Supplementary memorandum submitted by
the European Commission
Thank you for the opportunity to present information
on the behalf of the European Commission at the UK inquiry on
current issues relating to the disposal of domestic refrigerators.
Please find herewith the answers to two questions that you asked
Which parts of the Annexes refer to CFCs in foam?
CFC-11 is the most common ozone depleting substance
in foam in domestic refrigerators manufactured using CFCs. CFC-12
was also used but its use in foam was comparatively rare. These
are the first two ozone-depleting substances on the list in Annex
1 of EC2037/00. The substances are grouped according to the same
groupings in the Montreal Protocol and in the previous regulation
EC3093/94 on ozone depleting substances. The groupings would therefore
be very familiar to DEFRA staff who have experience working with
ozone depleting substances in the Protocol, EC2037/00 and EC3093/94.
Could I ask for the same to be done in relation
to Articles 1 and 2? I am anxious to knowas normally documents
are read from the front to the backat what point somebody
reading this thing for the first time might have come across words
which could have suggested to them that it was the totality of
CFCs within a refrigerator that might be covered by this? The
line of questioning up to now has centred on, "Could it in
the real world actually be done?", but the early part of
the Regulation defines the territory over which you want to try
and cover and ensure that CFCs do not get released into the atmosphere,
so perhaps we could have a little clarification.
From 1 January 2002, Article 16(2) requires
controlled substances to be recovered from domestic refrigerators
using technologies and procedures described in Article 16(1).
CFCs are controlled substances and, in this case, would refer
to the CFCs in the cooling circuit. CFCs are also contained in
foam. Foam is a product that is covered by Article 16(3) which
requires controlled substances contained in products to be recovered
using technologies and procedures described in Article 16(1),
if practicable. Therefore, Articles 16(2) and 16(3) require CFCs
to be recovered from all parts of domestic refrigerators, and
Article 16(1) describes technologies and procedures for recovery
We showed in our survey results reported to
the Inquiry that it is practicable to recover CFCs from all parts
of the domestic refrigerators as this has been demonstrated by
commercial facilities operating in Member States even prior to
EC2037/00 coming into force on 1 October 2000. Recovery and destruction
of CFCs in foam in domestic refrigerators is particularly important
as typically two-thirds of the CFCs are in the foam and one-third
in the compressor.