EPA 609 study guide
EPA Section 609 certification is about servicing motor vehicle air conditioners. Subpart B does not publish a test outline; it says only what approved certification tests must cover (40 CFR 82.40(a)(2)). This guide follows the rule itself (40 CFR Part 82, Subpart B): scope, definitions, required practices, equipment, technician and shop certification, records, small-can sales, disposal facilities and, briefly, the service procedures printed in its appendices. The last two topics add the substitute refrigerant (SNAP) rules for motor vehicle air conditioning from 40 CFR Part 82, Subpart G. Every point links to the rule text it comes from, with the exact words quoted.
Purpose and scope
Subpart B carries out section 609 of the Clean Air Act on servicing motor vehicle air conditioners (MVACs). It also carries out section 608 for certain servicing, maintenance, repair and disposal of air conditioners in MVACs and MVAC-like appliances.
“The purpose of the regulations in this subpart B is to implement section 609 of the Clean Air Act, as amended (Act) regarding the servicing of motor vehicle air conditioners (MVACs), and to implement section 608 of the Act regarding certain servicing, maintenance, repair and disposal of air conditioners in MVACs and MVAC-like appliances”
The rules apply to anyone who services a motor vehicle for consideration when the service involves the refrigerant in the motor vehicle air conditioner.
“These regulations apply to any person performing service on a motor vehicle for consideration when this service involves the refrigerant in the motor vehicle air conditioner.”
Service for consideration means being paid for the service, in cash, credit, goods or services. It covers all service except service done for free.
“Service for consideration means being paid to perform service, whether it is in cash, credit, goods, or services. This includes all service except that done for free.”
Key definitions
A motor vehicle is any self-propelled vehicle designed to carry persons or property on a street or highway, including passenger cars, light duty vehicles and heavy duty vehicles.
“Motor vehicle as used in this subpart means any vehicle which is self-propelled and designed for transporting persons or property on a street or highway, including but not limited to passenger cars, light duty vehicles, and heavy duty vehicles.”
A vehicle whose final assembly the original equipment manufacturer has not completed is not a motor vehicle under this definition.
“This definition does not include a vehicle where final assembly of the vehicle has not been completed by the original equipment manufacturer.”
Motor vehicle air conditioners are mechanical vapor compression refrigeration equipment used to cool the driver's or passenger's compartment of any motor vehicle.
“Motor vehicle air conditioners means mechanical vapor compression refrigeration equipment used to cool the driver's or passenger's compartment of any motor vehicle.”
The MVAC definition is not meant to cover hermetically sealed refrigeration systems for refrigerated cargo, or the air conditioning systems on passenger buses using HCFC-22.
“This definition is not intended to encompass the hermetically sealed refrigeration systems used on motor vehicles for refrigerated cargo and the air conditioning systems on passenger buses using HCFC-22 refrigerant.”
For the term MVAC-like appliance, Subpart B points to the definition in 40 CFR 82.152.
“MVACs and MVAC-like appliances (as that term is defined in 40 CFR 82.152)”
Refrigerant means any class I or class II substance used in an MVAC; these substances are listed in Part 82, Subpart A, Appendix A. Since November 15, 1995, refrigerant also includes any substitute substance.
“Refrigerant means any class I or class II substance used in a motor vehicle air conditioner. Class I and class II substances are listed in part 82, subpart A, appendix A. Effective November 15, 1995, refrigerant shall also include any substitute substance.”
Service involving refrigerant is any service during which refrigerant can reasonably be expected to be discharged or released from the MVAC or MVAC-like appliance to the atmosphere.
“Service involving refrigerant means any service during which discharge or release of refrigerant from the MVAC or MVAC-like appliance to the atmosphere can reasonably be expected to occur.”
Charging an MVAC or MVAC-like appliance with refrigerant and doing nothing else (a "top-off") is also service involving refrigerant.
“Service involving refrigerant includes any service in which an MVAC or MVAC-like appliance is charged with refrigerant but no other service involving refrigerant is performed (i.e., a “top-off”).”
Approved refrigerant recycling equipment is equipment certified by EPA (the Administrator) or by an organization approved under 82.38 as meeting a standard in 82.36. It extracts and recycles refrigerant, or extracts it for recycling on-site or reclamation off-site.
“Approved refrigerant recycling equipment means equipment certified by the Administrator or an organization approved under § 82.38 as meeting either one of the standards in § 82.36. Such equipment extracts and recycles refrigerant or extracts refrigerant for recycling on-site or reclamation off-site.”
Who must be certified and required practices
No person repairing or servicing MVACs for consideration, and no person repairing or servicing MVAC-like appliances, may perform service involving the refrigerant without properly using equipment approved under 82.36.
“No person repairing or servicing MVACs for consideration, and no person repairing or servicing MVAC-like appliances, may perform any service involving the refrigerant for such MVAC or MVAC-like appliance: (1) Without properly using equipment approved pursuant to § 82.36;”
To perform service involving the refrigerant, a person repairing or servicing an MVAC for consideration must also be properly trained and certified by a technician certification program approved by EPA under 82.40.
“Unless any such person repairing or servicing an MVAC has been properly trained and certified by a technician certification program approved by the Administrator pursuant to § 82.40; and”
To perform service involving the refrigerant, a person repairing or servicing an MVAC-like appliance (paid or not) must be properly trained and certified by a technician certification program approved by EPA under either 82.40 or 82.161(a)(5).
“Unless any such person repairing or servicing an MVAC-like appliance has been properly trained and certified by a technician certification program approved by the Administrator pursuant to either § 82.40 or § 82.161(a)(5).”
Properly using equipment means using it in line with Subpart B, including the prohibitions and required practices in 82.34 and the recommended service procedures in 82.36(a) and Appendices A to F, as applicable.
“Properly using means using equipment in conformity with the regulations set forth in this subpart, including but not limited to the prohibitions and required practices set forth in § 82.34, and the recommended service procedures and practices for the containment of refrigerant set forth in § 82.36(a) and appendices A, B, C, D, E, and F to this subpart, as applicable.”
Properly using also means operating the equipment according to the manufacturer's operation and maintenance guide, and using it only for the controlled substance it is designed for.
“In addition, this term includes operating the equipment in accordance with the manufacturer's guide to operation and maintenance and using the equipment only for the controlled substance for which the machine is designed.”
With equipment that extracts and recycles, refrigerant must be recycled before it goes back into an MVAC or MVAC-like appliance, even the same one it came from.
“For equipment that extracts and recycles refrigerant, properly using also means to recycle refrigerant before it is returned to a motor vehicle air conditioner or MVAC-like appliance, including to the motor vehicle air conditioner or MVAC-like appliance from which the refrigerant was extracted.”
With recover-only equipment, the refrigerant must be recycled on-site or sent off-site for reclamation.
“For equipment that only recovers refrigerant, properly using includes the requirement to recycle the refrigerant on-site or send the refrigerant off-site for reclamation.”
Approved equipment must be used to extract refrigerant before any service during which refrigerant can reasonably be expected to be discharged from the MVAC.
“In any event, approved equipment must be used to extract refrigerant prior to performing any service during which discharge of refrigerant from the motor vehicle air conditioner can reasonably be expected.”
Intentionally venting refrigerant, or disposing of it to the atmosphere, is an improper use of equipment.
“Intentionally venting or disposing of refrigerant to the atmosphere is an improper use of equipment.”
Approved refrigerant recycling equipment may be taken off-site to service at other locations, but that servicing must meet every Subpart B requirement that would apply on-site.
“approved refrigerant recycling equipment may be transported off-site and used to perform service involving refrigerant at other locations where such servicing occurs. Any such servicing involving refrigerant must meet all of the requirements of this subpart B that would apply if the servicing occurred on-site.”
Facilities that charge MVACs or MVAC-like appliances but do no other service involving refrigerant (top-offs only) are engaged in service involving refrigerant.
“Facilities that charge MVACs or MVAC-like appliances with refrigerant but do not perform any other service involving refrigerant (i.e., perform “top-offs” only) are considered to be engaged in “service involving refrigerant””
Top-off-only facilities are subject to all the requirements that apply to facilities doing a wider range of refrigerant servicing; for facilities that charge MVACs, this includes buying approved refrigerant recycling equipment.
“are therefore subject to any and all requirements of this subsection that apply to facilities that perform a wider range of refrigerant servicing. For facilities that charge MVACs, this includes the requirement to purchase approved refrigerant recycling equipment.”
For facilities that only charge (top off) MVAC-like appliances, these requirements do not include buying approved refrigerant recycling equipment, but do include being properly trained and certified by a program approved under 82.40 or 82.161(a)(5).
“For facilities that only charge MVAC-like appliances, this does not include the requirement to purchase approved refrigerant recycling equipment, but does include the requirement to be properly trained and certified by a technician certification program approved by the Administrator pursuant to either § 82.40 or § 82.161(a)(5).”
Anyone opening MVAC-like appliances must have at least one piece of approved recovery or recycling equipment available at their place of business.
“All persons opening (as that term is defined in § 82.152) MVAC-like appliances must have at least one piece of approved recovery or recycling equipment available at their place of business.”
Approved refrigerant handling equipment
Refrigerant recycling equipment must be certified by EPA, or by an independent standards testing organization EPA approved under 82.38, to meet the applicable standard listed in 82.36(a).
“Refrigerant recycling equipment must be certified by the Administrator or an independent standards testing organization approved by the Administrator under § 82.38 to meet the following standard:”
Equipment that recovers and recycles CFC-12 must meet the standards in Appendix A.
“Equipment that recovers and recycles CFC-12 refrigerant must meet the standards set forth in appendix A of this subpart”
Equipment that recovers but does not recycle CFC-12 must meet the standards in Appendix B.
“Equipment that recovers but does not recycle CFC-12 refrigerant must meet the standards set forth in appendix B of this subpart”
Since January 1, 2008, equipment that recovers and recycles HFC-134a, including equipment that also recharges systems with HFC-134a, must meet Appendix C, based on SAE J2788.
“Effective January 1, 2008, equipment that recovers and recycles HFC-134a refrigerant and equipment that recovers and recycles HFC-134a refrigerant and recharges systems with HFC-134a refrigerant must meet the standards set forth in Appendix C of this subpart based upon J2788”
Equipment that recovers and recycles HFO-1234yf from MVACs and recharges MVAC systems with HFO-1234yf must meet SAE J2843, which is incorporated by reference.
“Equipment that recovers and recycles HFO-1234yf refrigerant from MVACs and recharges MVAC systems with HFO-1234yf refrigerant must meet the standards set forth in SAE J2843 (incorporated by reference, see § 82.31).”
Refrigerant handling equipment made or imported for servicing MVACs for consideration cannot be introduced into interstate commerce unless it meets 82.36.
“Refrigerant handling equipment manufactured or imported for use during the maintenance, service or repair of MVACs for consideration cannot be introduced into interstate commerce unless meeting the requirements of § 82.36.”
EPA keeps a list of approved equipment by manufacturer and model.
“The Administrator will maintain a list of approved equipment by manufacturer and model.”
Not covered here
We do not set out the technical contents of SAE J2843, J2851 and J3030, because they are incorporated by reference and their text is not printed in Subpart B. We only write what an official source states, so study these parts with your certifying program's materials.
Technician training and certification
A technician training program may not issue certificates unless it meets all of the standards in 82.40(a).
“No technician training programs may issue certificates unless the program complies with all of the standards in § 82.40(a).”
Approved programs must give adequate training through on-the-job training, self-study of instructional material, or on-site training with instructors, videos or a hands-on demonstration.
“Each program must provide adequate training, through one or more of the following means: on-the-job training, training through self-study of instructional material, or on-site training involving instructors, videos or a hands-on demonstration.”
The certification test must cover the service and repair standards in 82.36(a) and Appendices A to F for MVACs and MVAC-like appliances.
“The certification tests must adequately and sufficiently cover the following: (i) The standards established for the service and repair of MVACs and MVAC-like appliances as set forth in § 82.36(a) and appendices A, B, C, D, E, and F to this subpart.”
The test must also cover expected future technology (such as HFC-134a in new MVACs) and the environmental consequences of refrigerant release and of stratospheric ozone depletion.
“Anticipated future technological developments, such as the introduction of HFC-134a in new motor vehicle air conditioners. (iii) The environmental consequences of refrigerant release and the adverse effects of stratospheric ozone layer depletion.”
Completed tests must be graded by someone who gets no benefit from the outcome; a grading fee may be charged.
“Completed tests must be graded by an entity or individual who receives no benefit based on the outcome of testing; a fee may be charged for grading.”
Each program must offer individual proof of certification, such as a certificate, wallet-sized card or display card, and give each certified technician a unique number.
“Each certification program must offer individual proof of certification, such as a certificate, wallet-sized card, or display card, upon successful completion of the test. Each certification program must provide a unique number for each certified technician.”
EPA's authorized representatives may require technicians to show, on the business premises, that they can recover and/or recycle refrigerant properly.
“Authorized representatives of the Administrator may require technicians to demonstrate on the business entity's premises their ability to perform proper procedures for recovering and/or recycling refrigerant.”
Failing to demonstrate, or failing to use the equipment properly, may lead EPA to revoke the certificate; a technician whose certificate is revoked must be recertified before servicing or repairing any MVAC.
“Failure to demonstrate or failure to properly use the equipment may result in revocation of the technician's certificate by the Administrator. Technicians whose certification is revoked must be recertified before servicing or repairing any motor vehicle air conditioners.”
Shop certification to EPA
By January 1, 1993, anyone repairing or servicing MVACs for consideration had to certify to EPA that they have acquired and are properly using approved equipment, and that each person authorized to use it is properly trained and certified.
“No later than January 1, 1993, any person repairing or servicing motor vehicle air conditioners for consideration shall certify to the Administrator that such person has acquired, and is properly using, approved equipment and that each individual authorized to use the equipment is properly trained and certified.”
The certification is a statement signed by the equipment owner or another responsible officer. It gives the purchaser's name, the address where the equipment will be located, and the equipment's manufacturer, model number, date of manufacture and serial number.
“Certification shall take the form of a statement signed by the owner of the equipment or another responsible officer and setting forth: (i) The name of the purchaser of the equipment; (ii) The address of the establishment where the equipment will be located; and (iii) The manufacturer name and equipment model number, the date of manufacture, and the serial number of the equipment.”
The statement must also say the equipment will be properly used, that each individual the purchaser authorizes to perform service is trained and certified under 82.40, and that the information is true and correct.
“The certification must also include a statement that the equipment will be properly used in servicing motor vehicle air conditioners, that each individual authorized by the purchaser to perform service is properly trained and certified in accordance with § 82.40, and that the information given is true and correct.”
Section 82.42(a)(1) lists, by state or territory, the EPA Regional office whose CAA section 609 Enforcement Contact receives the certifications of owners or lessees of recycling or recovery equipment. For example, those with places of business in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island or Vermont send their certifications to EPA Region I.
“Owners or lessees of recycling or recovery equipment having their places of business in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont must send their certifications to: CAA section 609 Enforcement Contact; EPA Region I”
Recordkeeping
Owners of approved refrigerant recycling equipment certified under 82.36(a)(2) (CFC-12 recover-and-recycle equipment) must keep records of the name and address of any facility they send refrigerant to.
“Any person who owns approved refrigerant recycling equipment certified under § 82.36(a)(2) must maintain records of the name and address of any facility to which refrigerant is sent.”
Owners of approved refrigerant recycling equipment must keep records showing that everyone authorized to operate it is currently certified under 82.40.
“Any person who owns approved refrigerant recycling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified under § 82.40.”
Records required by 82.42 must be kept for at least three years unless otherwise indicated. Entities that service MVACs for consideration must keep them on-site.
“All records required to be maintained pursuant to this section must be kept for a minimum of three years unless otherwise indicated. Entities which service motor vehicle air conditioners for consideration must keep these records on-site.”
Entities that service MVACs for consideration must let an authorized EPA representative who presents credentials enter the premises and see all required records.
“All entities which service motor vehicle air conditioners for consideration must allow an authorized representative of the Administrator entry onto their premises (upon presentation of his or her credentials) and give the authorized representative access to all records required to be maintained pursuant to this section.”
Small-container refrigerant sales and the store sign
Since November 15, 1992, no person may sell or distribute, or offer to sell or distribute, a class I or class II substance suitable for use as an MVAC refrigerant in a container holding less than 20 pounds of it, except as the next point allows.
“Effective November 15, 1992, no person may sell or distribute, or offer for sale or distribution, any class I or class II substance that is suitable for use as a refrigerant in motor vehicle air-conditioner and that is in a container which contains less than 20 pounds of such refrigerant to any person”
Such a sale is allowed only to a buyer who is properly trained and certified under 82.40, or who intended the containers for resale only and so certifies to the seller under 82.42(b)(3).
“to any person unless that person is properly trained and certified under § 82.40 or intended the containers for resale only, and so certifies to the seller under § 82.42(b)(3).”
The seller must verify that the buyer is properly trained and certified under 82.40, and must have a reasonable basis for believing the buyer's information is accurate.
“must verify that the purchaser is properly trained and certified under § 82.40. The seller must have a reasonable basis for believing that the information presented by the purchaser is accurate.”
The only exception is a purchase for resale only. Then the seller must get a written statement from the buyer that the containers are for resale only, giving the buyer's name and business address.
“The only exception to these requirements is if the purchaser is purchasing the small containers for resale only. In this case, the seller must obtain a written statement from the purchaser that the containers are for resale only and indicate the purchasers name and business address.”
These sales records must be kept for three years.
“Records required under this paragraph must be retained for a period of three years.”
Anyone making retail sales of these containers (class I or class II, suitable for MVACs, less than 20 pounds) must prominently display a sign where they are sold.
“Any person who conducts any retail sales of a class I or class II substance that is suitable for use as a refrigerant in a motor vehicle air conditioner, and that is in a container of less than 20 pounds of refrigerant, must prominently display a sign where sales of such containers occur”
The sign must state that it is a violation of federal law to sell containers of class I and class II refrigerant of less than 20 pounds to anyone who is not properly trained and certified to operate approved refrigerant recycling equipment.
“It is a violation of federal law to sell containers of Class I and Class II refrigerant of less than 20 pounds of such refrigerant to anyone who is not properly trained and certified to operate approved refrigerant recycling equipment.”
Not covered here
We do not cover sales rules for small containers of substitute refrigerants here, because the Subpart B sales restriction and sign text name only class I and class II substances. The federal sales restriction that also reaches non-exempt substitute refrigerants is in Subpart F (40 CFR 82.154(c)). We only write what an official source states, so study these parts with your certifying program's materials.
Motor vehicle disposal facilities
A motor vehicle disposal facility is a commercial facility that disposes of (dismantles, crushes or recycles) MVACs or MVAC-like appliances, such as automotive recycling facilities, scrap yards, landfills and salvage yards.
“Motor vehicle disposal facility means any commercial facility that engages in the disposal (which includes dismantling, crushing or recycling) of MVACs or MVAC-like appliances, including but not limited to automotive recycling facilities, scrap yards, landfills and salvage yards engaged in such operations.”
Repair and servicing facilities, including collision repair facilities, are not motor vehicle disposal facilities.
“Motor vehicle repair and/or servicing facilities, including collision repair facilities, are not considered motor vehicle disposal facilities.”
Refrigerant extracted at a disposal facility from an MVAC or MVAC-like appliance bound for disposal may not later be charged into an MVAC or MVAC-like appliance unless it is first handled in one of two ways.
“Any refrigerant that is extracted from an MVAC or an MVAC-like appliance (as that term is defined in § 82.152) bound for disposal and located at a motor vehicle disposal facility may not be subsequently used to charge or recharge an MVAC or MVAC-like appliance, unless, prior to such charging or recharging, the refrigerant is either:”
One way: the refrigerant is recovered and reclaimed under the rules referred to in 82.32(e)(2).
“Recovered, and reclaimed in accordance with the regulations promulgated under § 82.32(e)(2) of this subpart B; or”
The other way: it is recovered with approved recycling equipment dedicated to MVACs and MVAC-like appliances, by a certified technician or by an employee, owner, operator or contractor of the disposal facility, and then recycled by the facility that charges it, properly using approved recycling equipment and following any applicable recommended service procedures in the Subpart B appendices.
“Recovered using approved refrigerant recycling equipment dedicated for use with MVACs and MVAC-like appliances, either by a technician certified under paragraph (a)(2) of this section, or by an employee, owner, or operator of, or contractor to, the disposal facility; and (B) Subsequently recycled by the facility that charges or recharges the refrigerant into an MVAC or MVAC-like appliance, properly using approved refrigerant recycling equipment in accordance with any applicable recommended service procedures set forth in the appendices to this subpart B.”
Refrigerant whose sale is restricted under Subpart F, extracted at a disposal facility and not reclaimed under Subpart F, may be sold before re-use only to a technician certified under 82.34(a)(2).
“Any refrigerant the sale of which is restricted under subpart F that is extracted from an MVAC or an MVAC-like appliance bound for disposal and located at a motor vehicle disposal facility but not subsequently reclaimed in accordance with the regulations promulgated under subpart F, may be sold prior to its subsequent re-use only to a technician certified under paragraph (a)(2) of this section.”
A certified technician who obtains such refrigerant may re-use it only in an MVAC or MVAC-like appliance, and only if it has been reclaimed or properly recycled.
“Any technician certified under paragraph (a)(2) of this section who obtains such a refrigerant may subsequently re-use such refrigerant only in an MVAC or MVAC-like appliance, and only if it has been reclaimed or properly recycled.”
Service procedures from the appendices
Appendix A, the standard for equipment that recovers and recycles CFC-12, includes a recommended service procedure for the containment of CFC-12 and a standard of purity for use in mobile air conditioning systems.
“Equipment that recovers and recycles CFC-12 refrigerant must meet the standards set forth in appendix A of this subpart (Recommended Service Procedure for the Containment of CFC-12, Extraction and Recycle Equipment for Mobile Automotive Air-Conditioning Systems, and Standard of Purity for Use in Mobile Air Conditioning Systems).”
In the R-12 (CFC-12) recovery procedure printed in Appendix A, the recovery unit is run until the vehicle system goes from pressure to a vacuum. With the unit shut off for at least 5 minutes, the technician checks that no refrigerant remains.
“Operate the recovery unit until the vehicle system has been reduced from a pressure to a vacuum. With the recovery unit shut off for at least 5 min, determine that there is no refrigerant remaining in the vehicle AC system.”
If the system has pressure, more recovery is needed; the operation is repeated until the system vacuum stays stable for 2 minutes.
“If the vehicle system has pressure, additional recovery operation is required to remove the remaining refrigerant. Repeat the operation until the vehicle AC system vacuum level remains stable for 2 min.”
In the Appendix A R-12 (CFC-12) procedure, manifold gage set hoses (high, low and center) must have shutoff valves within 12 in (30 cm) of the service ends, and the valves must be closed before the hoses are removed from the system.
“Service hoses must have shutoff valves in the high, low, and center service hoses within 12 in (30 cm) of the service ends. Valves must be closed prior to hose removal from the air-conditioning system.”
Appendix A's purity specification covers refrigerant removed directly from, and meant to go back into, a mobile air-conditioning system. It limits the contaminants in this recycled refrigerant 12 to moisture (15 ppm by weight), refrigerant oil (4000 ppm by weight) and noncondensable gases, air (330 ppm by weight; the eCFR text prints “by wright”).
“The refrigerant in this document shall have been directly removed from, and intended to be returned to, a mobile air-conditioning system. The contaminants in this recycled refrigerant 12 shall be limited to moisture, refrigerant oil, and noncondensable gases, which shall not exceed the following level: 3.1 Moisture: 15 ppm by weight. 3.2 Refrigerant Oil: 4000 ppm by weight. 3.3 Noncondensable Gases (air): 330 ppm by wright.”
The Appendix A R-12 (CFC-12) procedure says recycled refrigerant should not be stored in disposable containers (the kind virgin refrigerant is sold in); only DOT (49 CFR) or UL approved storage containers should be used.
“Recycled refrigerant should not be salvaged or stored in disposable refrigerant containers. This is the type of container in which virgin refrigerant is sold. Use only DOT CFR title 49 or UL approved storage containers for recycled refrigerant.”
In the same Appendix A procedure, an external portable container must be evacuated to at least 27 in of vacuum (75 mm Hg absolute) before recycled refrigerant is transferred into it.
“When external portable containers are used for transfer, the container must be evacuated at least 27 in of vacuum (75 mm Hg absolute pressure) prior to transfer of the recycled refrigerant.”
Not covered here
We do not cover refrigerant identification, service fittings, or the container colors and markings that some appendices set as equipment requirements (for example Appendix B, 6.3.1). The SNAP rules for substitute refrigerants are covered in the last two topics of this guide. We only write what an official source states, so study these parts with your certifying program's materials.
Substitute refrigerants (SNAP)
The program is called the Significant New Alternatives Policy, or SNAP, program.
“This program will henceforth be referred to as the “Significant New Alternatives Policy” (SNAP) program.”
No person may use a substitute without following the use restrictions set by its acceptability decision, once the rule imposing them has taken effect.
“(c) No person may use a substitute without adhering to any use restrictions set by the acceptability decision, after the effective date of any rulemaking imposing such restrictions.”
No person may use a substitute after the effective date of a rule adding it to the list of unacceptable substitutes.
“(d) No person may use a substitute after the effective date of any rulemaking adding such substitute to the list of unacceptable substitutes.”
Appendix B lists R-152a as acceptable subject to use conditions for CFC-12 automobile motor vehicle air conditioning, new equipment only. One condition: engineering strategies and/or devices must be built into the system so that foreseeable leaks into the passenger compartment do not cause R-152a concentrations of 3.7% v/v or more in any part of the free space inside the passenger compartment for more than 15 seconds while the ignition is on.
“Engineering strategies and/or devices shall be incorporated into the system such that foreseeable leaks into the passenger compartment do not result in R-152a concentrations of 3.7% v/v or above in any part of the free space1inside the passenger compartment for more than 15 seconds when the car ignition is on”
Appendix B lists HFO-1234yf as acceptable subject to use conditions as a substitute for CFC-12 in automobile motor vehicle air conditioning, for new equipment in passenger cars and light-duty trucks only.
“CFC-12 Automobile Motor Vehicle Air Conditioning (New equipment in passenger cars and light-duty trucks only)”
The second HFO-1234yf condition binds manufacturers: they must conduct a failure mode and effect analysis (FMEA) as provided in SAE J1739 and keep it on file for at least three years from its creation.
“(2) Manufacturers must conduct Failure Mode and Effect Analysis (FMEA) as provided in SAE J1739.5 7 Manufacturers must keep the FMEA on file for at least three years from the date of creation”
EPA's comments in the table (not a SNAP condition) note that, under EPA's Significant New Use Rule for HFO-1234yf under the Toxic Substances Control Act, commercial users or consumers can only recharge MVAC systems with HFO-1234yf where the original equipment manufacturer did the original charging with HFO-1234yf.
“Consistent with EPA's Significant New Use Rule for HFO-1234yf under the Toxic Substances Control Act, commercial users or consumers can only recharge MVAC systems with HFO-1234yf where the original charging of the system with HFO-1234yf was done by the original equipment manufacturer.”
Appendix B lists carbon dioxide (CO2) as acceptable subject to use conditions as a substitute for CFC-12 in motor vehicle air conditioning, new equipment only.
“CFC-12 Motor Vehicle Air Conditioning (New equipment only) Carbon dioxide (CO2) as a substitute for CFC-12”
For CFC-12 motor vehicle air conditioners (retrofit and new equipment/NIKs), Appendix B lists flammable substitutes as unacceptable, other than R-152a or HFO-1234yf in new equipment.
“Flammable Substitutes, other than R-152a or HFO-1234yf in new equipment”
EPA's comments in the table (not a condition) say the risks of using flammable substitutes other than R-152a and HFO-1234yf in this end-use have not been addressed by a risk assessment, and that R-152a and HFO-1234yf may be used in new equipment with the use conditions in Appendix B.
“The risks associated with using flammable substitutes (except R-152a and HFO-1234yf) in this end-use have not been addressed by a risk assessment. R-152a and HFO-1234yf may be used in new equipment with the use conditions in appendix B to this subpart.”
Fittings and labels
As of June 3, 2022, the HFO-1234yf conditions require HFO-1234yf MVAC systems to adhere to all of the safety requirements of SAE J639, including requirements for a flammable refrigerant warning label, a high-pressure compressor cutoff switch and pressure relief devices, and unique fittings.
“As of June 3, 2022: (1) HFO-1234yf MVAC systems must adhere to all of the safety requirements of SAE J639,4 7 including requirements for a flammable refrigerant warning label, high-pressure compressor cutoff switch and pressure relief devices, and unique fittings.”
As of June 3, 2022, the HFO-1234yf conditions require fittings for connections with small refrigerant cans, for consumer or professional use, to have a 0.5-inch diameter, a thread pitch of 16 threads per inch and a left-hand thread direction, consistent with SAE J2844.
“For connections with small refrigerant cans for consumer or professional use, use fittings must have a diameter of 0.5 inches, a thread pitch of 16 thread per inch, and a left thread direction, consistent with SAE J2844”
Under Appendix D (for several named retrofit refrigerants and all refrigerants listed in later Notices of Acceptability as CFC-12 substitutes in MVACs), each refrigerant may only be used with its own unique set of fittings, designed by the manufacturer of the refrigerant.
“Each refrigerant may only be used with a set of fittings that is unique to that refrigerant. These fittings (male or female, as appropriate) must be designed by the manufacturer of the refrigerant.”
The fittings must be used on all containers of the refrigerant, on can taps, on recovery, recycling and charging equipment, and on all air conditioning system service ports.
“The fittings must be used on all containers of the refrigerant, on can taps, on recovery, recycling, and charging equipment, and on all air conditioning system service ports.”
Using the refrigerant with a fitting designed by anyone else, or using an adapter or deliberately modifying a fitting to use a different refrigerant, violates this use condition.
“Using a refrigerant with a fitting designed by anyone else, even if it is different from fittings used with other refrigerants, is a violation of this use condition. Using an adapter or deliberately modifying a fitting to use a different refrigerant is a violation of this use condition.”
When a retrofit is done, the person doing it must put a label on the air conditioning system in the engine compartment.
“The person conducting the retrofit must apply a label to the air conditioning system in the engine compartment that contains the following information:”
If the refrigerant shows flammability limits measured under ASTM E681, the label must say “This refrigerant is FLAMMABLE. Take appropriate precautions.”
“If the refrigerant displays flammability limits as measured according to ASTM E681, the statement “This refrigerant is FLAMMABLE. Take appropriate precautions.””
Under Appendix H's criteria for unique MVAC fittings, “differ” for screw-on fittings means the diameter differs by at least 1/16 inch or the thread direction is reversed. Changing only the thread pitch is not enough.
“(b) For screw-on fittings, “differ” means that either the diameter must differ by at least 1⁄16 inch or the thread direction must be reversed (i.e. right-handed vs. left-handed). Simply changing the thread pitch is not sufficient.”
Appendix H states one exception to the 1/16-inch difference requirement: the small can fittings for GHG-X4 and R-406A.
“(c) The sole exception to the 1⁄16 inch difference requirement is the difference between the small can fittings for GHG-X4 and R-406A.”
No substitute refrigerant may be used to top off a system that uses another refrigerant. The original refrigerant must first be recovered under the section 609 rules.
“No substitute refrigerant may be used to “top-off” a system that uses another refrigerant. The original refrigerant must be recovered in accordance with regulations issued under section 609 of the CAA prior to charging with a substitute.”
Sources
- eCFR: 40 CFR 82.30, Purpose and scope (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.32, Definitions (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.34, Prohibitions and required practices (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.36, Approved refrigerant handling equipment (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.40, Technician training and certification (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.42, Certification, recordkeeping and public notification requirements (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR Part 82, Subpart B, Appendix A (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.170, Purpose and scope (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR 82.174, Prohibitions (as of Nov 3, 2026)Checked November 5, 2026
- eCFR: 40 CFR Part 82, Subpart G, Appendix B (as of Nov 3, 2026)Checked November 5, 2026