Most of those are banned now too. In fact any R-12 advertised as a replacement is banned. The only one that is OK is Enviro-Safe. But they advertise it as an R-134a replacement. Formerly it was an R-12/ R-134 replacement years ago. I think it is propane based so some worry about it exploding. I figure if your engine compartment is on fire that bad, you have worse things to worry about. I have been using it for years as it is compatible with the OEM mineral oil our cars came with. No flushing needed. My Bonnewagon AC system is all of 45 years old, has only a used rebuilt compressor changed, and blows 30° below ambient. Not too shabby.
What gets me is, you can't evacuate a system on purpose into the atmosphere. But if your system slowly leaks all out and gets recharged every year, that is fine. I am 609 certified too, and no one could answer that for me.