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Waste ODS & F-gases: Prior Annual Notifications

Recovery Refrigerant cylinder

Many refrigerants in common use are either Fluorinated Greenhouse Gases or Ozone Depleting Substances. There is a legal requirement to recover these refrigerants from end-of-life equipment. These recovered gases should be transferred to appropriately labelled cylinders for eventual recycling, reclamation or destruction.

When these gases become waste, third parties, such as refrigerant contractors, can only transport them if authorised to do so under waste legislation.  

Authorisation can be either:

  • A valid Waste Collection Permit that covers waste ODS and F-Gases issued by the National Waste Collection Permit Office (NWCPO.ie ); or,
  • A Prior Annual Notification (PAN) which has been submitted to and has been acknowledged by the Environmental Protection Agency. PANs are specifically designed for contractors in the refrigerant and fire suppressant sectors that transport waste gases. Unlike Waste Collection Permits, there is no fee for submitting an application and no requirement to submit annual reports. PAN’s are issued in accordance with Article 30(1) of the Waste Management (Collection Permit) Regulations 2007 as amended.

Who can request a PAN from the EPA?

A Prior Annual Notification can be submitted online to the Environmental Protection Agency by any person intending to collect and transport waste, returned or recovered refrigerants where the following conditions are met:

  • such transport is incidental to your main business activity
  • the quantity of waste gases returned or recovered gases transported does not exceed 2 tonnes
  • no mixing of different gases occurs
  • no venting or leakage occurs
  • the transport of the waste, returned or recovered refrigerants in cylinders is to an authorised waste facility
  • the waste, returned or recovered refrigerants will eventually be recycled, reclaimed or destroyed at an authorised waste facility

How to submit a Prior Annual Notification

PANs are applied for and issued through the EPA’s online Environmental Data Exchange Network (EDEN) for a maximum of 12 months, covering the period from 1st April to the 31st March of the following year.  Therefore, you need to renew your PAN every year. Once you are registered, you will receive automatic reminders by email.

 

Step 1: Register as a User on www.edenireland.ie (this is a once-off exercise).

Step 2: Access the ODS & F-Gas Compliance System on www.edenireland.ie and submit a PAN online through the ODS & F-gas Module. This process only takes a few minutes to complete.

Guidance on Submitting PANS

Register of Prior Annual Notifications

The EPA maintains a Register of Prior Annual Notifications received and acknowledged by the EPA.  If a refrigerant contractor is on this register, then they are entitled to transport waste ODS and F-Gases linked to their activities from a client’s premises to an authorised waste facility.  The client also has an obligation to ensure that their contractor is authorised to remove waste refrigerants from their premises. This register provides a means for the client to check if their contractor is authorised to transport waste refrigerants.

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