Refrigerant and equipment sales, with the records the rules ask for.

A contractor's technician picks up two cylinders and a condensing unit. Someone should confirm a certification card or employer letter is on file, note the refrigerant and quantity, read the unit's refrigerant and manufacture date against the AIM Act rules, and keep DOE's distributor record for a split air conditioner. At a busy branch in June, part of that waits.

For the test, AI reads copies of those tickets with your certification files and item data and drafts the record for each sale: the rules that applied, what was on file, what was missing, and what the contractor said the equipment was for. Nothing is held, released or reported.

Who may buy refrigerant. Under 40 CFR 82.154(c), refrigerant other than exempt substitutes may be sold only to a technician certified Type I, II, III or Universal, to a buyer who employs one and gives the seller proof, or for eventual resale to certified technicians. Refrigerant inside an appliance with a fully assembled circuit, or inside a component, falls outside it, and a 1995 stay still suspends the rule for appliances whose circuit isn't fully assembled. Invoices showing purchaser, date and quantity, plus any employer proof, are kept for three years.

Proof you hold, not proof you can look up. EPA doesn't issue certification cards; the organization that tested the technician does and keeps the record. EPA's guidance makes the wholesaler responsible for judging whether someone picking up for a company is its authorized representative, and recommends, without requiring, a list of them and a signed statement from buyers purchasing for resale. The draft checks each ticket against the cards, letters and lists in your files.

Which equipment can still go in. EPA's Technology Transitions rule under the AIM Act caps global warming potential at 700 for new residential and light commercial air conditioning and heat pump systems from January 1, 2025: R-410A is above it, R-454B and R-32 below. A May 2026 final rule, effective July 27, removed the deadline for installing systems whose specified components (condensing units, condensers, compressors, evaporator units and evaporators) were all made or imported before 2025. Self-contained products above the limit can't be sold from January 1, 2028. A specified component made since 2025 for a refrigerant above the limit must be labeled "For servicing existing equipment only", along with its refrigerant and year of manufacture.

Repair, or a new system. In that 2026 rule EPA says replacing a failed condensing unit without the indoor coil is not a new installation, but replacing the coil afterward would be, and the reverse holds too. EPA's SNAP listings accept R-454B, R-32 and other A2Ls only in new equipment built for them, under use conditions that include UL 60335-2-40, and not as a retrofit for an existing system. That is why what the contractor says the equipment is for belongs on the record.

Where a split air conditioner ends up. For central air conditioners installed since January 1, 2023, DOE requires 13.4 SEER2 nationally and 14.3 SEER2 for split systems under 45,000 Btu/h in the Southeast and Southwest, plus EER2 minimums in the Southwest: Arizona, California, Nevada and New Mexico. An outdoor unit model with any certified combination below a region's level can't be installed there. Distributors keep, for at least 54 months, each split outdoor unit's and single-package air conditioner's manufacturer, model and serial, who it was bought from and sold to and when, with addresses and phone numbers, and where it was delivered. Knowingly selling to a contractor who will install in violation, or routinely does, is itself a violation.

A yes from your reviewer moves the job onto new refrigerant and equipment sales for about 30 days, at a fixed price agreed before anything is signed.

Your compliance lead approves every record before it is filed, and every hold, refusal or follow-up with a contractor stays with your people. When a rule changes, the change goes into the success criteria first.