California Signs Law Clarifying Refrigerant Requirements
AB 663 Outlines the Criteria for Certified Reclaimed Refrigerants as Part of SB 1206
On October 1, 2025, California Governor Gavin Newsom signed Assembly Bill (AB) 663, which addresses hydrofluorocarbon (HFC) sale and distribution prohibition exemptions. AB 663 clarifies the state’s State Bill (SB) 1206, dictating what criteria must be met for a refrigerant to qualify as a certified reclaimed refrigerant.
Simply put, SB 1206 puts GWP limits on HFC refrigerants and HFC blends used to service equipment but notes that certified reclaimed refrigerants are exempt from the limits.
What changes for SB 1206 with AB 663 is that, now, there is clarity as to what qualifies as a certified reclaimed refrigerant.
- Contains at least 85% reclaimed material by weight – new per AB 663
- AHRI 700 certified
- Reclaimed by an EPA-Certified Reclaimer
- 99.5% minimum purity
AB 663 also clarifies a gray area. Stockpiled refrigerants that do not meet the criteria above are not compliant, regardless of purchase date.
A-Gas offers PENGUINTM Certified Reclaimed Refrigerants that meet the California state requirements and provides you with all of the required documentation to keep your business compliant.
What does this mean for you?
Wholesale Suppliers
Manage Your Inventory
To comply with the law, you should only stock and sell certified reclaimed refrigerants that meet the criteria. Do an inventory and quarantine any refrigerants that do not meet the criteria by removing them from the sellable stock. Work with your corporate team to destock those refrigerants, perhaps moving them to a location outside of the state for sale. Ensure your corporate team understands the consequences. This is a legal requirement; thus, there are both criminal and civil consequences for non-compliance. Fines can compound quickly if you sell multiple non-compliant products.
You should also work with your supplier to secure your supply of certified reclaimed refrigerant and develop a plan that ensures compliance with state law. Because it will need to meet strict criteria, certain products may not be available on short notice or at the volume you need. Work with your EPA Certified Reclaimer Partner to discuss your supply agreement and needs to confirm you will have the products your customers need. As an EPA-Certified Reclaimer, A-Gas is ready to assist. Contact us today to discuss your supply needs.
Educate Your Customers
As customers come in looking to purchase products with a GWP over 2,200 (or 750 for those working on state-owned equipment), educate them on the updated regulations. Point them to resources that explain the regulation, such as A-Gas’ fact sheet on the law or the SB 1206 website. Make sure they understand that this is now a law and not following it could lead to criminal and civil consequences.
Contractors and Technicians
Educate Your Team
Learn about the law and ensure everyone who purchases or uses refrigerant on the job understands what it means. Our fact sheet can be printed out and kept in trucks or at your shops. Your team should only accept refrigerant that meets the criteria for purchase or servicing. The supplier should be able to provide a Certificate of Analysis (COA) for the product. The product should also be clearly labeled so that your team knows they are only putting compliant refrigerant into the systems they work on.
Do not be fooled—you may hear some folks say it’s ok to use refrigerant you already have on hand if it was purchased before January 1, 2025, when SB 1206 went into place. That just isn’t true. Refrigerant that does not meet the criteria, regardless of purchase date, is not legal.
Be sure to explain the potential consequences of not complying with the law. They could individually be at risk of criminal and civil consequences such as fines and jail time, as could others at your business.
Educate Your Customers
Make sure your customers know that you are complying with the law and have the documentation to prove it. This will not only tick their compliance box but also solidify you as their trusted partner.
No matter what, A-Gas is here to support the industry to ensure suppliers have the products they need stocked, and technicians have the products they need to service equipment. Reach out if you have any questions or need certified reclaimed products to meet California's new SB 1206 requirements.
