Report on meeting held at DTI Conference
Tuesday 21 August 2001
It was confirmed by DEFRA that EC Regulation
2037/2000 became law within the UK in October 2000 and that the
regulation demanded the recovery of all Ozone Depleting Substances
(ODS), which included CFC and HCFC blowing agents within the foam
insulation, from Domestic Refrigeration Waste, as from 31 December
DEFRA were asked if it would be possible to
defer the start date for the recovery of ODS from Domestic Refrigeration
Waste. It was explained that this piece of Legislation was not
a Directive but a Regulation, which meant that it was directly
applicable to UK law, as written, and that it was impossible to
alter any aspects of the regulation, including the date of 31
December 2001 for the recovery of ODS from Domestic Refrigeration
DEFRA confirmed that after 31 December 2001
it would be illegal to dispose of waste domestic refrigeration
in a manner that would allow CFC or HCFC refrigerants and/or blowing
agents to vent into the atmosphere.
DEFRA confirmed that the landfilling or conventional
fragmentising of domestic refrigeration waste would be illegal
after 31 December 2001 and anyone found disposing of domestic
refrigeration waste in this manner could be liable for prosecution.
It was agreed that suitable methods of destruction
Processing via the development of
EA approved refrigeration recycling plants.
High Temperature Incineration of
the complete carcass.
Export for destruction within the
EU, subject to available capacity.
Reuse and/or Export of HCFC units
for refurbishment, if suitable (CFC contaminated units could not
be reused and must be destroyed).
Failure to comply would cause Infraction Proceedings
being levied against the UK by the EC, an option which DEFRA confirmed
was not one the UK government was prepared to take.
It was understood that there were three High
Temperature Incineration plants within the UK and that the cost
of disposing of domestic refrigeration in this manner was not
really an option, due to lack of capacity and excessive costs,
in addition to the waste of recyclable resources destroyed within
This being the case, it was understood that
there was zero capacity within the UK to comply with the regulation.
The Export for destruction was discussed, but
it was felt that there was not sufficient capacity anywhere in
the EU, with the possible exception of Germany, that could satisfy
this option. It was also felt that any spare capacity within Germany
would be utilised by closer neighbouring countries.
Whilst the Export of HCFC units outside the
EU was still allowed under the regulation, this would only be
acceptable to supply essential and critical needs only, and could
not be used as an option for the disposal of non refurbishable
It was estimated that it would take a minimum
period of about 10 months to develop approved Refrigeration Recycling
Plants throughout the UK.
All equipment not reused, exported or incinerated,
would have to be Staked and Racked until approved Refrigeration
Recycling Plants have been established.
Investment by Industry in the Refrigeration
Recycling Plants would be made available subject to DEFRA confirmation
What standard would be set for the
recovery of ODS?
How will enforcement be implemented?
The EA confirmed that anyone handling waste
domestic refrigeration after 31 December 2001 would require a
Waste Management Licence. This requirement would include those
undertaking the collection and storage through retailer return
schemes, although DEFRA indicated that it may be possible to obtain
an Waste Management Licence Exemption Certificate in some cases.
It was discussed whether IPPC permits would
be required and the EA indicated that each application would be
assessed according to its merit, and that some time in the future
IPPC controls may be put in place, if necessary.
Hazardous Waste List
As from 31 December 2001 waste domestic refrigeration
will be classified as a Hazardous Waste.
It was felt that the current method of reclaiming
the refrigerants "on location" would no longer be allowed.
This was because when reclaiming refrigerant gases it was necessary
to `open up the refrigeration circuit' causing contaminated ODS/Oil
Mixtures to be released into the environment.
2 Prepared by DARP Environmental Ltd. Back