Regulatory Requirements for MVAC System Servicing

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EPA Regulatory Requirements for MVAC Servicing under the Clean Air Act

• Technician Training and Certification
• Servicing Equipment
• Refrigerant Handling
• Venting Prohibition
• Recordkeeping Requirements for Service Shops
• Ozone-Depleting Refrigerants: Sales Restrictions & Recordkeeping Requirements
• Safe Disposal Requirements
• Significant New Alternatives Policy (SNAP) Program

EPA Programs under the American Innovation and Manufacturing (AIM) Act

• Technology Transitions Program

EPA Regulatory Requirements for MVAC Servicing under the Clean Air Act

Motor vehicle air conditioning (MVAC) equipment uses refrigeration to cool the driver's or passenger's compartment. This page describes EPA requirements for servicing these systems, and how these requirements impact service technicians, shop owners, and some refrigerant retailers. Most of these requirements come from regulations under section 609 of the Clean Air Act (CAA), while two additional sections of the CAA, 608 and 612, play smaller roles.

Here are the basics on EPA’s regulatory requirements, explained in more detail below:

• Refrigerant: Must be approved by EPA and cannot be intentionally released (vented) to the environment.*
• Servicing: When payment of any kind is involved (including non-monetary), any person working on an MVAC system must be certified under section 609 of the CAA and they must use approved refrigerant handling equipment.
• Reusing Refrigerant: Refrigerant must be properly recycled or reclaimed before it can be reused, even if it is being returned to the vehicle from which it was removed.

Technician Training and Certification

Technicians who repair or service MVAC systems for consideration (e.g., payment or bartering) must be trained and certified under CAA section 609 by an EPA-approved technician training and certification programs. Section 609 certification is required to service any MVAC system for consideration, regardless of what refrigerant is used in the system.

Servicing Equipment

Technicians must use refrigerant handling equipment that has been certified by EPA or an independent standards testing organization approved by EPA to certify equipment.

Refrigerant Handling

Certified servicing equipment must be used to remove refrigerant prior to servicing or repairing an MVAC system, or conducting any other service on a vehicle during which discharge of refrigerant can reasonably be expected. Recovered refrigerant must be either recycled or reclaimed before it can be recharged into an MVAC system, even if the refrigerant is being returned to the system from which it was removed.

Recovered refrigerant can either be recycled on-site using approved equipment designed to both recover and recycle refrigerant, or sent off-site to a reclamation facility to be purified according to Air-Conditioning, Heating and Refrigeration Institute (AHRI) Standard 700. Recycling removes impurities and oil, while reclamation returns the refrigerant to virgin specifications. Refrigerant sent off-site must be sent to an EPA-certified refrigerant reclaimer.

Venting Prohibition

Section 608 of the Clean Air Act prohibits the intentional release (venting) of any refrigerant when maintaining, servicing, repairing, or disposing of air conditioning or refrigeration equipment, including MVAC systems.

*Of the Significatn New Alternatives Policy (SNAP)-approved alternatives only one refrigerant, carbon dioxide (also known as R-744 or CO₂), is exempt from the venting prohibition under section 608. Although CO₂ can be released to the environment under section 608, it is not exempt from the section 609 requirements.

Recordkeeping Requirements for Service Shops

New service shops or shops servicing MVAC systems for the first time must certify to their EPA Regional Office that they have acquired and are properly using approved refrigerant handling equipment. This is a one-time requirement. If a shop has certified ownership of a piece of chlorofluorocarbon (CFC)-12 or hydrofluorocarbon (HFC)-134a equipment at any time in the past, the shop is not required to re-submit certification to EPA when they purchase new equipment. This applies even if the shop purchases equipment for a different refrigerant, such as hydrofluoroolefin (HFO)-1234yf.

1. The name of the purchaser of the equipment;
2. The name, address, and telephone number of the establishment where the equipment is located;
3. The name brand, model number, year and serial number(s) of the equipment acquired for use at the above establishment; and
4.  A statement that your recover, recover/recycle, or recover/recycle/recharge equipment is approved under Section 609 of the Clean Air Act, that each individual authorized to use the equipment is properly trained and certified, and that the information provided is true and correct. 

Service shops must maintain on-site records proving that each person using servicing equipment has been properly trained and certified under Section 609. Additionally, they must maintain records on-site of the name and address of any facility to which they send recovered refrigerant. Records must be maintained for 3 years.

Ozone-Depleting Refrigerants: Sales Restrictions & Recordkeeping Requirements

The sale or distribution of any refrigerant containing ozone-depleting CFCs or HCFCs is restricted to technicians certified under section 608 or section 609 of the CAA. CFC-12 in a container of less than 20 pounds may only be sold to technicians certified under section 609. Any person who sells or distributes CFC-12 in containers less than 20 pounds must verify that the purchaser has obtained certification by an EPA-approved section 609 technician training and certification program.

An exception to these requirements is when small containers are purchased for resale only. In this case, the seller must obtain a written statement from the purchaser that the containers are for resale only. The statement must include the purchasers name and business address. Records must be maintained for 3 years.

In all cases, the seller must display a sign where sales occur stating the certification requirements for purchasers.

The U.S. EPA recently identified sales of a product marketed as Cool Penguin “F-12.” Sold in small cans through online retail platforms for motor vehicle air conditioner use, the mixture consisted of CFC-12, CFC-114, HCFC-142b and HCFC-22, along with non-ozone depleting components. Under current regulations, not only is the import of these cans illegal, no person may sell or distribute, or offer for sale or distribution, any regulated ozone-depleting substance that they know, or have reason to know, was imported illegally (e.g., without appropriate allowances or after the phaseout date for that chemical). For more information on the phaseout of ODS, please visit EPA ODS Phaseout.

Safe Disposal Requirements

When an MVAC system enters the waste stream, the final person in the disposal chain must remove the refrigerant, or make certain that their customer has removed it, prior to disposal. For additional information see safe disposal requirements.

Significant New Alternatives Policy (SNAP) Program

EPA evaluates alternative refrigerants under its SNAP program, established under section 612 of the CAA. SNAP lists refrigerants for MVAC systems as either “acceptable subject to use conditions” or “unacceptable.” For additional information on the individual MVAC refrigerants, and the transition from CFC-12 to HFC-134a to lower-GWP refrigerants (e.g., HFO-1234yf), see the webpage "Motor Vehicle Air Conditioning Refrigerant Transition & Environmental Impacts."

SNAP regulatory requirements related to MVAC systems is explained below:

Unique Fittings

Each SNAP-approved refrigerant is required to be used with a unique set of fittings to prevent the accidental mixing of different refrigerants. These fittings are attachment points on the car itself, on all recovery and recycling equipment, on can taps and other charging equipment, and on all refrigerant containers. An adapter should not be used to convert a fitting.

Unique fittings help protect the consumer by helping to protect the purity of refrigerant in their vehicle. For a list of the MVAC refrigerant unique fittings see "MVAC Refrigerants Fitting Sizes and Label Colors."

Applicability of Unique Fittings to Manifold Gauges and Refrigerant Identifiers

A standardized fitting may be used at the end of hoses attached to manifold gauges or a refrigerant identifier, but unique fittings must be permanently attached at the ends of the hoses that attach to MVAC system and servicing equipment.

Adapters for one refrigerant may not be attached and then removed and replaced with the fitting for a different refrigerant. The guiding principle is that once attached to a hose, the fitting is permanent and cannot be removed.

EPA Technology Transitions Program under Subsection (i) of the American Innovation and Manufacturing (AIM) Act

Technology Transitions Program

On October 24, 2023, EPA issued a final rule Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons under the American Innovation and Manufacturing Act of 2020, to implement sector-based transitions through restrictions on higher-GWP HFCs in aerosol, foams, and RACHP (refrigeration, air conditioning, and heat pump) products and equipment. The rule restricts the use of HFCs with a GWP of 150 or greater (e.g., HFC-134a) in newly manufactured and imported light-duty vehicles, medium-duty passenger vehicles, heavy-duty pick-up trucks, complete heavy-duty vans, and certain nonroad vehicles. See the 2023 Technology Transitions Final Rule. This final rule does not restrict the use of HFC refrigerants in the servicing or repair of existing MVAC systems. So, technicians that service, repair, or retrofit existing MVAC systems can continue to use HFCs.