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Is It Legal to Replace HFC-134a with HC-12a ® , Duracool 12a, or OZ-12 ® ; under the SNAP Regulations?
Under EPA's Significant New Alternatives Policy (SNAP) program, it is illegal to replace CFC-12 with HC-12a® in any type of air conditioning system, including car and truck air conditioners. Similarly, it is illegal to replace CFC-12 with HC-12a in any refrigeration system with the single exception of industrial process refrigeration.
The question of the legality of replacing HFC-134a with HC-12a® is generally asked in reference to a procedure where CFC-12 is removed from a car or truck air conditioner, HFC-134a is charged into the system and then immediately removed, and HC-12a® is then charged into the system. This procedure is referred to as a "sham retrofit" and is illegal. Regardless of how long the vehicle contains HFC-134a, if it arrives at a shop containing CFC-12 and leaves containing HC-12a®, that is clearly an illegal sham retrofit. Other than this case, EPA and hotline staff cannot determine the legality of replacing HFC-134a with HC-12a® based solely on a phone call or letter. Rather, the determination depends on many factors, including the nature of the retrofit from CFC-12 to HFC-134a, the reason for the retrofit, and the exact procedure and timing involved.
If, despite this information, you plan to change a car from HFC-134a to HC-12a®, you should consider the following:
- The following 17 states ban the use of flammable refrigerants like HC-12a in motor vehicle air conditioning, regardless of the original refrigerant: Arkansas, Arizona, Connecticut, Florida, Idaho, Indiana, Kansas, Louisiana, Maryland, North Dakota, Oklahoma, Texas, Utah, Virginia, Wisconsin, Washington, and the District of Columbia.
- Cars and trucks built after 1994 are designed to use HFC-134a, and there is no reason to retrofit a new vehicle that contains HFC-134a. According to the auto manufacturers, changing the refrigerant will void the warranty and may damage the system. If the air conditioner on a new car or truck is not working, consult a qualified mechanic or your dealer.