Briefings

EC Regulation No 2037/2000 on Substances that Deplete the Ozone Layer

Background
European Council Regulation No. 2037/2000 on substances that deplete the ozone layer came into effect in October 2000. Article 16 of the Regulation requires Members States to remove ozone depleting substances (ODS) (including CFCs and HCFCs) from end of life refrigeration equipment before such appliances are scrapped. These requirements came into force immediately for industrial and commercial appliances and have applied to domestic appliances from 1 January 2002. It is estimated that up to 3 million domestic refrigerators are disposed each year.

Fridges contain ODS in two forms: 20-25% are found in the liquid refrigerant and can be extracted relatively easily using existing technology which is widely used in the UK. The remaining 75-80% are contained in the foam insulation located between the plastic inner and steel outer of the fridge and need to be removed in a controlled environment for final management.

As a result of the 1987 Montreal Protocol many manufacturers stopped using CFCs as refrigerant in the mid-1990's but HCFCs continued to be used as a blowing agent for the insulating foam for several subsequent years. For this reason the majority of refrigerators currently entering the waste stream will require treatment. However, generally, fridges manufactured more recently will be free of ODS.

Since 1 January 2001, the Regulation has required CFCs recovered from the cooling circuit to be destroyed. Recovered HCFCs can either be destroyed or reused until 2015. From 1 January 2002, the same rules applied to ODS extracted from the foam insulation.

The current UK situation
Prior to the introduction of the Regulation, around 30% of end-of-life fridges were exported in good working order to countries outside the UK and most of the remainder were fed through conventional shredders to recover the metals. The Regulation prohibits both management routes.

As a direct result of the regulatory uncertainty caused by delays to the implementation of the Regulation, there were no facilities for treating fridges in the UK when the Regulation came in to force. From 1 January 2002 the UK began to stockpile domestic fridges and Defra made available £46 million to local authorities.

There remains a backlog of stockpiled fridges for treatment, but sufficient capacity has now been installed which should ensure ongoing compliance with the Regulation for the UK. However, there is considerable uncertainty about the collection and reporting of data relating to numbers of fridges treated and the amounts of ODS recovered and destroyed. The following table shows the disposal routes for waste refrigerators in 2002 and 2003 according to official Government figures:

Statistics on the destruction of ODS from coolant and foam are not collected through the current reporting mechanism. However, based on the estimated ODS content in fridges, the average quantity of controlled substances recovered from the refrigerant and blowing agent that was subsequently destroyed in England and Wales for 2003 is thought to be around 236g per fridge.
 
Storage of waste refrigerators
Guidance to local authorities and other operators on safe storage of waste fridges, produced by the Environment Agency, is available from DEFRA at:
http://www.defra.gov.uk/environment/waste/topics/fridges/pdf/fridges_storage.pdf

A Waste Management Licence will be required for the storage of waste refrigerators pending treatment and waste refrigerators must be stored in such a manner so as to prevent damage to stored units and to prevent the release of CFC and lubricating oil. The guidance available from DEFRA sets out the measures that should be taken to ensure proper storage. Particular attention should be paid to:

• site security;
• fire prevention;
• the provision of impermeable surfaces and drainage facilities;
• removal of fridge doors if they are to be stored outside;
• removal of liquid refrigerant from the refrigerating unit; and 
• stacking height (fridges should be stored whole and stacked not more than two high).

Government guidance allows fridges to be stored on sites with a waste management licence, or on unlicensed sites as long as an application for a licence has been made. The Environment Agency has published detailed guidance on the specific requirements for storage of fridges:
http://www.environment-agency.gov.uk/business/444304/444641/595811/595886/fridges/?lang=_e

Recovery and disposal of ODS
In March 2002, the Environment Agencies published a set of draft standards for the recovery of ODS from fridges, and several companies have since introduced technologies to recover ODS during the shredding process.

The UK also possesses alternative technologies which can process fridges and destroy the ODS according to the requirements of the Regulation. For example, high temperature incineration (HTI) has the capacity to treat 3,000 end of life fridges per week. It is an environmentally accepted method and has been approved by the Environment Agency.

Other relevant links
DTi web site on controls on ozone depleting substances, including a directory of fridge treatment companies

March 2004