Fridges throw spanner in WEEE works

The demanufacturing industry is calling on the EU to rewrite the rules for WEEE, claiming they need to clearly explain what should happen to the CFCs contained in end-of-life fridges and freezers. The RAL Quality Assurance Association for Demanufacture of Refrigeration Equipment Containg CFCs argues its case.

WEEE: Changes to Annex II Unacceptable

A letter from the EU Commissioner for the Environment has clarified for recyclers the question regarding acceptable treatment of waste refrigeration appliances that contain hydrocarbons.

In the opinion of the RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs, the commissioner's statement is a clear indication that the hydrocarbons from waste refrigerator and freezer appliances must be removed from the appliances and then recycled or disposed of.

Despite the very clear position held by the EU Commission, attempts are still being made to alter or reinterpret the text of the WEEE directive. The Quality Assurance Association rejects such moves, particularly those relating to the processing of end-of-life refrigeration equipment.

Background:

The current version of Directive 2002/96/EC of the European Parliament and the Council of 27 January 2003 on waste electrical and electronic equipment (WEEE) clearly sets out the way in which waste refrigeration equipment must be treated.

According to annex II, section 1 of the WEEE directive, all CFCs, HCFCs, HFCs and hydrocarbons (HCs) must be removed and then disposed of or recovered in compliance with article 4 of Council Directive 75/442/EEC. As the generic term "materials" is used at the start of section 1, it is clear that the specified minimum requirements apply to both the liquid and solid forms of CFCs, HCFCs, HFCs and HCs.

Section 1 of annex II stipulates the basic underlying requirements. The specification in section 2 relating to gases that are ozone depleting or have a global warming potential (GWP) above 15 represents additional information, but in no way calls in to question the general imperative for the removal set out in section 1.

Article 4 of Council Directive 75/442/EEC requires that waste be recovered or disposed of without endangering human health and without using processes or methods which could harm the environment, and in particular without risk to water, air, soil and plants and animals. The release of hydrocarbons into the atmosphere is therefore prohibited just as it is for CFCs, HCFCs and HFCs.

Recyclers throughout Europe responded to the publication of the WEEE directive by investing millions in new plant technology or in modifying existing plants to meet the new requirements.

The majority of plants now contain state-of-the-art technology that allows the hydrocarbons to be removed from the foam insulation together with the CFCs, HCFCs and HFCs and jointly disposed of or recovered. The statement issued by the Commission justifies the investments made by the recycling industry.

In the opinion of the RAL Quality Assurance Association it is counterproductive and wholly unacceptable that attempts are now being made to eliminate hydrocarbons from annex II, section 1 of the WEEE directive - some three years after publication of the directive and its (in some cases verbatim) incorporation into the waste legislation of many EU member states.

Even though the hydrocarbons present in fridges and freezers do not have the same environmental relevance as CFCs, there are important arguments against the release of hydrocarbons to the environment.

Minimization of VOC emissions

Isobutane, cyclopentane and other hydrocarbons contained in refrigeration equipment belong to the group of volatile organic compounds (VOCs). According to a UN ECE protocol, Germany has agreed to reduce its emissions of volatile organic compounds by 69 % by 2010.

Volatile organic compounds act as precursors in the formation of tropospheric ozone. Close to ground level, ozone is formed from the action of intense sunlight on nitrogen oxides (NOx), which come predominantly from road traffic, and on VOCs whose primary source is from their use as industrial solvents.

Other reasons why VOCs should be minimized in the environment can be readily found in the literature on environmental protection.

To restrict VOC emissions in Germany, the 31st implementation ordinance to the Federal Immission Control Act ("31. BImSchV"), which limits the emission of VOCs when organic solvents are used, came into force on 25 August 2001.

This ordinance represents the transposition into German law of the European VOC directive ("1999/13/EC") on the limitation of emissions of volatile organic compounds. Other EU member states have also transposed the VOC directive into their national law.

For these reasons, the provisions governing the operation of car shredder facilities restrict hydrocarbon emissions from such equipment to very low levels.

As a result of the legislation, major measures have been taken in many parts of industry and the skilled trades to minimize HV emissions.

From an environmental point of view, there is no reason why an annual load of more than 2,500,000 kg of hydrocarbons from end-of-life refrigeration equipment (expectation value for 2010) should be left effectively unregulated.

Environmental and climate protection will both suffer if the treatment of hydrocarbons from waste fridges and freezers is not subject to clear rules.

Given the absolute quantities involved, it is obvious that failure to provide clear guidance on this issue would send a very negative signal both to small businesses who have been working to minimize their hydrocarbon emissions and to large industrial plants where major investments have already been made to reduce HC output into the environment.

If hydrocarbons are eliminated from legislative texts, waste fridges containing hydrocarbons will end up being put through car shredders. At a time in which the consultation process for an EU recycling strategy is currently underway - a strategy that, according to press reports, will help to ensure that in future the EU has "more and improved recycling" - the utility of raising such a negative issue in the fridge recycling sector is highly questionable.

There is no doubt that the quality of recycled materials and the income that can be generated by their subsequent sale is higher and more reliable from plants that have been designed specifically to handle waste fridges than from car shredder units.

RAL has already drawn attention to a further argument that the recycling rates and process monitoring demanded by the WEEE directive cannot be realized when non-specialist plants are used.

The RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs argues strongly for the retention of the existing phrasing regarding the removal of CFCs, HCFCs, HFCs and HCs in section 1 or annex II of the WEEE directive.

It is unacceptable to abandon the environmental protection ideals that underlie the current version of the WEEE directive and related national regulations and laws passed by EU member states.

The RAL Quality Assurance Association believes that failure to maintain a systematic approach to producer responsibility when recycling waste fridges would call into question the voluntary commitment agreed by European fridge manufacturers in the early 1990s to replace the climate killers CFCs, HCFCs and HFCs with other more benign materials.

Based on its discussions so far with European environmental agencies, the RAL Quality Assurance Association is very confident that current attempts to eliminate reference to hydrocarbons in annex II are unlikely to succeed.

For further information please contact:
RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs,
B.P. 1228, 29, avenue de la Gare,
L-1012 Luxembourg,
Tel.: +352-(0)488361-41 Fax: +352-(0)488361-42
www.ral-online.org info@ral-online.org

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