EPA refrigerant recordkeeping requirements in 2026

Under the 2026 rule, the records are the compliance. An auditor doesn't watch you fix a leak — they read your paperwork. Here's precisely what §84.106(l) requires you to keep, and for how long.

1 · Per-appliance baseline (by Jan 1, 2026, or on install)

• Owner/operator identity and the address where the appliance sits
• The full charge and the method used to determine it
• Any later revisions to the full charge, how and when
• The date of installation

§84.106(l)(1)

2 · Every service event

For each time a 15+ lb appliance is installed, serviced, repaired, or disposed of:

• Identity and location of the appliance; date and type of work
• Which parts were serviced; who performed the work
• Amount and type of refrigerant added (or removed at disposal)
• The full charge, and the leak rate with the method used

§84.106(l)(2)

3 · The rest of the file

Certified technicians (the "608" in EPA 608)

Repairs under §84.106 must be done by a certified technician — the familiar EPA Section 608 certification (Type I, II, III, or Universal). §84.106(c)(1); 40 CFR §82.161 Your records should tie each service event to the technician who performed it.

Older R-22 systems (Section 608)

Appliances running solely an ozone-depleting refrigerant like R-22 stay under §82.157, which carries its own three-year recordkeeping regime and a 50-lb threshold. §82.157(a),(l)