EPA compliance · guide

What refrigerant records the EPA requires, and for how long

40 CFR 84.106(l) and (m) · in force since January 1, 2026

Three years, paper or electronic, and the list is longer than most people keep. The rule is specific about what goes in a service record, and it requires a separate standing record for every covered appliance that exists before any of it is serviced.

Three years, and longer for the appliance record

All the records below must be kept for at least three years, in electronic or paper format, unless the rule says otherwise. The appliance record is the exception: it is kept until three years after the appliance is retired.

Record 1: the appliance itself

Before you service anything, you need a standing record for each covered appliance — one with 15 or more pounds of refrigerant. This had to exist by January 1, 2026, or on installation for anything put in after that date. It holds:

Who the owner or operator is
The address where the appliance is located
The full charge, and the method used to work out the full charge
If the full charge was established as a range, the range, its midpoint, and how the range was arrived at
Any revisions to the full charge, how they were determined, and when
The date of installation

The full charge is the denominator in every leak rate calculation you will ever do on that appliance, so the rule wants to know how you arrived at it and whether it has ever changed.

Record 2: every install, service, repair or disposal

Each time a covered appliance is installed, serviced, repaired or disposed of, a record must capture eight things:

The identity and location of the appliance
The date of the work
Which parts of the appliance were installed, serviced, repaired or disposed of
The type of work performed on each part
The name of the person who performed it
The amount and type of refrigerant added — or removed, on disposal
The full charge of the appliance
The leak rate, and the method used to determine it

The leak rate line is not required when disposing of an appliance, following a retrofit, installing a new appliance, or where the refrigerant addition qualifies as a seasonal variance — the same three exceptions that excuse you from calculating it. — 40 CFR 84.106(l)(2)(viii)

The technician has to hand it over

This one cuts both ways depending on which end of the job you are on. Whoever adds or removes refrigerant must, on finishing, provide the owner or operator with documentation meeting these requirements. If you are the contractor, that is your obligation. If you are the owner, that is your right — and you cannot keep the records you are required to keep without it.

Record 3: if you ever change calculation method

You are normally locked into one leak rate calculation method across every covered appliance at an operating facility. In the narrow case where you may switch — you acquired a facility that used the other method — you have to record the identification details, the date of the acquisition, and the leak rates for the affected appliances under both methods.

What has to be reported, not just kept

Chronically leaking appliances

An appliance with 15 or more pounds of refrigerant that leaks 125% or more of its full charge in a calendar year must be reported to the EPA by March 1 of the following year. This is a report, not a record — keeping good paperwork does not discharge it.

Purged refrigerant does not always count against you

Purged refrigerant that is destroyed at a verifiable destruction efficiency of 98% or greater does not count toward the leak rate. If you have destruction equipment on a purge unit, the evidence of that efficiency is worth keeping with the calculation it affects.

The practical failure is not dishonesty, it is assembly. Most of these eight fields are known by somebody at the moment of the job — the tech knows the pounds and the part, the office knows the full charge, the calculation needs both. Records get lost in the gap between a van and a filing cabinet, not in bad faith. Three years later, an inspector does not care which.

What the records are actually for

Two things. First, proving the leak rate calculation you were required to do on every refrigerant addition — which needs the full charge, the pounds added, the dates and the method. Second, proving that when a calculation came out over the threshold you did the repair, the initial verification test and the follow-up within the deadlines.

If you want to check where an appliance stands right now, our refrigerant leak rate calculator shows the arithmetic in a form you can copy into the record, and the 30-day repair clock sets out the dates you would then have to evidence.

Eight fields, every visit, three years

AirCert collects the record while the job is happening

The appliance record, the full charge and how it was determined, the pounds added, the leak rate and the method used — captured on the phone at the unit, not reconstructed later from a scribbled docket. Then printed as a PDF you can hand to the owner or an inspector. Out now on Android, and coming soon to iPhone and iPad.

Get it on Google Play

ToolRefrigerant leak rate calculator Guide10%, 20% or 30% — which threshold applies GuideThe 30-day repair clock and the two verification tests

Where this comes from

Recordkeeping and reporting are at 40 CFR 84.106, paragraphs (l) and (m); the chronic leaker report is at (j) and purged refrigerant at (k). The EPA summarises the same duties in its January 2026 leak repair fact sheet.

This is a guide, not legal advice. The rule contains further reporting duties and conditions that are not all reproduced here. Check the regulation, and take advice where your circumstances are unusual.