10 EPA 608 facts prep sites get wrong
A lot of EPA 608 study material still teaches rules that changed years ago. We found the 10 claims below on prep, quiz and study pages in September 2026 and checked each against the current regulation or an EPA page on September 24, 2026.
We don't name the sites. The point is the rule, not who got it wrong. A claim made this list only if the eCFR, an EPA page or the Federal Register settles it.
Who does what: EPA sets the rules and keeps the question bank secret. 87 EPA-approved certifying programs (EPA list, updated August 20, 2026) give the test and issue the card. Pass608 is an independent study tool.
The table
| # | What you'll read | What the rule says | Source · checked |
|---|---|---|---|
| 1 | Repair leaks over 35% (commercial refrigeration, IPR) or 15% (comfort cooling) | 20% commercial refrigeration, 30% IPR, 10% comfort cooling and other, under both leak-repair rules. 35/35/15 is pre-2019. | 40 CFR 82.157, 84.106; 81 FR 82280 · Sept 24, 2026 |
| 2 | Fines of $27,500, $37,500, $44,539 or $61,847 a day | $124,426 per day per violation, for penalties assessed on or after Jan 8, 2025 | 40 CFR 19.4 · Sept 24, 2026 |
| 3 | "The official EPA 608 exam is 2 hours long" | EPA sets no time limit. Your program does. | 40 CFR 82.161; Appendix D to subpart F · Sept 24, 2026 |
| 4 | "Universal certification exams may have up to 50 questions" | Universal is 100. A single-Type test is 50. | Appendix D · Sept 24, 2026 |
| 5 | Cards "with renewal dates" | Certification does not expire. EPA may require recertification later, by Federal Register notice. | EPA requirements page (updated July 15, 2026); 40 CFR 82.161 · Sept 24, 2026 |
| 6 | "R-410A: Phasing out in 2025 for new systems," with no word on the 2026 install rule | New home and light-commercial systems at GWP 700 or more may still go in if every specified component was made or imported before Jan 1, 2025. | 40 CFR 84.54(c)(1); 91 FR 31284 (effective July 27, 2026) · Sept 24, 2026 |
| 7 | Type II = units over 5 lb | Type II = medium-, high- and very high-pressure appliances, except small appliances and MVAC. Pressure, not charge. | 40 CFR 82.161, 82.152 · Sept 24, 2026 |
| 8 | High-pressure, 200 lb or more: 23 in. Hg | 4 in. Hg (recovery equipment made before Nov 15, 1993) or 10 in. Hg (on or after). There is no 23. | 40 CFR 82.156, Table 1 · Sept 24, 2026 |
| 9 | "Real exam questions" | EPA releases its bank only to approved programs and approves no prep materials. | 40 CFR 82.161(c); EPA program list (updated Aug 20, 2026) · Sept 24, 2026 |
| 10 | A2L is new on the 2026 exam | EPA wrote in 2021 that its bank "already includes questions concerning A2L refrigerants." | 86 FR 24468 (May 6, 2021) · Sept 24, 2026 |
1. Leak rates: 35/35/15 ended with the 2016 rule
EPA's 2016 rule says it plainly: "Prior to this rule, the leak rates for ODS equipment were 35 percent for IPR and commercial refrigeration appliances, and 15 percent for comfort cooling and other appliances" (81 FR 82280). Today's triggers, 20/30/10, sit in two rules:
- 40 CFR 82.157 (Section 608). Since April 10, 2020, only appliances with 50 lb or more of an ODS refrigerant, like R-22.
- 40 CFR 84.106 (AIM Act). Appliances with 15 lb or more of an HFC, or a substitute with a GWP above 53, from January 1, 2026. Residential and light-commercial AC and heat pumps are excluded.
Also watch for 30% given for commercial refrigeration. That's the IPR number. The Type II guide compares the two rules.
2. Penalties: five stale numbers
40 CFR 19.4 sets the inflation-adjusted Clean Air Act figure for 42 U.S.C. 7413(b): $124,426 per day per violation, for penalties assessed on or after January 8, 2025. Its history table dates the old numbers: $27,500 for violations from January 30, 1997 to March 15, 2004, and $37,500 for January 12, 2009 to November 2, 2015. $44,539, $44,000 and $61,847 appear nowhere in 19.4.
The figure moves with inflation, so a penalty with no date is a red flag. EPA's bank is secret, so nobody outside the programs knows which figure it uses. We teach $124,426 with its date.
3. Time limits: EPA sets none
The test rules, 40 CFR 82.161 and Appendix D, set no length for the test. Their only time rules are paperwork: programs send results and the wallet card within 30 days of the test.
EPA sets no time limit; your program does. Programs whose own pages we checked on September 23, 2026 set 30 minutes per section, 1 hour per Type exam and 2 hours for Universal, 2 hours, or 3 hours. Ask yours. The certification hub lists each program's rules.
4. Question count: Universal is 100
Appendix D: "All Type I, Type II and Type III, certification tests will include 25 questions from Group I and 25 questions from Group II. Universal certification tests will include 25 questions from Group I and 75 questions from Group II." Group I is Core. So it's 25 per section, 50 for a single Type and 100 for Universal. You can take Universal at once or combine passing scores from separate Type I, II and III tests.
5. Expiry: there is no renewal
EPA's requirements page (updated July 15, 2026): "Section 608 Technician Certification credentials do not expire." 40 CFR 82.161 lets EPA require recertification later "by placing a notice in the Federal Register." The page still says no expiry. A revoked technician has to recertify, which is a different thing. State and local rules for HVAC work are separate from 608.
6. R-410A installs: the 2026 rule moved the line
A December 2023 rule (88 FR 88825) allowed systems built from pre-2025 components to be installed only "until January 1, 2026." EPA removed that deadline in a rule effective July 27, 2026 (91 FR 31284). 40 CFR 84.54(c)(1) now says new residential and light-commercial AC and heat pump systems with a GWP of 700 or more "may continue to be installed where all specified components of that system are manufactured or imported prior to January 1, 2025."
EPA lists R-410A's GWP at about 2,090. The 700 limit on newly made systems stands. What's gone is the install deadline for older stock.
7. Type II: pressure class, not 5 lb
40 CFR 82.161 puts "medium-, high-, or very high-pressure appliances (except small appliances, MVACs, and MVAC-like appliances)" in Type II. Pressure class comes from the refrigerant's saturation pressure at 104 °F (82.152). The CFR names R-134a as medium-pressure and R-22 and R-410A as high-pressure.
The 5-lb line is Type I. A small appliance is factory-made, charged and hermetically sealed with 5 lb or less. A big charge doesn't decide it either: a low-pressure chiller on R-123 is Type III at any size. EPA's summary page leaves medium-pressure out of Type II. The CFR includes it, and the CFR is the rule.
8. Evacuation: "23 in. Hg" isn't in the table
Table 1 in 40 CFR 82.156, in inches of Hg vacuum, by when the recovery equipment was made or imported:
| Appliance | Before Nov 15, 1993 | On or after Nov 15, 1993 |
|---|---|---|
| Very high-pressure | 0 | 0 |
| High-pressure, under 200 lb | 0 | 0 |
| High-pressure, 200 lb or more | 4 | 10 |
| Medium-pressure, under 200 lb | 4 | 10 |
| Medium-pressure, 200 lb or more | 4 | 15 |
| Low-pressure | 25 mm Hg absolute | 25 mm Hg absolute |
No 23 anywhere, and high-pressure under 200 lb is 0, not 4. Table 1 applies before opening or disposing of an appliance. Non-major repairs and leaking components follow separate 0 psig rules in 82.156(a).
9. "Real exam questions": nobody legitimate has them
40 CFR 82.161(c): "The Administrator will release this bank of questions only to approved technician certification programs." Appendix D makes programs keep "the test questions and answer keys" secure. EPA's program list: "EPA does not review or approve any training preparatory programs or materials."
A page that claims to have the bank is either wrong or holding material it shouldn't have. Honest practice questions, ours included, are original and written to EPA's published Test Topics (updated December 5, 2025).
10. A2L on the exam: not new
When EPA listed R-32, R-454B and other A2Ls for new home AC in 2021, it wrote: "EPA's 608 test bank already includes questions concerning A2L refrigerants and the appliances covered by this rule" (86 FR 24468, May 6, 2021).
What's reported for 2026 is more A2L coverage. ESCO Institute offers a "2018" and a "2026" EPA exam. ACHR News reported on September 19, 2026, quoting ESCO, that the new bank adds general-knowledge questions on A2L and A3 refrigerants and that old-bank exams "can be administered only through Jan. 1, 2027." EPA has not published the change on its own pages as of September 24, 2026. More: 2026 exam changes and A2L refrigerants.
Check any study page in 30 seconds
- Look for a CFR section and a date. No date, no trust.
- Leak repair: which rule? 82.157 for ODS at 50 lb or more. 84.106 for HFCs at 15 lb or more, from 2026.
- Clock, calculator, scoring unit: program rules. EPA sets the pass mark and the question counts.
Every Pass608 question that keys a regulatory number carries its source and date. Start with the Core guide or the free section.
Start the free Core section — free account, no card
Sources
Checked September 24, 2026, unless noted. Page stamps as shown on each page.
- 40 CFR 19.4, penalty inflation table (eCFR, up to date as of 9/22/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4
- 40 CFR 82.152, definitions (eCFR, 9/22/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.152
- 40 CFR 82.156, evacuation, Table 1 (eCFR, 9/22/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.156
- 40 CFR 82.157, ODS leak repair (eCFR, 9/21/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.157
- 40 CFR 82.161, technician certification (eCFR, 9/22/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.161
- Appendix D to 40 CFR 82 subpart F (eCFR, 9/21/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/appendix-Appendix%20D%20to%20Subpart%20F%20of%20Part%2082
- 40 CFR 84.106, HFC leak repair (eCFR, 9/22/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.106
- 40 CFR 84.54, Technology Transitions (eCFR, 9/21/2026): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-B/section-84.54
- 81 FR 82272 (Nov. 18, 2016), leak rates at 82280: https://www.govinfo.gov/content/pkg/FR-2016-11-18/html/2016-24215.htm
- 86 FR 24444 (May 6, 2021), test-bank statement at 24468: https://www.govinfo.gov/content/pkg/FR-2021-05-06/html/2021-08968.htm
- 88 FR 88825 (Dec. 26, 2023): https://www.federalregister.gov/documents/2023/12/26/2023-28500
- 91 FR 31284 (May 26, 2026; effective July 27, 2026): https://www.federalregister.gov/documents/2026/05/26/2026-10387
- EPA, Section 608 Technician Certification Requirements (updated July 15, 2026): https://www.epa.gov/section608/section-608-technician-certification-requirements
- EPA, Section 608 Test Topics (updated Dec. 5, 2025): https://www.epa.gov/section608/test-topics
- EPA, Certification Programs for Section 608 Technicians (updated Aug. 20, 2026): https://www.epa.gov/section608/certification-programs-section-608-technicians
- EPA SNAP table, residential and light commercial AC, R-410A GWP (updated Mar. 19, 2026): https://www.epa.gov/snap/substitutes-residential-and-light-commercial-air-conditioning-and-heat-pumps
- Attributed sources (not EPA): ESCO Institute EPA 608 page (checked Sept 24, 2026), https://www.escogroup.org/training/epa608.aspx · ACHR News, Sept 19, 2026 (checked Sept 23, 2026), https://www.achrnews.com/articles/166686-what-you-need-to-know-about-the-new-section-608-exam
- Program time limits: each program's own page, checked Sept 23, 2026; listed on the certification hub.