EPA Form 6602 and Annual Refrigerant Reporting: A Walkthrough

What "Form 6602" Actually Is

The EPA does not publish a single, free-standing paper form titled "Form 6602" that a facility manager can download and mail in. The reporting obligation under 40 CFR § 84.110 is satisfied by submitting a structured electronic report through EPA's Central Data Exchange (CDX), typically via the Compliance and Emissions Data Reporting Interface (CEDRI). "Form 6602" is the internal EPA report identifier most commonly used to refer to the Subpart C annual compliance report, but in practice the report is a guided web form with optional file upload, not a fillable PDF.

Treat the form as a structured summary of what is already in your recordkeeping system. If the records you maintain under § 84.106(l) are complete and well-organized, the annual filing is mostly a data-extraction exercise. If they are not — if leak inspections are scattered across spreadsheets, technician PDFs, and email attachments — preparing the report becomes a multi-week scramble every spring.

Who Must File

Reporting under § 84.110 is tied to the applicability cutoffs in § 84.106. In practical terms, an annual report is owed by:

• Owners or operators of any appliance with a full charge of 1,500 pounds or more of a regulated substance or substitute with a GWP above 53, that experienced a leak event during the reporting year requiring recordkeeping under § 84.106(l).
• Owners or operators who chose, retrofitted, or retired equipment in lieu of completing repairs and need to report the milestone dates required under § 84.106(i) and (j).
• Reclaimers and certified technicians who handle recovered refrigerant from covered equipment, where their activity triggers a § 84.110 reporting obligation distinct from the owner/operator report.

Comfort-cooling-only facilities (offices, schools, retail stores without process refrigeration) are generally outside the report population because they are outside the leak repair scheme to begin with. Smaller commercial refrigeration footprints — for instance, a convenience store with a 200-pound rack — also fall below the applicability threshold. The fastest way to confirm your status is to start with the applicability threshold guide before assuming reports are due.

Note also that some owners with covered appliances may have a negative reporting year — no exceedances, no retrofits, no retirements. The rule does not require a separate "nothing happened" filing in every case; check the specific report triggers in § 84.110(a) for your facility profile. When in doubt, file. A short, clean report is far cheaper than defending a missed filing.

Deadline and Reporting Year

The Subpart C reporting cycle uses a calendar year as the reporting period. The annual report for activities during a given calendar year is due to EPA the following calendar year. EPA has historically used a spring filing window aligned with other AIM Act reports — consult § 84.110 and the current CEDRI report instructions for the specific date applicable to your filing year, since EPA has occasionally adjusted the cycle in response to operator feedback.

Build the deadline into a recurring calendar reminder no later than January 15 of the filing year. The most common delay in reporting is not regulatory ambiguity — it is the time required to consolidate technician service tickets, leak rate calculations, and refrigerant purchase records from multiple sites. Two weeks of lead time is minimum for a multi-site operator; six weeks is realistic.

What Data Goes on the Form

The CEDRI report is organized around the appliance, not the facility. Each covered appliance becomes a distinct entry with its own data block. The high-level structure is:

For multi-site operators, the same appliance template repeats for each unit. EPA permits batched data upload (CSV) for high-volume filers; the template is available inside CEDRI and includes hard field types (dates as ISO 8601, refrigerant codes drawn from a controlled list, etc.). Before relying on the CSV path, do a dry-run import early — the field validators are strict, and the most common rejection cause for batched filers is mismatched refrigerant codes or unzero-padded dates.

The E-Filing Process: CDX and CEDRI

All § 84.110 reports are submitted through EPA's Central Data Exchange (CDX), the agency's single sign-on platform for environmental reporting, and routed to the CEDRI module that handles AIM Act submissions. There is no paper filing path for routine reports.

1. Register a CDX account. Visit cdx.epa.gov and create an organizational account. Allow several business days for identity verification — first-time registration is not instantaneous.
2. Request the CEDRI program service. Inside CDX, add the "CEDRI: Compliance and Emissions Data Reporting Interface" service and the Subpart C reporting role. EPA may require additional confirmation for first-time AIM Act program access.
3. Designate the responsible official. CDX distinguishes between a preparer (who enters data) and a responsible official (who certifies and signs). The responsible official must complete an Electronic Signature Agreement (ESA) before any report can be certified.
4. Open the Subpart C report template. Inside CEDRI, select the reporting year, the regulation (40 CFR Part 84 Subpart C), and the report type. The template auto-populates facility information from the CDX organizational profile.
5. Enter or upload appliance data. Use the in-browser forms for small filings or the CSV upload for high-volume filers. CEDRI validates each field as it is entered; required fields display in red until satisfied.
6. Attach supporting files. Where the report references a calculation methodology, retrofit plan, or extension request, CEDRI permits PDF attachments up to the per-submission size limit. Keep filenames descriptive — "site_A_retrofit_plan_2026.pdf" beats "scan001.pdf."
7. Run the pre-submission validation. CEDRI offers a validation pass that surfaces missing or out-of-range data before certification. Always run it; correcting after certification requires a formal amendment.
8. Certify and submit. The responsible official logs in, reviews the prepared report, and applies the electronic signature. CDX returns a Copy of Record (CoR) acknowledging receipt. Save the CoR. It is the only proof the report was filed on time.

The CoR is not optional documentation. In any enforcement inquiry, the agency will ask for it before any other artifact. Store it alongside the source records under your § 84.106(l) recordkeeping system; a missing CoR effectively recreates the question of whether the report was ever filed at all.

Common Reasons Reports Get Rejected or Flagged

CEDRI distinguishes between a rejected report (validation failure — the submission is not on file and you must correct and re-submit) and a flagged report (accepted but routed for additional EPA review). Both outcomes are avoidable with disciplined preparation.

The single largest cause of last-minute filing failure is the Electronic Signature Agreement. The ESA is a paper form that the responsible official signs, scans, and submits separately to EPA. It can take days to process. A facility manager who logs into CEDRI on the deadline and discovers the ESA is missing or expired typically cannot certify the report on time, and CEDRI does not extend the deadline for procedural failures of this kind.

Run the validation pass at least two days before the deadline so that any flagged item can be reviewed by a second pair of eyes inside the organization. CEDRI's validators catch syntax and range errors but cannot catch logical errors — a misallocated leak event between two appliances, for example, will pass validation unflagged.

Cross-Reference to § 84.106(l) Recordkeeping

The annual report is not a substitute for the underlying records. § 84.106(l) requires owners and operators to maintain the source documentation for at least three years — covering every entry on the annual report. The report summarizes; the records prove. EPA can request the underlying records at any time, and an enforcement action will almost always include a request to reconcile the report values against the source data.

A practical discipline: every field on the annual report should carry a citation back to a specific document in your records repository. If a report value cannot be sourced to a dated artifact, treat it as a defect — investigate before submission, not after the information request arrives. See the full guidance on § 84.106(l) recordkeeping requirements for the underlying retention rules.

Who Signs the Report

The Subpart C annual report is certified by a responsible official — a defined term in EPA environmental reporting that maps loosely to the corporate-officer level. The certification language is not boilerplate: it states that the signer has examined the report, that the information is true and complete to the best of their knowledge and belief, and that they are aware of the criminal penalties for knowing submission of false information.

For most entities, the responsible official may be:

• For a corporation: a president, vice president, secretary, treasurer, or other corporate officer in charge of a principal business function, or a duly authorized representative who manages one or more facilities and has authority to make major capital and operating expenditure decisions
• For a partnership or sole proprietorship: a general partner or the proprietor, respectively
• For a municipality, state, federal, or other public agency: a principal executive officer or ranking elected official

The responsible official does not have to be the person who prepared the data. In practice, a compliance officer or facility engineer prepares the report inside CEDRI as the "preparer," and the responsible official reviews and electronically signs. Delegating signing authority to a non-qualifying party — for example, a contracted consultant — invalidates the certification and the report.

Practical Notes for Multi-Site Operators

Operators with covered appliances across many sites face a consolidation problem that the regulation does not solve. A national grocery chain with hundreds of supermarkets, a cold-chain logistics provider with regional warehouses, or a food manufacturer with several process plants will typically be filing on dozens to hundreds of appliances simultaneously. Several practical patterns help:

• Single CDX organizational account. Avoid registering each facility separately unless a corporate structure requires it. A single org account permits role-based assignment of preparers per region while keeping the responsible official singular at the corporate level.
• Use the CSV batch upload from day one. Manual data entry across 200 appliances is the surest way to introduce transcription errors. Build the CSV from your underlying recordkeeping system and treat the upload as the canonical entry path.
• Lock data at the regional level early. Set an internal cutoff approximately 30 days before the EPA deadline by which regional compliance leads sign off on their data. After that, treat changes as exceptions that require a documented reason.
• Pre-run validation in batches. CEDRI permits validation runs against partial data. Run validation on a regional slice as soon as that region is locked, rather than waiting until the final consolidated CSV is assembled.
• Track amendments separately. If an amendment is required mid-cycle (for example, a leak event identified after initial filing), CEDRI's amendment workflow generates a new CoR. Save the amendment CoR alongside the original.

Enforcement Context

Failure to file, late filing, and submission of false or misleading information are all enforceable under the AIM Act's civil penalty authority. Each day late can constitute a separate violation. False certifications by a responsible official also expose the certifier to criminal liability under the knowing-misrepresentation language of the statute.

In practice, EPA has pursued enforcement actions in the refrigerant sector under both Subpart C and the legacy Section 608 program. Routine annual reports are not where most enforcement starts — they are how EPA verifies the rest of a facility's compliance story when an inquiry begins for a separate reason. A clean, well-sourced annual report makes other inquiries shorter; a missing or inconsistent one extends them.

For an overview of how penalties are calculated and the range of enforcement outcomes EPA has applied to refrigerant violations, see EPA Subpart C enforcement and penalties.

Frequently Asked Questions

Related Resources

• Recordkeeping Requirements Under § 84.106(l) — the source-document obligations that feed the annual report
• § 84.106(a) Applicability Threshold — confirm whether your equipment is in scope at all
• Leak Rate Calculation Methods Under § 84.106(b) — methodology your report will reference
• Automatic Leak Detection Requirements Under § 84.108 — ALD records that appear in the report's ALD block
• EPA Subpart C Enforcement and Penalties — what is at stake if reporting fails
• Preparing for an EPA Refrigerant Compliance Audit — how the report fits the broader audit story

Sources

• eCFR — 40 CFR § 84.110 (Reporting)
• eCFR — 40 CFR § 84.106 (Leak Repair and Recordkeeping)
• EPA Central Data Exchange (CDX)
• EPA — Compliance and Emissions Data Reporting Interface (CEDRI)
• EPA — HFC Reduction and AIM Act Implementation
• Federal Register — Emissions Reduction and Reclamation Final Rule (October 11, 2024)
• EPA — Enforcement of the American Innovation and Manufacturing Act
• EPA — AIM Act Compliance Guidance (2024)
• 42 U.S.C. § 7675 — American Innovation and Manufacturing Act