EPA 609 shop certification and recordkeeping
This page covers the shop certification and recordkeeping rules in 40 CFR 82.42(a) and (b) for anyone who services motor vehicle air conditioners for consideration. Each point quotes the rule and links to it.
The short answer
No later than January 1, 1993, any person repairing or servicing motor vehicle air conditioners for consideration had to certify to EPA, in a signed statement, that it has acquired and is properly using approved equipment and that each individual authorized to use it is properly trained and certified. Owners of approved refrigerant recycling equipment must keep records showing that everyone authorized to operate it is currently certified. Required records must be kept for at least three years unless otherwise indicated, on-site for entities that service MVACs for consideration.
Each part of this answer is quoted from the rule below.
Who must certify to EPA
Subpart B applies to anyone who services a motor vehicle for consideration when the service involves the refrigerant in the motor vehicle air conditioner.
“These regulations apply to any person performing service on a motor vehicle for consideration when this service involves the refrigerant in the motor vehicle air conditioner.”
Service for consideration means being paid for the service, in cash, credit, goods or services. It covers all service except service done for free.
“Service for consideration means being paid to perform service, whether it is in cash, credit, goods, or services. This includes all service except that done for free.”
Any person repairing or servicing motor vehicle air conditioners for consideration must certify to EPA that it has acquired, and is properly using, approved equipment and that each individual authorized to use the equipment is properly trained and certified. The deadline for this was January 1, 1993.
“No later than January 1, 1993, any person repairing or servicing motor vehicle air conditioners for consideration shall certify to the Administrator that such person has acquired, and is properly using, approved equipment and that each individual authorized to use the equipment is properly trained and certified.”
What the certification says
The certification is a statement signed by the owner of the equipment or another responsible officer.
“Certification shall take the form of a statement signed by the owner of the equipment or another responsible officer”
It gives the name of the purchaser of the equipment, the address of the establishment where the equipment will be located, and the equipment's manufacturer name, model number, date of manufacture and serial number.
“(i) The name of the purchaser of the equipment; (ii) The address of the establishment where the equipment will be located; and (iii) The manufacturer name and equipment model number, the date of manufacture, and the serial number of the equipment.”
It must also state that the equipment will be properly used in servicing MVACs, that each individual the purchaser authorizes to perform service is properly trained and certified under 82.40, and that the information given is true and correct.
“The certification must also include a statement that the equipment will be properly used in servicing motor vehicle air conditioners, that each individual authorized by the purchaser to perform service is properly trained and certified in accordance with § 82.40, and that the information given is true and correct.”
Section 82.42(a)(1) lists, by state or territory, the EPA Regional office whose CAA section 609 Enforcement Contact receives the certifications of owners or lessees of recycling or recovery equipment. For example, those with places of business in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island or Vermont send their certifications to EPA Region I.
“Owners or lessees of recycling or recovery equipment having their places of business in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont must send their certifications to: CAA section 609 Enforcement Contact; EPA Region I”
Records to keep
Anyone who owns approved refrigerant recycling equipment certified under 82.36(a)(2) must keep records of the name and address of any facility to which refrigerant is sent.
“Any person who owns approved refrigerant recycling equipment certified under § 82.36(a)(2) must maintain records of the name and address of any facility to which refrigerant is sent.”
Equipment covered by 82.36(a)(2) is equipment that recovers and recycles CFC-12 refrigerant.
“Equipment that recovers and recycles CFC-12 refrigerant must meet the standards set forth in appendix A of this subpart”
Anyone who owns approved refrigerant recycling equipment must keep records demonstrating that all persons authorized to operate it are currently certified under 82.40.
“Any person who owns approved refrigerant recycling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified under § 82.40.”
Technicians' proof of certification (a certification-program duty)
Proof of certification is a duty of the certification program, not of the shop: among the standards a program must meet for EPA approval under 82.40(a), each certification program must offer individual proof of certification, such as a certificate, wallet-sized card or display card, upon successful completion of the test, and must provide a unique number for each certified technician.
“Each certification program must offer individual proof of certification, such as a certificate, wallet-sized card, or display card, upon successful completion of the test. Each certification program must provide a unique number for each certified technician.”
How long, where, and inspections
All records required by 82.42 must be kept for at least three years unless otherwise indicated.
“All records required to be maintained pursuant to this section must be kept for a minimum of three years unless otherwise indicated.”
Entities that service motor vehicle air conditioners for consideration must keep these records on-site.
“Entities which service motor vehicle air conditioners for consideration must keep these records on-site.”
Entities that service MVACs for consideration must let an authorized EPA representative enter their premises, on presentation of credentials, and give access to all required records.
“All entities which service motor vehicle air conditioners for consideration must allow an authorized representative of the Administrator entry onto their premises (upon presentation of his or her credentials) and give the authorized representative access to all records required to be maintained pursuant to this section.”
Authorized EPA representatives may also require technicians to demonstrate, on the business premises, that they can perform proper procedures for recovering and/or recycling refrigerant.
“Authorized representatives of the Administrator may require technicians to demonstrate on the business entity's premises their ability to perform proper procedures for recovering and/or recycling refrigerant.”
Sources
- eCFR: 40 CFR 82.30, Purpose and scope (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.32, Definitions (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.42, Certification, recordkeeping and public notification requirements (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.36, Approved refrigerant handling equipment (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.40, Technician training and certification (as of Nov 3, 2026)Checked November 5, 2026