December 2005

RAL policy confirmed

In a recent development in the debate on the interpretation of the WEEE directive regarding the proper treatment of refrigeration equipment containing hydrocarbons, EU Commissioner Stavros Dimas has verified that the approach adopted by the RAL Quality Assurance Association is in complete compliance with the intent of the directive. According to the Commission, there is an unequivocal obligation to remove liquid hydrocarbons such as cyclopentane from end-of-life fridges and freezers.

The RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment Containing CFCs wrote to the Environment Commissioner in July of this year requesting clarification about the obligatory treatment of waste refrigeration equipment as specified in annex II of the EU directive. In his written reply at the end of September, Commissioner Dimas shared the Quality Assurance Association’s concerns regarding the uncontrolled release of hydrocarbons into the environment when hydrocarbon-containing fridges are treated in, for instance, waste shredders.

In the opinion of the Commissioner Stavros Dimas “the term “removal of all fluids” makes it clear that not only the gases mentioned in annex II, No. 2 are to be extracted from refrigeration equipment, but also any kind of liquid contained in the cooling circuits or insulation materials. This would apply even if a fluid was not mentioned in the list of substances under Annex No. 1.“ According to the Commissioner, there is, therefore, a “clear obligation to remove liquid hydrocarbons, such as cyclopentane, from fridges and freezers.”

The RAL Quality Assurance Association has already pointed out in numerous discussions with environment ministries and agencies in EU member states and in its talks with manufacturers’ associations that annex II of the WEEE directive explicitly and unambiguously mentions the removal of all hydrocarbons at the same time as it refers to the extraction of CFCS, HCFCS and HFCs – clearly putting the mandatory removal of these substances on an equal footing.

According to Christoph Becker, secretary to the RAL Quality Assurance Association, the discussions on the proper treatment of waste refrigeration equipment should now be concluded. The clarification from the EU Commission not only sets out the relevant legal framework in an unambiguous way, it also makes clear that it is of major environmental concern whether there is uncontrolled release of hydrocarbons such as pentane into the environment or whether these substances are removed from waste appliances in specialized plants for subsequent recycling or environmentally benign disposal.

In the interests of uniform EU-wide environmental and climate protection and in the interests of free and fair market competition amongst market players in the member states, the Commission’s interpretation of the law should be implemented as soon as possible within Europe.

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