In January, European appliance industry association CECED, the WEEE Forum and the European Electronics Recyclers Association (EERA) agreed on a set of specifications with respect to the collection, transportation, storage, and treatment of end-of-life household cooling and freezing appliances containing hydrocarbons (HC) such as cyclopentane. The three organizations developed the specifications because Directive 2002/96/EC on waste electrical and electronic equipment (WEEE) does not specify how appliances containing hydrocarbons should be treated in the recycling process.
“According to Annex II.2 of the Directive, hydrocarbons in gaseous form that are ozone depleting or have a GWP above 15 are subject to (proper) extraction and (proper) treatment,” Luigi Meli, director general of CECED tells APPLIANCE. “Therefore, those hydrocarbons in gaseous form that are non-ozone depleting and have a GWP below 15 are not subject to extraction or treatment. In other words, hydrocarbons in gaseous form that are non-ozone depleting and have a GWP below 15 can be released into the atmosphere (albeit in a controlled manner), but need not be ‘extracted.’”
Because hydrocarbons are flammable, the organizations say the new specifications were created to ensure that health and safety requirements are respected and that any release of HCs into the environment during the treatment process complies with all environmental laws.
Meli says this means that recycling plants for cooling appliances must be designed to accomplish four main tasks: (1) protect workers against fire and explosions or other health hazards, (2) prevent the release of ozone-depleting gases such as CFCs and HCFCs, (3) prevent the release of gases with a significant global warming potential such as HFCs, and (4) meet air quality limits.
“It is, however, not justifiable on environmental grounds that hydrocarbons used in cooling appliances have to be extracted from the appliances and treated in dedicated facilities,” Meli notes.
Since the specifications were announced, there has been some speculation within the industry regarding the motive behind them. Some have gone so far as to claim the specifications call for a breach of the WEEE directive.
Meli says this is not the case at all. “We definitely challenge the allegation that CECED is inciting stakeholders to disregard applicable law,” he tells APPLIANCE. “CECED has never disputed the claim that ozone-depleting substances such as the fluorinated gases CFC and HCFC, or gases with a substantial GWP, such as HFC, require extraction and proper treatment. What we do challenge is the claim that there is an obvious environmental benefit in extracting and treating hydrocarbon gases in the foam.”
To address industry concerns, Meli says that CECED has obtained technical guidance to support the claim that hydrocarbons in the foam are not a liquid, but a gas. “We have also obtained legal clearance of our position in relation to the interpretation of Annex II,” he explains. “And finally, we registered a trend among stakeholders in the Technical Adaptation Committee to interpret the provisions in Annex II related to gases in refrigeration equipment as requiring different approaches and treatment process specifications, which are in line with those issued by CECED, the WEEE Forum and EERA.”