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Recordkeeping Requirements for Refrigerant Retailers

The sale of refrigerants is constrained by several EPA regulations. This fact sheet explains the requirements according to the identity of the purchaser and the seller. In all cases, the following guidance applies:

Please follow the link for the relevant situation:

Selling a large cylinder to:
a service technician or a refrigerant wholesaler

Selling a small can to:
a service technician or a refrigerant wholesaler

Selling a Large Cylinder (e.g. 30 pounds) to a Service Technician

In this situation, the seller has two required actions:
  1. The seller must either see a 608 or 609 technician certification card. (Note that section 609 technicians may not purchase HCFC-22.) If the buyer is uncertified but is purchasing on behalf of a shop or other facility, the seller must see evidence that at least one tech at that shop is certified (for example, a letter from the shop stating that Joe Tech is certified plus a copy of Joe Tech's card). The Seller must keep this information on file. The purchasing facility must notify the seller when Joe Tech is no longer employed. After such notification, the seller is prohibited from selling refrigerant to the authorized representative of the shop.

  2. The seller must keep an invoice listing name of purchaser, date of sale, and quantity of refrigerant purchased.

Selling a Large Cylinder (e.g. 30 pounds) to a Refrigerant Wholesaler

In this situation, the seller has one recommended action and one required action:

Recommended: The seller doesn't need to see a 608 or 609 technician certification card. However, it is a good idea to get a written statement certifying that the cylinders will be resold. The statement should include the name and business address of the wholesaler. Why? Because sellers of refrigerant are legally responsible for ensuring that their customers are allowed under the Clean Air Act to purchase refrigerant.

Required: The seller must have an invoice listing the name of purchaser, date of sale, and quantity of refrigerant purchased.

Selling a Small Can (less 20 pounds or less) to Persons Servicing Motor Vehicle Air Conditioners

In this situation, the seller has one required action:

Required: The seller must see the technician's 609 certification card. Small cans of CFC-12 or EPA-approved substitutes for MVACs containing an ozone-depleting substance (for example, Autofrost, Chill-it, HotShot, FR-12, Freeze 12) may only be sold to a section 609 technician. Note: Section 608 certified technicians may not purchase small cans of CFC-12 or small cans of EPA-approved MVAC substitutes containing an ozone-depleting substance.

Selling a Small Can (less than 20 pounds) to a Refrigerant Wholesaler

In this situation, the seller has one required action:

Required: For sales of small cans of CFC-12 or EPA-approved substitutes for MVACs containing an ozone-depleting substance (for example, Autofrost, Chill-it, HotShot, FR-12, Freeze 12), the seller must obtain a written statement from the wholesaler that the small cans are for resale only. The statement must indicate the purchaser's name and business address.

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