Heads up. The AIM Act Part 84 leak-repair rules became effective on January 1, 2026. If your shop services in-scope HFC equipment, the recordkeeping workload can now start at a much lower charge threshold than the older Part 82 leak-repair rules. This is not legal advice. Always verify against the current eCFR (40 CFR Part 84) before relying on any specific rule.
If you've been running an HVAC shop for a while, "EPA Section 608" probably feels familiar: refrigerant leaks, certified technicians, recordkeeping. You learned it once, you live with it.
What's new is that there's now a second federal framework sitting beside it: the AIM Act, implemented under 40 CFR Part 84. As of January 1, 2026, a refrigerant job may need Part 84 leak-repair records while Section 608 service practices, certification, and other recordkeeping duties still matter. For contractors, the practical takeaway is simple: classify the unit first, then capture the service event with the right regulatory basis.
This post walks through what each rule covers, what changed in 2026, what you actually need to capture in the field per service event, and how to stay audit-ready without burying your techs in paperwork. If you'd rather skip the background and see how a software platform handles this workflow directly, jump to how TuffOps Comply supports Part 84 rollout.
Executive summary
| Question | Short answer for HVAC contractors |
|---|---|
| What changed in 2026? | Part 84 leak-repair rules took effect for covered refrigerant-containing appliances with a full charge of 15 lb or more. |
| Does Part 84 replace Section 608? | No. Section 608 still matters for technician certification, service practices, and Part 82 leak repair for covered ODS appliances. |
| What should shops do first? | Classify each unit by refrigerant, full charge, GWP, subsector, and ODS-only status before closing refrigerant work. |
| What records matter most? | Unit identity, service date, technician, refrigerant added or removed, leak-rate method, repair details, verification, and rule basis. |
The two frameworks, in plain English
For the software view of this workflow, see EPA AIM Act / Part 84 compliance software. TuffOps ties compliance events back to equipment history, technician certification, and records exports instead of leaving the work in spreadsheets.
Section 608 (40 CFR Part 82, Subpart F) — the "old" rule you already know
Section 608 of the Clean Air Act is the foundational refrigerant rule. It's been around for decades and covers:
- Technician certification. Anyone who could release refrigerant must be certified under Section 82.161 (Type I, II, III, or Universal).
- Service practices. Recovery before opening a system, evacuation requirements, leak inspection, etc.
- Leak repair. For appliances with a full charge of 50 lb or more, leaks above the threshold rate must be repaired within set timeframes.
- Recordkeeping. Service records, refrigerant added/recovered, leak rate calculations, and repair verification, typically retained for at least 3 years when the leak-repair rules apply.
For leak-repair recordkeeping, Part 82 is focused on larger appliances: 50 lb or more of Class I or Class II refrigerant, or a blend containing Class I or Class II refrigerant. Section 608 still matters more broadly for service practices and technician certification.
AIM Act / Part 84 (40 CFR Part 84, Subpart C) — the "new" rule effective 2026-01-01
The American Innovation and Manufacturing Act (AIM Act) authorized the EPA to phase down high-GWP HFCs and govern their servicing, repair, disposal, and installation. Part 84 Subpart C is the operational rulebook for HVAC contractors. Three things matter most for day-to-day operations:
1. Lower charge threshold (15 lb instead of 50 lb)
Where Part 82's leak-repair recordkeeping starts at 50 lb for covered ODS equipment, Part 84 leak repair starts at 15 lb for covered refrigerant-containing appliances. That can bring more mid-size commercial refrigeration, industrial process, comfort cooling, refrigerated transport, and other equipment into the compliance workflow.
EPA basis: 40 CFR 84.106(a) applies Part 84 leak repair to refrigerant-containing appliances with a full charge of 15 or more pounds when the refrigerant is a regulated substance or a covered substitute. 40 CFR 82.157(a) applies Part 82 leak repair to appliances with a full charge of 50 or more pounds of Class I or Class II refrigerant, or a blend containing one.
2. GWP > 53 captures many modern HFC blends
Part 84 covers refrigerants that are either (a) regulated substances under the AIM Act or (b) substitutes with a Global Warming Potential greater than 53. That second condition matters because it can sweep in many common HFC blends contractors service today: R-410A, R-404A, R-407C, R-134a, R-32, and many replacements.
If you serviced it with a non-CO2, non-ammonia, non-hydrocarbon refrigerant, treat it as a unit that needs classification before the job is closed.
3. Two important carve-outs
Not every appliance is in scope. Two carve-outs to know:
- RLCA (Residential and Light Commercial AC/HP). Equipment in the residential and light commercial air conditioning and heat pump subsector is carved out of Part 84's leak-repair obligations. This is the carve-out that keeps many residential service calls outside the new leak-repair rules. Important: the carve-out is per-unit and depends on subsector classification, so it is not a blanket "residential is exempt" rule. Document the determination on each unit.
- ODS-only appliances. Equipment containing solely listed ozone-depleting substances (like R-22) as refrigerant is exempted from Part 84 specifically. Part 82 may still govern the R-22 service event.
EPA basis: 40 CFR 84.106(a)(3) excludes ODS-only appliances and refrigerant-containing appliances used for the residential and light commercial air conditioning and heat pump subsector from Part 84 leak repair.
Both frameworks can matter on the same job
Part 84 does not replace Section 608. A job may need Part 84 leak-repair records while Section 608 technician certification, service practices, sales restrictions, or ODS leak-repair rules also matter. Your audit trail should show which rule applies to the unit and which rule each record supports.
25 lb commercial refrigeration unit with R-404A
- Section 608 / Part 82 leak repair: Does not apply to the Part 82 leak-repair threshold because the unit is under 50 lb.
- AIM Act / Part 84 leak repair: Applies if the unit is over 15 lb, GWP > 53, not in the RLCA carve-out, and not ODS-only.
80 lb chiller with R-22
- Section 608 / Part 82 leak repair: Applies because the unit is over 50 lb and uses an ODS refrigerant.
- AIM Act / Part 84 leak repair: Does not apply because of the ODS-only carve-out.
80 lb chiller with R-410A
Part 84 leak repair can apply. Section 608 still matters for technician certification and service practices, but Part 82 leak-repair requirements are not triggered solely by an HFC-only appliance.
What you actually need to track per service event
Strip away the legal language and the field-level requirements come down to a fairly consistent list. For every refrigerant-related service event on an in-scope unit, your records should capture:
- Unit identification. The specific appliance: make, model, serial, location, full charge in pounds, refrigerant type, and GWP.
- Technician. Certified tech name, certification number, and certification type (Section 82.161 Type I/II/III/Universal).
- Service date and arrival time. When work began and ended.
- Reason for service. Leak inspection, leak repair, charge addition, recovery, retrofit, decommission, etc.
- Refrigerant added. Amount in pounds, source (virgin/reclaimed), refrigerant type.
- Refrigerant recovered. Amount in pounds, destination (recovery cylinder ID, reclaim, destruction).
- Leak rate calculation when applicable, with the underlying inputs.
- Leak repair details. Component repaired, repair method, verification test results, repair deadline tracking.
- Verification of repair. Initial and follow-up verification per the applicable regulation.
- CFR citation for the rule being satisfied: Part 82, Part 84, or another applicable Section 608 requirement.
EPA basis: 40 CFR 84.106(l) says Part 84 records include the appliance identity and location, service date, parts worked on, type of work, person performing the work, refrigerant added or removed, full charge, and leak-rate method when applicable. 40 CFR 82.157(l) has a similar record structure for covered 50 lb appliances.
Recordkeeping: how long to keep what
Different sections have different retention periods, but a safe operating posture is:
- Service records: Minimum 3 years. Many shops keep them for the life of the equipment plus 3 years.
- Leak rate calculations and repair verifications: 3 years minimum, often longer when chained to ongoing inspection cadences.
- Technician certifications: Indefinitely for certification organizations; contractors should keep current proof of certification readily available for each technician.
- Refrigerant purchase, sales, and transfer records: 3 years.
The operational risk is not just whether the record exists. It is whether your team can find the right record for the right unit, service date, technician, refrigerant, and leak-rate calculation without rebuilding the job from memory.
EPA basis: 40 CFR 84.106(l) and 40 CFR 82.157(l) require covered leak-repair records to be kept for at least 3 years unless a longer period is specified for the record type. EPA's Section 608 recordkeeping guidance also notes that owners/operators must keep service records and repair-verification records for covered ODS appliances.
Want to see how TuffOps handles refrigerant compliance inside work orders? Book a 30-minute demo and we'll show how the Comply module builds Part 82 / Part 84 records directly from work orders.
A practical workflow your techs can actually follow
Compliance fails at the field level when techs have to remember the rules. The workflow that scales is:
- Start with the unit. Tech scans the unit (QR code or lookup) and the system already knows refrigerant type, GWP, full charge, RLCA classification, and which rules apply.
- Pick the service reason. "Charge addition," "leak repair," "recovery," etc. The system prompts only for fields the chosen reason actually requires.
- Capture refrigerant amounts. Added, recovered, source, destination: entered once, on the phone, in real time.
- Auto-calculate the leak rate. If the event triggers a leak rate calculation, the system runs it from the unit's rolling 12-month history rather than asking the tech to do math.
- Stamp the CFR citation. Every record carries the applicable rule (82, 84, or both) so audits map cleanly to the regulation.
- Drive deadlines forward. Leak-repair deadlines and follow-up verifications appear in dispatch, so the next compliance action is visible before it becomes overdue.
EPA basis: 40 CFR 84.106(d) and (e) set the repair timing, initial verification, and follow-up verification structure for covered Part 84 leaks.
That's the model TuffOps Comply is built around: the technician completes the job, and the compliance record is captured from the same workflow.
Quick-reference: Part 82 vs. Part 84
| Aspect | Section 608 / Part 82 | AIM Act / Part 84 |
|---|---|---|
| Effective | Existing | January 1, 2026 |
| Charge threshold for leak repair | ≥ 50 lb for covered ODS equipment | ≥ 15 lb for covered refrigerant-containing appliances |
| Refrigerants covered | Class I and II ODS | Regulated substances + substitutes with GWP > 53 |
| RLCA carve-out | Generally no | Yes: residential / light commercial AC/HP exempt from Part 84 leak repair |
| ODS-only appliances | Covered | Carved out |
| Technician certification | Section 82.161 (Type I/II/III/Universal) | References Section 82.161: same certs |
| Recordkeeping minimum | 3 years (typical) | 3 years (typical) |
| Can both frameworks matter on one job? | Yes: Part 84 does not remove Section 608 duties | |
What this means for your shop in 2026
Three honest observations for HVAC contractors right now:
- Your in-scope equipment count may expand. If you only tracked 50 lb+ ODS systems under Part 82, review your customer base for 15 lb+ HFC equipment that now needs Part 84 leak-repair classification.
- Spreadsheet risk goes up as the unit count grows. Part 84 adds unit classification, leak-rate methods, repair deadlines, verification records, and carve-out logic that can be hard to keep consistent in disconnected files.
- Per-event capture reduces rework. If your techs document refrigerant work while the unit context is open, the record is more likely to include the appliance, technician, refrigerant, charge, and calculation details the rule expects.
The good news: once your operation captures refrigerant events as part of the normal work order flow, the compliance record becomes much easier to produce because it is tied to the unit, the technician, and the job that generated it.
Where to verify the rules yourself
Last reviewed: This guide was reviewed against eCFR 40 CFR 82.157, eCFR 40 CFR 84.106, and EPA Section 608 recordkeeping guidance on May 7, 2026.
- 40 CFR Part 82 (Section 608): eCFR Part 82
- 40 CFR Part 84 (AIM Act): eCFR Part 84
- EPA's AIM Act page: epa.gov/climate-hfcs-reduction
Don't take this post (or any vendor's blog) as a substitute for reading the regulations or talking to your environmental counsel. The rules evolve and the edge cases are real.
Frequently asked questions
Does AIM Act Part 84 replace EPA Section 608?
No. Part 84 adds leak-repair and recordkeeping requirements for covered refrigerant-containing appliances, but it does not remove Section 608 duties such as technician certification, service practices, sales restrictions, and Part 82 leak-repair requirements for covered ODS appliances.
Does R-410A trigger Part 82 leak-repair rules?
Not solely because it is R-410A. Part 82 leak repair applies to appliances with 50 lb or more of Class I or Class II refrigerant, or a blend containing one. R-410A is an HFC blend, so a covered 15 lb+ R-410A appliance should be reviewed under Part 84 instead, while Section 608 certification and service-practice requirements may still matter.
How long do HVAC contractors need to keep refrigerant leak-repair records?
For covered leak-repair records, both 40 CFR 84.106(l) and 40 CFR 82.157(l) generally require records to be retained for at least 3 years unless a specific record type has a longer requirement. Contractors should keep technician certification proof readily available and verify current retention duties against the eCFR.
What should a Part 84 refrigerant service record include?
A practical Part 84 record should identify the appliance, location, refrigerant, full charge, service date, person performing the work, parts worked on, type of work, refrigerant added or removed, leak-rate method when applicable, and repair or verification details tied to the unit.
See refrigerant compliance built into work orders
TuffOps Comply tracks Part 82 and Part 84 context per unit, runs leak-rate calculations from captured inputs, and produces audit-ready records from the same work order your techs already do. Book a 30-minute walkthrough.
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