EPA 608 Plan

Who needs EPA 608 certification, and who does not

Short answer

Certification is required of anyone who could reasonably be expected to violate the integrity of the refrigerant circuit while maintaining, servicing, repairing or disposing of an appliance containing a class I or class II refrigerant or a non-exempt substitute. Registered apprentices are exempt while closely and continually supervised. Disposal of small appliances, MVACs and MVAC-like appliances needs no certification. There is no education or experience prerequisite.

The trigger

Section 82.161(a)(1) applies to "any person who could be reasonably expected to violate the integrity of the refrigerant circuit" during maintenance, service, repair or disposal of an appliance containing a class I or class II refrigerant or a non-exempt substitute refrigerant. Since 1 January 2018 it has covered substitute refrigerants, not only CFCs and HCFCs.

EPA's plain-language version of who counts as a technician: attaching and detaching hoses and gauges to measure pressure; adding or removing refrigerant; or any other activity that violates the integrity of an MVAC-like appliance or a small appliance, other than disposal.

No prerequisites

There is no minimum age, no schooling requirement, no apprenticeship requirement and no experience requirement in the regulation. You pass the test, you are certified. That is unusual among the certifications in this portfolio and it is worth saying plainly.

Who is exempt

Keeping it

Under 82.161(a)(4) you must keep a copy of your certificate at your place of business, and retain it until three years after you stop operating as a technician. Under 82.161(a)(3) EPA may require you to demonstrate proper recovery and recycling procedures at your place of business; failing to demonstrate, or failing to use the equipment properly, can suspend or revoke the certificate. If it is revoked you must recertify before working on appliances again.

Since 1 January 2018, certifying programmes other than federally run ones must publish an online list of the technicians they have certified, updated at least annually, and must let technicians opt out of being listed.

Turn this into a study plan

Enter your exam date and weekly hours; we allocate time by blueprint weight × your weak spots.

Build my study plan

Primary references

  1. 40 CFR Part 82 Subpart F — Recycling and Emissions Reduction — Office of the Federal Register (eCFR) · government · retrieved 2026-09-22, verified 2026-09-22
  2. Section 608 Technician Certification Requirements — United States Environmental Protection Agency · primary · retrieved 2026-09-22, verified 2026-09-22
Last reviewed: 2026-10-18Next review by: 2026-12-17Reviewed by: Openverse editorial team, Authoring and fact verificationHow we verify facts