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REPORT
Activating Circular Economy for Sustainable Cooling
Legislation and Practices for End-of-Life Management of Refrigerants and Other F-gases in Norway and the EU
Torgrim Asphjell, Alice Gaustad, Lisbeth Solgaard, Alina Danielsen, Kay Riksfjord, Geir Sørensen, Annika Steien, and Thomas Vandenbroucque

Suggested Citation: Asphjell, Torgrim, Alice Gaustad, Lisbeth Solgaard, Alina Danielsen, Kay Riksfjord, Geir Sørensen, Annika Steien, and Thomas Vandenbroucque. 2023. Activating Circular Economy for Sustainable Cooling: Legislation and Practices for End-of-Life Management of Refrigerants and Other F-gases in Norway and the EU. Norway: Norwegian Environment Agency

Overview

The report gives an overview of how waste refrigerants are handled in practice in Norway and describes the legal framework underpinning this infrastructure. It focuses on the recovery of gases, including sulphur hexafluoride (SF6) and other gases beyond the refrigeration sector, from the equipment taken out of service and their subsequent handling in terms of collection and destruction. The report gives examples from Norway, the European Union, and other regions that can serve as a good precedent for the Indian context. It can also aid a wider audience dealing with end-of-life management of ozone-depleting substances or fluorinated greenhouse gases.

This report is the Norwegian contribution to the work package on "Support recovery, recycling, reclamation and disposal of refrigerant gases in India" of the "Future Refrigeration India" or "INDEE+" project, which is performed jointly between the Council on Energy, Environment and Water (CEEW) and Norwegian Environment Agency (NEA).

Key findings

Norway has the relevant legislation, incentives and infrastructure to collect and destroy refrigerants at end-of-life. Generally, the recovery rate is high, and according to the Norwegian experience, real-life recovery rates will depend upon factors such as:

  • Enforcement (incl. information campaigns, audits and sanctions)
  • Available equipment and personnel skills
  • Economic incentives (refund, reimbursement, value of waste gas for energy or reuse)
  • The GWP or ODP of the gas if incentives are coupled with environmental characteristics
  • Logistics and volumes (size of charges or batches, on-site vs centralized recovery)
  • Required safety measures (flammability, toxicity of gas)
  • Destruction costs (or income)
  • Existing systems for general waste recycling (for example, for vehicles and WEEE)
  • Technical recovery efficiency (completeness of recovery, leakages during handling)

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As India’s demand for cooling continues to surge, it is critical to ensure that this growth is sustainable. With Norway’s expertise in sustainable refrigerant management, we believe that the experiences and practices from our country can play a significant role in guiding India’s path towards HFC phase-down. By working together and sharing knowledge, we can create a more sustainable future for all.

Executive summary

The Montreal-protocol on Substances that Deplete the Ozone Layer had substantial effects on the use of CFC and HCFC refrigerants and other ozone-depleting substances. The Kigali amendment to the protocol agreed upon in 2016 introduced similar constraints on the use of HFC-refrigerants based on their contribution to climate change. However, these global agreements focus on restrictions on production and use, and consequently Norway has implemented additional legislation and measures on collection and destruction of waste refrigerants and other gases to avoid atmospheric release.

Norway has followed the usual Montreal-protocol path of phasing out CFCs, the transitional substances in the HCFC group and other ozone-depleting substances. We are now in a situation where the climate gases in the HFC group are gradually being replaced by natural refrigerants or synthetic refrigerants with lower contribution to global warming. However, there will for many years to come be large quantities of waste HFCs, and also considerable amounts of ozone-depleting substances, that need to be recovered and destructed.

In this report we will use the main gas categories Ozone-depleting substances (ODSes) and other fluorinated greenhouse gases (F-gases). The latter group includes HFCs and SF6. Focus will be on the use as refrigerant in refrigeration- and air-conditioning equipment, including heat pumps.

Norway is not a member of the European Union but is connected to the union by the European Economic Area (EEA) Agreement. A consequence of this is that most EU legislation is also implemented in Norway. The EU regulations and directives on ODSes, F-gases, waste and industrial pollution are incorporated into Norwegian national regulation. In addition, Norway has implemented some domestic only regulation and measures.

Norway introduced the first regulations to limit the import and use of CFCs in 1979. Subsequent legislations were adopted to include the other ODSes. These had requirements that the used ODSs can be handed in for safe destruction free of charge. This resulted in the establishment of the Norwegian Foundation for Refrigerant Recovery (SRG). As of the year 2002, Norway implemented the EU regulations on ozone depleting substances, including the Regulation No 2037/2000 in 2002 and the revised Regulation No 1005/2009 in 2013. This latter regulation introduced further restrictions on the use of all ozone depleting substances controlled under the Montreal Protocol to ensure full phase out of the substances according to the obligations under the Protocol.      

The EU F-gas regulation was adopted by the EU in 2006 and implemented in national Norwegian legislation in 2010. The intention behind the regulation is to limit the emissions of HFCs, PFCs and SF6 through containment, recovery, and restrictions of use in products, equipment, and applications. The regulation is supplemented by implementing regulations on topics such as leakage checking, labelling, reporting and certification.  

According to the F-gas regulation HFC refrigerants shall be properly recovered by certified personnel from all stationary refrigeration and air conditioning equipment and SF6 shall be recovered from gas insulated switchgears (GIS). Recovery is also mandatory for most other gases and uses, with foam blowing agents being the most notable exception.

A revised EU F-gas regulation entered into force in the EU in 2015. This regulation introduced further measures to reduce emission, including a phase-down scheme for HFCs. Norway implemented this regulation in 2018, as well as its own phase-down scheme in accordance to its compliance obligations with the Montreal protocol.

While the F-gas regulation constitutes a strong legal basis for recovery of gas, Norway has also established a domestic incentive by a tax and refund scheme for HFCs and PFCs. All import of HFCs and PFCs in bulk and in products is taxed.

The tax also applies to production, but since Norway has no domestic production of HFCs and PFCs (or any other F-gas) it is in practice a tax on import. The level of the tax is according to the global warming potential (GWP) of the gas and is tied to the CO2-tax for mineral oils and was 766 NOK (appr. 6000 INR) per GWP weighted tonnes in 2022. The tax is refunded to those who deliver HFCs or PFCs for destruction. There is no documentation requirement that the tax was paid. But there are requirements as regards documentation of the amount and composition of the gas destructed.

The requirements as regards treatment of the waste gases after recovery from products and equipment is found in the national waste regulation, which covers collection, recycling, destruction, export and other aspects as regards all types of waste. This is largely based on the EU Waste Framework directive and implementing acts.

The waste regulation includes a separate chapter om hazardous waste. Waste CFCs, HCFCs and HFCs in bulk or in waste electric or electronic products (WEEE) are classified as hazardous waste and specific requirements for storage, transport and treatment apply. Personnel handling the waste shall have documentable adequate skills and undertakings shall have a permit to handle hazardous waste and deliver the waste to an approved undertaking at least once a year.

A system for collection, recycling and other treatment of WEEE was established in Norway in 1999. This system is based on the Extended Producer Responsibility, which requires that all importers and producers of relevant products must be member of a Producer Responsibility Organization, which is responsible for establishing and operating of a system for collection and treatment of WEEE. Household appliances such as fridges, freezers and domestic air conditioners or heat pumps (domestic AC/HP), as well as smaller gas insulated switchgears (GIS) containing SF6 can be handed in free of charge at collection facilities for subsequent environmentally sound treatment. The regulation specifies that CFCs, HCFCs, HFCs and other gases that are ozone-depleting or have a GWP of more than 15 shall be recovered at an early stage in the treatment process.

For collection of vehicles by end-of-life, a similar producer responsibility scheme has been established. The regulation requires that vehicles shall be delivered free of charge. As an extra incentive a compensation is being paid to those delivering the car, financed by governmental subsidies. In 2022 this amounted to 3000 NOK (appr. 24 000 INR) for a passenger car.

Enterprises that collect, treat, or destroy waste gases or other waste need an emission permit to operate. These permits, which come in addition to the specific legislation on F-gases and ODSes and the general regulations on waste, set specific requirements for operation and management of the plant. All undertakings with emission permits are audited regularly, evaluating all aspects of the permits as well as compliance to relevant regulations.

In addition to the environmental regulation, other legislation and policy, on safety and working environment in particular, is also important and will indirectly affect environmental performance as well.

In Norway there are primarily three companies involved in recovery and collection of gas on a large scale, commercial basis and each of them have a somewhat different approach:

  • Norwegian Foundation for Refrigerant Recovery (SRG) collects ODSes and HFCs in bulk. This company was established in 1991 as part of the Norwegian implementation of the Montreal Protocol and has a nationwide network for collection and consolidation of waste- or surplus refrigerants, which is sent to France for final destruction. They are the sole commercial provider of refund for HFCs in bulk and are to a large degree financed by the governmental refund scheme. SRG was established before the refund scheme entered into force and they also have other activities which provide finance for their operation. SRG has a subsidiary, Isovator, that analyze the gas eligible for refunds or for other purposes. Isovator also issues mandatory F-gas certificates for personnel and companies and training attestations on behalf of the government.
  • Stena Recycling is a company that treats all kinds of WEEE. Home appliances and small commercial appliances containing f-gases, such as refrigerators, freezers and domestic AC/HP, are sent to their facility in Sweden, where refrigerants and foam-blowing agents are recovered and destroyed on-site. On their Norwegian site, they have a vacuum chamber for complete recovery of SF6 from medium voltage GIS. They also serve as a collection point for surplus SF6 in cylinders.
  • Revac is another company specializing in treatment of WEEE. They have a newly installed "Fridegeline" for the collection of refrigerants from freezers, fridges, domestic AC/HP and other home appliances (step 1) and foam blowing agents from insulation used in some of these appliances (an optional step 2). The recovered refrigerant is handled by SRG. Foam blowing agents are sent to a destruction facility in Germany.

In addition to the three companies mentioned above, vehicle- and metal recycling companies also perform related activities.  

Much of the first line collection of products containing ODSes and F-gases is done by municipal waste companies, local retailers in the case of WEEE, car collection sites or businesses in the refrigeration and air conditioning (RAC) sector. Businesses in the RAC sector also collect gas recovered on-site in cylinders for delivery into the SRG system.

Norway has the technical capacity to destroy refrigerants by co-processing in cement kilns. However, for logistical reasons today all ODSes and F-gases collected in Norway are sent to other European countries for destruction or, possibly, reclamation.

Destruction is done thermally by incineration or by high temperature plasma arc technology. In these processes, the chemical compounds are destroyed by breaking them down to simpler molecules. The process must be carefully controlled to avoid new toxic compounds being formed during the process. CFCs and HCFCs contain chlorine that might contribute to the formation of extremely toxic dioxins and furans, and emissions of particulate matter and chlorine, fluorine and other compounds, are to be monitored regularly. Only ODS destruction technologies approved by the Montreal Protocol are used and the facilities are covered by the EU directive on the incineration of waste.

The gas collected by SRG (including the refrigerants from Revac) is sent to a hazardous waste treatment plant in France, while co-processing in cement kiln in Norway has been used previously. Refrigerants and foam blowing agents from Stena Recycling is destroyed on-site in Sweden.

Recovered SF6 is sent to Sweden or Germany. Reclaimed halon fire extinguishing gas is exported for subsequent critical reuse according to the Montreal protocol and the EU regulation on ozone depleting substances. In addition to the established main lines for collection and destruction of gas described here, some surplus or waste gas might be handled independently by importers or other companies.

Legislation by itself is not enough to assure high recovery. The real-life recovery rates will depend upon factors such as:

  • Enforcement (incl. information campaigns, audits and sanctions)
  • Available equipment and personnel skills
  • Economic incentives (refund, reimbursement, value of waste gas for energy or reuse)
  • The GWP or ODP of the gas if incentives are coupled to environmental characteristics
  • Logistics and volumes (size of charges or batches, on-site vs. centralized recovery)
  • Required safety measures (flammability, toxicity of gas)
  • Destruction costs (or income)
  • Existing systems for general waste recycling (for example for vehicles and WEEE)
  • Technical recovery efficiency (completeness of recovery, leakages during handling)

Summary Figure 1: Recovered volumes of gas in Norway 2009-2021 measured in metric tonnes.

Summary Figure 2: Logistics chain for ODSes and F-gases in a cradle-to-grave perspective. The Text at the top describes the legislation associated with each phase in the lifecycle. This example is based on Norwegian practices and experience, but for the purpose of illustration and simplification some minor modifications have been made. SF6 is not included in the figure.

1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32000R2037&from=EN

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R1005&from=EN

For an overview of EU legislation to control F-gases, see: https://ec.europa.eu/clima/eu-action/fluorinated-greenhouse-gases/eu-legislation-control-f-gases_en

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32008L0098&from=EN

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