RAL praise for German and Austrian governments
Two official responses to the European WEEE Directive contain clear statements regarding the treatment of waste refrigeration appliances containing either chlorofluorocarbons or hydrocarbons
That both countries have categorically rejected the separate treatment of these two types of refrigeration appliance is expressly welcomed by the RAL Quality Assurance Association for the Demanufacture of Refrigeration Equipment.
In the opinion of the RAL Quality Assurance Association, the studies on which the German and Austrian statements were based offer little room for interpretation and provide clear-cut specifications for the EU Commission when revising the WEEE Directive.
As part of the stakeholder consultation process, stakeholders in the European WEEE market were given until June 5th to submit their views on the main proposed changes to the WEEE Directive.
So far, more than 150 stakeholder statements have been uploaded by the EU commission to the CIRCA website.
The RAL Quality Assurance Association also participated in the consultation process.
The statements submitted area available at: http://circa.europa.eu/Public/irc/env/weee_2008_review/library?l=/stakeholder_opinionsandvm=detailedandsb=Title.
On the question of the treatment of end-of-life refrigeration appliances, the statements issued by the Austrian and German governments are remarkably clear.
The comments submitted by the Austrian ministry contain the following passage (quoted verbatim):...
As regards refrigerators, it has to be pointed out that refrigerators containing HC and CFC or HCFC as blowing agent should be treated in the same plants due to the risk of failures in sorting, which take place in any case.
Besides, some refrigerators contain CFC as blowing agent in the cabinet and HC in the front door or vice versa.
A treatment of refrigerators containing HC and CFC or HCFC as blowing agent in shredder plants where no separate collection of the blowing agent takes place, should not be allowed in any case.
The statement from Germany is consistent with the Austrian viewpoint.
The following is taken from the German response to Section D.
Requirements relating to the treatment of waste refrigeration equipment.
Selective treatment must ensure that the goals of removing pollutants and resource efficiency are met.
All waste refrigeration appliances (those containing CFCs and those free of CFCs) shall be collected together and processed jointly in a treatment plant designed for treating CFC-containing appliances, as error-free sorting of the appliances in the waste stream appears not be possible and priority must be given to the collection of CFCs.
Both statements are obviously referring to the life cycle assessment (LCA) published in March of last year by the environmental research institution Oko-Institut e.V.
The LCA study rejects the pre-sorting of incoming waste refrigeration appliances on environmental grounds and argues for the joint processing of all the different types of refrigeration appliances.
The statement submitted to the EU Commission by the RAL Quality Assurance Association contained the very same arguments and the Quality Assurance Association welcomes the unambiguous wording chosen by the government ministries in Vienna and Berlin.
It remains wholly inexplicable why producer associations should choose to continue to support the pre-sorting and separation of appliances in the incoming waste streams, despite the compelling evidence arguing for the joint processing of appliances.
In view of the fact that none of the scientifically based environmental evidence supports the pre-sorting and separation of appliances, the RAL Quality Assurance Association believes that waste refrigeration appliances must be handled and treated in the manner advocated by the Austrian and German governments.
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