 pounds, unless it is permanently attached to the appliance as a pump-out unit (40 CFR 82.156(e)). Owners who service only their own appliances that have pump-out units do not need certified self-contained equipment (40 CFR 82.156(f)).

Whatever you use, follow the manufacturer's directions unless they conflict with the regulation (40 CFR 82.156(g)).

Recovery and recycling equipment must be certified by an EPA-approved equipment testing organization as able to reach the required evacuation levels (40 CFR 82.158). Equipment made or imported before November 15, 1993, is treated as certified if it can reach the levels in Table 2 of §82.158. Newer equipment is tested to AHRI Standard 740. Equipment for flammable refrigerants is tested under appendix B4, which adds UL 1963 Supplement SB.

Certified equipment carries a permanent label naming the testing organization and the appliance category it is certified for, with the date of manufacture and serial number (40 CFR 82.158(h)). It must have low-loss fittings on all hoses. If it has a noncondensables purge, that purge may release no more than 3 percent of the refrigerant being recycled (40 CFR 82.158(d)). Altering a certified design so it no longer meets the standard makes it uncertified (40 CFR 82.158(b)).

For small appliances, equipment must be certified to recover 90 percent with the test stand's compressor running and 80 percent with it off, or to reach a 4-inch vacuum (40 CFR 82.158(e)).

The three Rs are defined in 40 CFR 82.152 and turn up on every Core test:

• Recover: remove refrigerant in any condition from an appliance and store it in an external container, without necessarily testing or processing it.
• Recycle: extract refrigerant and clean it for reuse in equipment of the same owner, usually by oil separation and filter-driers, without meeting all the reclamation requirements.
• Reclaim: reprocess refrigerant to the purity specifications in appendix A of Subpart F, based on AHRI Standard 700-2016, and verify it by the prescribed lab analysis.
• Recovered refrigerant may go back into the same appliance, or another appliance with the same owner, without recycling or reclaiming (40 CFR 82.156(h)). If it changes owners, it must be reclaimed by an EPA-certified reclaimer first (40 CFR 82.154(d)).
• Certified reclaimers may release no more than 1.5 percent of the refrigerant during reclamation (40 CFR 82.164(a)(3)). Since January 1, 2026, refrigerant sold as reclaimed may contain no more than 15 percent virgin HFC by weight (40 CFR 84.112).

Equipment dismantled on site, such as chillers, central residential air conditioning, retail food refrigeration and industrial process refrigeration, must have its refrigerant recovered to the servicing levels before disposal (EPA: Safe Disposal Requirements). Technicians who recover refrigerant to dispose of appliances holding more than 5 and less than 50 pounds must keep records for three years (40 CFR 82.156(a)(3)). The records cover the company name, the appliance location, the date, the refrigerant type, monthly totals, and transfers for reclamation or destruction.

Small appliances, MVACs and MVAC-like appliances usually reach the scrap yard or landfill with the charge still inside. The final processor must either recover the refrigerant or get a signed statement or contract showing it was recovered. A signed statement must give the name and address of the person who recovered it and the date. Those statements are kept for three years (40 CFR 82.155). People recovering refrigerant from these appliances for disposal don't need to be certified, but their equipment must meet the same standards as servicing equipment.

Refrigerant containing a CFC or HCFC, and since January 1, 2018 any non-exempt substitute, may only be sold to a certified technician or to an employer who proves it employs one (40 CFR 82.154(c)). Section 609 MVAC technicians may buy only refrigerant acceptable for MVACs. Small cans of MVAC refrigerant, 2 pounds or less with a unique fitting and a self-sealing valve, are the main exception. Sellers must keep invoices showing the buyer, date and quantity for three years.

EPA's Q&A adds two points. You cannot use your card to buy refrigerant for someone who is not certified. And you cannot sell refrigerant you recovered from customers' equipment unless it has been reclaimed.