EPA 608 Type I study guide
Type I covers small appliances: EPA lists recovery requirements, recovery techniques and safety as its topics. This guide sets out what the federal rule (40 CFR Part 82, Subpart F) states on each of them, plus the disposal and Type I certification rules. Every point links to the rule text it comes from, with the exact words quoted.
Recovery requirements
A small appliance is an appliance that is fully manufactured, charged and hermetically sealed in a factory with 5 pounds or less of refrigerant.
“Small appliance means any appliance that is fully manufactured, charged, and hermetically sealed in a factory with five (5) pounds or less of refrigerant”
The rule names examples of small appliances: refrigerators and freezers, medical or industrial research refrigeration equipment, room air conditioners, dehumidifiers, under-the-counter ice makers, vending machines and drinking water coolers.
“including, but not limited to, refrigerators and freezers (designed for home, commercial, or consumer use), medical or industrial research refrigeration equipment, room air conditioners (including window air conditioners, portable air conditioners, and packaged terminal air heat pumps), dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.”
Since January 1, 2018, the evacuation rules apply to appliances containing any class I or class II (ozone-depleting) refrigerant or any non-exempt substitute refrigerant.
“Starting on January 1, 2018, this section applies to evacuation of refrigerant from appliances containing any class I or class II refrigerant or any non-exempt substitute refrigerant”
Before opening a small appliance, or when disposing of one, you must recover the refrigerant with a recovery and/or recycling machine certified under 40 CFR 82.158.
“Before opening a small appliance or when disposing of a small appliance, persons must recover refrigerant, using a recovery and/or recycling machine certified pursuant to § 82.158, according to the following conditions:”
With recovery equipment made before November 15, 1993, one of the allowed options is to recover 80 percent of the refrigerant in the small appliance.
“When using recovery equipment manufactured before November 15, 1993, recover 80 percent of the refrigerant in the small appliance; or”
With recovery equipment made on or after November 15, 1993, one of the allowed options is to recover 90 percent of the refrigerant if the appliance's compressor is functioning, or 80 percent if it is not.
“When using recovery equipment manufactured on or after November 15, 1993, recover 90 percent of the refrigerant in the appliance when the compressor in the appliance is functioning, or 80 percent of the refrigerant in the appliance when the compressor in the appliance is not functioning; or”
Instead of the percentage levels, you may evacuate the small appliance to four inches of mercury vacuum.
“Evacuate the appliance to four inches of mercury vacuum.”
Recovery equipment for small appliances must be certified by an approved testing organization as able to recover 90 percent of the refrigerant with the test stand's compressor running and 80 percent with it not running.
“must be certified by an approved equipment testing organization to be capable of recovering 90 percent of the refrigerant in the test stand when the compressor of the test stand is operational and 80 percent of the refrigerant when the compressor of the test stand is not operational”
Equipment made or imported before November 15, 1993, counts as certified if it can recover 80 percent of the refrigerant, whether or not the test stand's compressor is running, or reach a four-inch vacuum when tested with a properly calibrated pressure gauge.
“Equipment manufactured or imported before November 15, 1993, will be considered certified if it is capable of either recovering 80 percent of the refrigerant in the system, whether or not the compressor of the test stand is operational, or achieving a four-inch vacuum when tested using a properly calibrated pressure gauge.”
Equipment used to evacuate a class I or class II refrigerant or a non-exempt substitute from small appliances before they are disposed of may also be certified if it can reach a four-inch vacuum when tested with a properly calibrated pressure gauge.
“Equipment used to evacuate any class I or class II refrigerant or any non-exempt substitute refrigerant from small appliances before they are disposed of may also be certified if it is capable of achieving a four-inch vacuum when tested using a properly calibrated pressure gauge.”
When refrigerant is recovered from a small appliance for disposal, the same evacuation levels apply, using recovery equipment that meets the standards in 40 CFR 82.158.
“Persons recovering refrigerant from a small appliance, MVAC, or MVAC-like appliance for purposes of disposal of these appliances must evacuate refrigerant to the levels in § 82.156(b) through (d) using recovery equipment that meets the standards in § 82.158(e) through (g)”
The final processor is whoever takes the final step in disposing of a small appliance, such as a scrap recycler or landfill operator. It must either recover any remaining refrigerant itself or verify, with a signed statement or a contract, that all refrigerant that had not already leaked out was recovered.
“The final processor—i.e., persons who take the final step in the disposal process (including but not limited to scrap recyclers and landfill operators) of a small appliance, MVAC, or MVAC-like appliance—must either: (1) Recover any remaining refrigerant from the appliance in accordance with paragraph (a) of this section; or (2) Verify using a signed statement or a contract that all refrigerant that had not leaked previously has been recovered from the appliance or shipment of appliances in accordance with paragraph (a) of this section.”
A signed statement must include the name and address of the person who recovered the refrigerant and the date it was recovered.
“If using a signed statement, it must include the name and address of the person who recovered the refrigerant and the date the refrigerant was recovered.”
It is a violation to accept a signed statement or contract if you knew or had reason to know it was false.
“It is a violation of this subpart to accept a signed statement or contract if the person receiving the statement or contract knew or had reason to know that the signed statement or contract is false.”
The final processor must tell suppliers, for example with signs or letters, that refrigerant must be recovered before the appliances are delivered.
“The final processor must notify suppliers of appliances that refrigerant must be properly recovered in accordance with paragraph (a) of this section before delivery of the items to the facility. The form of this notification may be signs, letters to suppliers, or other equivalent means.”
If all the refrigerant has leaked out, the final processor must get a signed statement that it leaked out before delivery and recovery is not possible.
“If all the refrigerant has leaked out of the appliance, the final processor must obtain a signed statement that all the refrigerant in the appliance had leaked out prior to delivery to the final processor and recovery is not possible.”
"Leaked out" means escape through system failures, accidents or other unavoidable events, not through negligence or deliberate acts such as cutting refrigerant lines.
““Leaked out” in this context means those situations in which the refrigerant has escaped because of system failures, accidents, or other unavoidable occurrences not caused by a person's negligence or deliberate acts such as cutting refrigerant lines.”
The final processor must keep copies of the signed statements or contracts on site, on paper or electronically, for three years.
“The final processor of a small appliance, MVAC, or MVAC-like appliance must keep a copy of all the signed statements or contracts obtained under paragraph (b)(2) of this section on site, in hard copy or in electronic format, for three years.”
Recovery techniques
Self-contained recovery equipment can remove refrigerant without help from the appliance's own components.
“Self-contained recovery equipment means refrigerant recovery and/or recycling equipment that is capable of removing the refrigerant from an appliance without the assistance of components contained in the appliance.”
System-dependent recovery equipment needs the help of components in the appliance to remove the refrigerant.
“System-dependent recovery equipment means refrigerant recovery equipment that requires the assistance of components contained in an appliance to remove the refrigerant from the appliance.”
System-dependent equipment may not be used on appliances with a full charge of more than 15 pounds, unless it is permanently attached as a pump-out unit.
“System-dependent equipment may not be used with appliances with a full charge of more than 15 pounds of refrigerant, unless the system-dependent equipment is permanently attached to the appliance as a pump-out unit.”
A process stub is a length of tubing that gives access to the refrigerant in a small appliance or room air conditioner and can be resealed after repair or service.
“Process stub means a length of tubing that provides access to the refrigerant inside a small appliance or room air conditioner and that can be resealed at the conclusion of repair or service.”
A small appliance may not be sold or distributed unless it has a process stub for removing refrigerant at servicing and disposal (appliances with only exempt refrigerants are excepted).
“No person may sell or distribute, or offer for sale or distribution, any small appliance (except appliances containing only refrigerants that have been exempted under paragraph (a)(1) of this section) unless it is equipped with a process stub to facilitate the removal of refrigerant at servicing and disposal.”
The rule lists activities reasonably expected to violate the integrity of the refrigerant circuit. They include, but are not limited to, attaching or detaching hoses and gauges, adding or removing refrigerant, adding or removing components, and cutting the refrigerant line.
“Activities reasonably expected to violate the integrity of the refrigerant circuit include but are not limited to: Attaching or detaching hoses and gauges to and from the appliance; adding or removing refrigerant; adding or removing components; and cutting the refrigerant line.”
EPA's test method for small-appliance recovery equipment runs separate tests with the test stand's compressor running and not running.
“Separate tests are also conducted with the test stand compressor running during the recovery operation, and without the test stand compressor running during the recovery operation, to calculate the system's recovery efficiency under either condition.”
Not covered here
We do not cover identifying refrigerants or noncondensables by pressure and temperature, specific passive recovery methods (heating and striking the compressor, using a vacuum pump with an unpressurized container), installing high- and low-side access valves, running an operative compressor during passive recovery, removing solderless access fittings, or R-134a as a substitute for R-12, because the federal rule text and the EPA pages we checked do not state them beyond listing them as test topics. We only write what an official source states, so study these parts with your certifying program's materials.
Safety
Not covered here
We do not cover the decomposition products refrigerants form at high temperatures, because the federal rule text and the EPA pages we checked do not state them beyond listing the topic. We only write what an official source states, so study these parts with your certifying program's materials.
Type I certification
Anyone who could reasonably be expected to violate the integrity of the refrigerant circuit while maintaining, servicing, repairing or disposing of appliances containing a class I or class II refrigerant or a non-exempt substitute must pass a certification exam from an approved program. People who maintain, service or repair small appliances must be certified as Type I technicians.
“Any person who could be reasonably expected to violate the integrity of the refrigerant circuit during the maintenance, service, repair, or disposal of appliances (as follows in this paragraph) containing a class I or class II refrigerant or a non-exempt substitute refrigerant must pass a certification exam offered by an approved technician certification program. (i) Persons who maintain, service, or repair small appliances must be certified as Type I technicians.”
Apprentices are exempt from the certification requirement while a certified technician closely and continually supervises them.
“Apprentices are exempt from the requirement in paragraph (a)(1) of this section provided the apprentice is closely and continually supervised by a certified technician”
People who only dispose of small appliances do not need to be certified.
“Persons who dispose of small appliances, MVACs, and MVAC-like appliances are not required to be certified.”
Programs that offer only Type I certification may use an on-site format or a mail-in format.
“Organizations providing Type I certification only may choose either an on-site format or a mail-in format similar to what is permitted under the MVACs program.”
A mail-in Type I test cannot be used toward Universal certification.
“Mail-in format Type I tests cannot be used toward a Universal certification.”
The passing score is 70 percent on the closed-book Type I test and 84 percent on the mail-in Type I test.
“The passing score for the closed-book Type I, Type II, Type III and Universal certification test is 70 percent. The passing score for Type I certification tests using the mail-in format is 84 percent.”
Each Type I test includes 25 questions from Group I and 25 from Group II.
“All Type I, Type II and Type III, certification tests will include 25 questions from Group I and 25 questions from Group II.”
For a mail-in Type I test, the program must send the results within 30 days of receiving the completed test and any required documents.
“Type I certifying programs using the mail-in format must notify the applicants of their test results no later than 30 days from the date the certifying programs received the completed test and any required documentation.”
Each Type I test must include a way to verify the identity of the person taking it, such as a driver's license or passport.
“Each test for Type I certification must provide a means of verifying the identification of the individual taking the test. Acceptable forms of identification include but are not limited to drivers' licenses and passports.”
Training material sent with mail-in Type I tests must not include sample questions that mimic the language of the certification test.
“Training material accompanying mail-in Type I tests must not include sample test questions mimicking the language of the certification test.”
Sources
- eCFR: 40 CFR 82.152, Definitions (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.156, Proper evacuation of refrigerant from appliances (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.158, Standards for recovery and/or recycling equipment (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.155, Safe disposal of appliances (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.154, Prohibitions (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR Part 82 Subpart F, Appendix C, Method for Testing Recovery Devices for Use With Small Appliances (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.161, Technician certification (as of Nov 3, 2026)Checked November 5, 2026