Waste temperature exchange equipment – appropriate measures: are you ready?

Refrigerator waste.

Dr Richard Hooper, Principal Environmental Consultant, Mayer Environmental, takes a deep dive into Waste Temperature Exchange Equipment appropriate measures and asks are you ready.

For more than two decades, innovation in technology and rising industry standards have helped transform the way that fridges, freezers and air conditioning units – or Waste Temperature Exchange Equipment (WTEE) – have been recycled in the UK.

The next stage of this journey has now arrived with the publication of a new set of “Appropriate Measures” by the Environment Agency.

The updated regulations will require WTEE recyclers to appoint a third-party auditor to review and approve their data, increasing the accuracy of reporting and creating a level playing field for those businesses operating at the highest possible standards.

For this reason, Mayer Environmental is confident that the Environmental Agency’s new Appropriate Measures can have a beneficial impact on both the industry as a whole and, more specifically, individual businesses which engage with the new requirements positively.

What are “Appropriate Measures”?

Refrigerator waste

Appropriate Measures are being introduced into Environmental Permits by the Environment Agency for operators in a range of industries to increase standards and improve the accuracy of data.

In essence, these Appropriate Measures are extra standards that must be implemented by the facility to ensure that they are appropriately recovering and disposing of waste to the best available techniques (BAT) at waste installation facilities – such as those permitted under the European Industrial Emission Directive (2010/75/EU).

According to the Environment Agency’s own definition, Appropriate Measures are “the standards that operators should meet to comply with their environmental permit requirements.” There are quite a few already published, for example, metal shredders, biological waste treatment, non-hazardous inert waste and WEEE as examples, with others due to arrive over the coming months and years.

As the measures are specific to each permitted operation – such as “Treating metal waste in shredders” and “Chemical waste” – the exact implication and required measurements will vary on the type(s) of waste treated and the age of the facility.

One of the most recent sets of Appropriate Measures to be published is specific to WTEE and installations that transfer or treat such equipment. These Appropriate Measures relate to the recycling and recovery of fridges and freezers, portable air-conditioning units, equipment that dispenses cold products, dehumidifiers that use cooling gases and heat pump tumble driers.

While fridges and freezers account for the vast majority of WTEE, the number of end-of-life air-conditioning units and dehumidifiers reaching recyclers is expected to increase substantially in the future.

For this reason, prior to full publication, the Environment Agency updated the WCE acronym (Waste Cooling Equipment) to WTEE.

Appropriate Measures for WTEE

One unique element of the Appropriate Measures which have been published for WTEE is that recyclers’ reported data must undergo an independent third-party audit.

As a leading consultancy for the waste and recycling industry, Mayer Environmental stands ready to provide both this third-party auditing service and to help companies maintain the high standard of reporting required.

After a short delay, the Appropriate Measures for WTEE recyclers were implemented in late 2022 – however, in theory, every fridge recycler should have been monitored since August 2022. While Environment Agency teams are currently very busy it is only a matter of time before the first WTEE recycler receives a request for this audited data.

A good third-party auditor will help you prepare.

Implementing the requirements of the Appropriate Measures will depend on whether a facility is already operating or in the planning or construction phases.

For existing operations, the Environment Agency will be assessing individual facilities through a series of permit reviews. For new installations, the Appropriate Measures will have to be implemented and approved during the commissioning stage.

Failure to meet the requirements of Appropriate Measures will be noted, with improvement plans and strict timescales for compliance written into the permit.

How WTEE recycling works

Temperature exchange equipment, regardless of whether it is a fridge freezer, dehumidifier or air-conditioning unit, contains gases within the cooling circuit and it is these gases (refrigerants) that must be removed from the waste equipment before it is then correctly disposed of via methods such as incineration.

WTEE may also contain insulation materials to maintain a consistently cool temperature, usually in the form of blown foams (blowing agents) that must also be captured and correctly disposed of.

The most common types of equipment entering these waste installations are fridges and freezers and the operations used to recover the remaining gases are completed in two stages, simply referred to as Stage 1 and Stage 2.

Stage 1 (also known as degassing), involves puncturing the compressor and removing the fluids and gases under pressure. Stage 2 operations (referred to as destruction) predominantly use shredding technology to break the carcass of the unit into smaller pieces, thereby liberating the constituent parts from each other. A typical “intact” fridge or freezer (one unit equivalent) composition is shown in Table 1.

Table 1: Typical fridge composition (one unit)

Material Wt/Wt %
Ferrous metal 60
Plastic 13
Foam 10
Other 7
Non-ferrous metal 3
Copper 3
Glass 1
PVC (Cables) 1
Oil 1
Refrigerant fluid <1

The average weight of fridges and freezers entering recycling (recovery) facilities at the current time range from 19kg, for an under-counter cooling unit, up to 60kg (and greater) for a double-door American-style fridge freezer. The typical gross unit weight entering the recovery process has been calculated at 35kg.

Recovering harmful gases

As stated above, the gases which WTEE recyclers must recover from discarded units include the refrigerant from the compressor oil and the blowing agent present in the insulation (foam).

In the past two decades, manufacturers have transitioned from using ozone-depleting CFCs in compressors – or volatile hydrofluorocarbons (HCFCs) – and replacing these gases with pentane (volatile hydrocarbons).

While pentane, which remains the preferred gas for manufacturers today, does not have the same ozone-depleting qualities as CFCs, it remains a potentially harmful gas which must be captured and disposed of with care.

Industry-based refrigerant analysis calculates a 40g/unit charge for volatile hydrocarbons (VHC) compressors and a 100g/unit charge for volatile fluorocarbons (VFC) compressors.

Industry-based theoretical blowing agent charge weights, meanwhile, have been provided by the Environment Agency below (Table 2).

The number of VFC units has been in steady decline since the introduction of bespoke WTEE recycling operations in 2002, with CFC-based compressors reaching their end-of-life being replaced by pentane-based alternatives. Currently, the ratio of VFC:VHC units is 1:9 (2021 figures), reversing the ratio that existed when WTEE recycling began in 2002.

The table is based on data within the Appropriate Measures criteria, with each column representing a different unit type. Unit “types” refer to the storage capacity of the fridge, freezer or other equipment which is recycled: Type 1 < 0.18 m3, Type 2 > 0.18 m3 and < 0.35 m3 and Type 3 > 0.35 m3 and < 0.5 m3 m3 and Type 4 > 0.5 m3. The data is again separated into VHC and VFC gases.

Table 2: Theoretical blowing agent content

WTEE Type  Type 1  Type 2  Type 3 and 4 
VFC (g)
Foam content  3,140 4,180 5,230
Blowing agent content  257 343 429
VHC (g)
Foam content  3,300 6,300 8,300
Blowing agent content  125 239 315

The figures above are calculated on the basis that the blowing agent content of VFC foam is 8.2% wt/wt (82g per kg) and the blowing agent content of VHC foam is 3.8% wt/wt (38g per kg).

Overall, the gases that require collection from end-of-life WTEE typically account for a very small percentage of the overall weight of the individual unit.

The Environment Agency’s Appropriate Measures require data on the following elements of the WTEE process:

  1. General management (i.e. routine and ongoing performance review)
  2. Waste pre-acceptance, acceptance and tracking
  3. Waste storage and handling (maximum storage times and safe/stable storage)
  4. Waste treatment
  5. Process monitoring
  6. Emission monitoring

While all of the above are integral aspects of the respective environmental permit activities, those that are found within the treatment section are likely to come under the closest scrutiny under the new Appropriate Measures.

Stage 1 (degassing) – the treatment process must achieve and demonstrate a refrigerant removal and recovery rate of at least 90%

Stage 2 (destruction) – the treatment process must achieve and demonstrate both of the following:

  • Blowing agent removal and recovery rates of 90% or more, based upon an annual assessment of a selected sample of WTEE.
  • Removal and recovery rate of 80% or more, based upon a monthly assessment of the WTEE treated during that period.

What does this mean for your WTEE recycling operations?

Air conditioner

Whether your business is an established multi-site recycling company with decades of experience or a new player looking to disrupt the WTEE recycling market, these targets are ambitious.

To achieve 90% recovery of refrigerant from a VFC unit, as a minimum, 90g must be collected and weighed – for a VHC unit the recovery must be 36g. As mentioned above, the average unit weight is 35,000g (35kg) so the amount of gas to be recovered is very small, at 0.3%/unit for VFC compressors and 0.1%/unit for VHC compressors.

These installations record weights in metric tonnes and the most accurate balances for collecting refrigerant gases only weigh in increments of ± 0.1kg (100g).

Consider also the Stage 2 recovery, this time using the 80% average recovery using a monthly figure. Although these numbers are an order of magnitude higher (VFC foam is 82g per kg and VHC foam is 38g per kg) they are again small numbers – 0.73-1.22%/unit and 0.35-0.9%/unit for VFC and VHC respectively – given the accuracy of the balances employed.

Attention to detail is therefore key, given the low charge weights of the units (40g for VHC compressors, or 0.1%/unit) and accuracy of balances employed.

Recording and submitting Appropriate Measures data

Collecting all of this data may sound relatively simple in theory, especially as these dedicated facilities already operate under best practice in recovery and recycling. Achieving these removal and recovery rates in practice may prove more challenging.

A recent Freedom of Information (FOI) request provided 10 sets of Environment Agency returns data for each quarter between January 2019 and April 2021. The data collected represented a total of 3.9 million redundant fridges and freezers at Stage 1 and 3.4 million units from Stage 2. The data is obtained from a variety of geographies across the UK and contains 175 (Stage 1) and 161 (Stage 2) separate data points for comparison.

While the discrepancy of 0.5 million units between Stage 1 processing and Stage 2 highlights the limitations of this data, it does provide an insight into current practices at WTEE recycling operations.

The data shows:

  • Average Recovery of Stage 1 gases, for both VFC and VHC, was 60.8% (with a range of between 12.2% and 129%).
  • Average Recovery of Stage 2 gases, VFC and VHC, was 73.3% (with a range of 8.50% – 108%).

Alarmingly, despite the discrepancy, recovery rates at Stage 1 are still significantly lower for VFC-containing compressors than for those compressors containing VHCs, as shown in Table 3 below.

Table 3: VFC and VHC recovery rates, Stage 1

Minimum Average 95th %ile Maximum
Total Recovery % of refrigerant 12.2 60.8 99.2 129
% VFC Recovery Stage 1 6.20 29.0 57.4 89.1
% VHC Recovery Stage 1 15.5 70.8 137 210

Note: this data has been compiled using the industry average charge weights of 100g for VFC gases and 40g for VHC gases.

A similar story is found when comparing the average recovery rates of gases from Stage 2 destruction data (Table 4). Again, this has been separated into both VFC/VHC gases and unit size as per the Environment Agency returns format, then averaged for the total number of units processed and a recovery rate based upon the actual gas recovered, divided by the initial theoretical gas content.

Table 4: Blowing agent recovery rates, Stage 2

Minimum Average 95th %ile Maximum
Blowing agent recovery % 8.50 73.3 101 108
Recovery VFC Stage 2 5.99 47.7 68.7 73.3
Recovery VHC Stage 2 9.88 77.4 103 114

Concentrating only on the average recovery rates for Stages 1 and 2, the recovery of VHC gases from WTEE is nearly twice as efficient compared to the recovery of VFC gases. This also has the effect of reducing the overall “average” recovery rate of Stage 2.

Should operators be concerned? In the grand scheme of things, not really. The overall composition of VFC WTEE arising at recycling operations is dwindling.

Current figures suggest they represent no more than 12% of all WTEE units collected, a complete reversal of the situation in 2002. Eventually, there will be limited VFC units in the waste stream and VHC units will predominate.

However, the data still suggests that far less than 90% (80% for Stage 2) is being recovered when only considering VHC units.

There are valid arguments that if the gases are not there they cannot be recovered. In some instances, this will be true (for example, a unit with a broken compressor casing or missing doors). However, some compressors may still have some residual gas present, and doors that are collected may not belong to the original unit.

Whatever the reason, operators will have to have complete trials and tests on residual materials to show how effective their recovery operations are. The answer to actual recovery rates obtained lies entirely in the hands of the operators.


As described above, the way to approach these tests and trials is to be methodical, take some time and document everything. For this reason, having a team of well-trained staff who are prepared for the requirements of the Environment Agency’s Appropriate Measures will be essential.

If you’re looking for a partner to not only provide third-party auditing services but also deliver the employee training your business requires to succeed, then the Mayer Environmental team is ready to help.

While changes such as these can be intimidating, it’s also an important opportunity for the most diligent and professional operators to get the credit that they deserve.

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