EPA Guidelines

📜 U.S. EPA Refrigerant Sales Guidelines and Requirements

This page provides an overview of the mandatory sales restrictions set by the U.S. Environmental Protection Agency (EPA) under Section 608 and Section 609 of the Clean Air Act (40 CFR Part 82, Subpart F). Dana Home strictly adheres to these Federal requirements.

1. Requirements to Purchase Regulated Refrigerant

The ability to purchase refrigerant is determined by the buyer’s EPA certification and the intended use of the equipment (stationary vs. motor vehicle).

A. Purchase of Any Ozone-Depleting or Substitute Refrigerant (General)

The following parties can generally buy any type of regulated refrigerant:

Section 608 Certified Technicians: Individuals who have earned the EPA Section 608 Technician Certification (Type I, II, III, or Universal).
Employers of Section 608 Certified Technicians: An employer (or their authorized representative) if they provide written evidence to the wholesaler that they employ at least one properly certified technician.

B. Purchase of Refrigerant for Motor Vehicle Air Conditioners (MVAC)

The following parties can buy refrigerant that has been found acceptable for use in MVACs (e.g., certain R-134a products):

Section 609 Certified Technicians: Individuals who have earned the EPA Section 609 Technician Certification.
Employers of Section 609 Certified Technicians: An employer (or their authorized representative) if they provide written evidence to the wholesaler that they employ at least one properly certified technician.

C. Critical Distinction: Stationary vs. MVAC Use

Refrigerant Intended Use	Required Certification	Restriction
Stationary Equipment (HVAC, Chillers)	Section 608 Certified Technicians ONLY.	Section 609 certified technicians cannot purchase refrigerants intended for stationary equipment (e.g., R-22, R-404A), regardless of the container size.
MVAC (Motor Vehicle Air Conditioners)	Section 609 Certified Technicians OR Section 608 Certified Technicians.	Purchases must comply with both the 608 and 609 requirements.

D. Exemption for DIY Use (Small Cans)

An exemption exists for the general public regarding small cans of non-exempt MVAC refrigerant:

Containers designed to hold two pounds or less of MVAC refrigerant (such as certain R-134a products) that feature unique fittings and self-sealing valves can be sold to uncertified persons for Do-It-Yourself (DIY) use on their vehicles.

2. Wholesaler Responsibilities in Selling Refrigerant

As a wholesaler, Dana Home maintains the following mandatory and recommended practices to ensure compliance:

Mandatory Record-Keeping

We are required to retain sales invoices indicating the following information:

The name of the purchaser.
The date of sale.
The quantity of refrigerant purchased.

Verification and Authorization

Legal Responsibility: Dana Home is legally responsible for ensuring that all customers fit into one of the allowed categories of purchasers under the sales restriction.
Authorized Representatives: We must determine whether persons who claim to represent a purchaser (e.g., an employee buying for a company) are indeed authorized representatives.
Resale to Others (Recommended): If refrigerant is purchased for the purpose of resale, we follow the EPA recommendation to obtain a signed statement from the purchaser indicating that they are purchasing the refrigerant only for eventual resale to certified technicians.