Refrigerant waste: traceability, regulations

Since 2011, used refrigerant fluids have been considered as hazardous waste, requiring a BSD (bordereau de suivi) for transport and treatment.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
04.10.2015
Contents
Example H2
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Since 2011, halogenated refrigerants are no longer among the hazardous wastes exempted from the obligation to issue a hazardous waste tracking slip (BSD). This new regulatory constraint remains little known and little respected when used refrigerant waste is collected by refrigeration service providers. To remedy this situation, the French Ministry of Ecology plans to merge the BSD with the intervention sheet, which is also required for any handling of refrigerants.

Refrigerant waste: what do the regulations say today?

Since its amendment by Decree no. 2011-396 of April 13, 2011, Article R. 543-45 of the French Environment Code no longer exempts CFC, HCFC or HFC halogenated refrigerants from the BSD requirement. All holders of refrigeration and air-conditioning equipment are now required to issue a BSD using the Cerfa 12571 form, whenever they hand over a used fluid to a refrigeration service provider responsible for servicing their equipment, with a view to its regeneration or destruction.

As with all hazardous waste:

  • The BSD must accompany the refrigerants to the treatment site, and be completed by the various parties involved: transporter/collector, transit facility and disposal or recovery facility.
  • A copy of the BSD must be returned to the issuer within one month to confirm receipt and/or treatment of the used fluid.
  • The original or copy of the BSD must be kept for 5 years.

How do I fill in the BSD?

The issuer of the BSD (box 1) must be the waste producer, i.e. the owner of the equipment containing the refrigerant removed. By way of derogation, it can be the refrigeration service provider if it acts as a collector of small quantities as part of a collection round. In this case, the various refrigerant producers benefiting from this collection service fill in Appendix I of Cerfa 12571. Waste code 14 06 01 - Chlorofluorocarbons, HCFC, HFC must be used to complete box 3 of the BSD (Waste designation), indicating "gaseous" and "liquid" for consistency.

With regard to box 4 (Entries under regulations for the transport of dangerous goods), several UN numbers are possible depending on the fluid:

  • R 12 => A 1028, WASTE DICHLORODIFLUORO-METHANE (REFRIGERANT GAS R 12), 2.2
  • R 22 => UN 1018, WASTE CHLORODIFLUORO-METHANE (REFRIGERANT GAS R 22), 2.2
  • R 134a => UN 3159, WASTE TETRAFLUORO-1,1,1,2 ETHANE (REFRIGERANT GAS R 134a), 2.2
  • R 407c => UN 3340, WASTE REFRIGERANT GAS R 407C, 2.2
  • Other fluids => UN 1078, WASTE REFRIGERANT GAS, N.O.S. (+ chemical names of main components), 2.2

In box no. 5 of the BSD (Packaging), the "Other" box must be ticked, specifying that cylinders are involved and their number. Finally, the net weight of refrigerant recovered in tons must be indicated in box no. 6 (Quantity).

FOCUS ON ADR REQUIREMENTS FOR THE TRANSPORT OF HALOGENATED REFRIGERANTS

All halogenated refrigerants fall into transport category 3 under chapter 1.1.3.6 of the ADR. Consequently, as long as the net quantity of fluid loaded on board the vehicle remains below 1000 kg, the transport operation is partially exempted from certain provisions of the ADR concerning in particular :

  • the vehicle's ADR signage
  • the driver's ADR training certificate
  • safety instructions on board

However, the following still apply:

  • requirements for the design, inspection and labelling of the cylinders used
  • drawing up a transport document (= BSD for used fluids)
  • a fire extinguisher on board the cabin

And tomorrow?

In response in particular to the difficulties reported by refrigeration professionals in drawing up and monitoring BSDs, the French Ministry of Ecology has been working since 2012 on the creation of a Cerfa form specific to this sector, acting as both BSD and intervention sheet. As a reminder, this type of intervention sheet must be drawn up by refrigeration specialists for any operation involving the handling of refrigerants, including draining a refrigeration circuit to recover fluids.

The new Cerfa form would simplify administrative procedures by avoiding the need to fill out two documents containing, in effect, several common items of information, in particular the nature, quantity and destination of the fluid recovered. In view of the draft "F-Gas" decree submitted for public consultation in early 2015, this reform is no longer very far off. The proposed amendment to article R. 543-82 of the French Environment Code calls for the adoption of a ministerial order defining the future Cerfa form, merging the intervention sheet and the BSD.

Pending the publication of this decree, however, operators of refrigeration and air conditioning equipment are still strongly advised to ensure that a BSD is systematically drawn up on departure from their site when refrigerant waste is collected. The penalties incurred are far from negligible: in addition to a fine of up to €750 for failing to draw up a BSD, the absence of a transport document under the ADR could expose the shipper concerned to a penalty of 1 year's imprisonment and a €30,000 fine. All the more reason to ignore the objections and misgivings expressed by some refrigeration service providers.

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