The Environment Agency (EA) published new guidance on using R134a air conditioning gas from ELVs to recharge air conditioning systems: RPS 226 on 20th January 2020.
The guidance gives information on when you can use R134a air conditioning gas removed from end of life vehicles (ELVs) to recharge or top up vehicle air conditioning systems and the EA provides the following information:
If you comply with the conditions in this regulatory position statement (RPS) you can use R134a gas from ELVs to recharge or top up vehicle air conditioning systems.
This regulatory position statement (RPS) applies if you are using R134a air conditioning gas removed from ELVs to recharge or top up air conditioning systems in other vehicles.
If you follow the conditions in this RPS you can re-use R134a gas:
- at the site it was collected
- at garages and vehicle service or repair centres that are occupied and operated by the person who bought the gas
This RPS does not apply to any other activity, even if it is under the same legislation. You may still need other permits or licences for other activities you carry out.
Conditions you must comply with
R134a gas must only be sold to and used by people qualified under Article 10 of the fluorinated gas (F gas) regulations.
You must only remove R134a gas from ELVs into appropriate refillable containers. The containers must:
- prevent R134a gas escaping
- be clearly marked as containing R134a gas
You must keep the following records for a minimum of 5 years:
- the mobile air conditioning (MAC) qualification certificate number of the buyer
- the quantity of R134a gas that was bought
- the date the R134a gas was bought
- a letter of assurance that the R134a gas was sold to a qualified reseller – it must not be sold to individuals for use
You must not:
- vent R134a gas into the atmosphere
- remove R134a gas from ELVs or recharge it into another vehicle’s air conditioning system without the correct MAC qualification and appropriate specialist equipment
- supply R134a gas to anyone who cannot provide evidence of the correct MAC qualification
- supply R134a gas to anyone who does not keep records of who they are supplying it to, the quantities they are supplying and records of the MAC qualifications for anyone they supply
You must make sure your activities do not endanger human health or the environment.
You must not:
- cause a risk to water, air, soil, plants or animals
- cause a nuisance through noise or odours
- adversely affect the countryside or places of special interest
You must keep records for 5 years that show you have complied with this RPS. You must make these records available to the Environment Agency on request.
An RPS means that the Environment Agency will not normally take enforcement action against you for not having a permit provided:
- your activity meets the description set out in this RPS
- you comply with the conditions set out in this RPS
- your activity does not, and is not likely to, cause environmental pollution or harm human health
When to check back
Check back in November 2021 when this RPS will be reviewed to see if it still applies.
Contact the Environment Agency at firstname.lastname@example.org or call 03708 506 506
Head to the guidance at www.gov.uk