Waste ODS & F-gases: Prior Annual Notifications

Most refrigerantshalons and F-gases in common use are either Ozone Depleting Substances or Fluorinated Greenhouse Gases. When these gases become waste, they are considered hazardous.  

This means that the collection and transport of these waste gases can only be carried on by a contractor that is authorised under waste legislation to do so. 

Authorisation can be either 

  • A valid Waste Collection Permit issued by the National Waste Collection Permit Office (www.NWCPO.ie) for the area(s) in which collections are taking place and for the waste types that cover waste ODS and F-Gases.  

The relevant EWC codes may include 14 06 01* and 16 05 04* among othersor 

  • A Prior Annual Notification(PAN) which has been submitted to and has been acknowledged by the Environmental Protection Agency.  

The relevant legislation is the Waste Management (Collection Permit) Regulation 2007 (S.I. No. 820 of 2007), as amended by the Waste Management (Collection Permit) (Amendment) Regulations, 2008 (S.I. No. 87 of 2008).  A copy of these Regulations can be downloaded below.  

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 reports. 

Do you qualify for a PAN? 

  • Are you a contractor in the refrigeration, air conditioning, heat pump, and fire suppressant sectors? 
  • Do you carry out servicing and maintenance of equipment that may have ODS or F-Gas refrigerants or fire control gases, such as CFCs*, HCFCs* or HFCs**? 
  • During servicing and maintenance, do you recover gases that need to be disposed of or sent for reclamation? 
  • Do you transport these waste gases? 

If you answered yes to any of the above questions, then you must comply with waste law for the collection of waste and transport of waste gases from your client’s premises. You can do this by obtaining a PAN authorisation under the Waste Management Act 1996 (as amended). 

How to Submit a PAN 

A Prior Annual Notification can be submitted to the Environmental Protection Agency by any person intending to collect and transport waste, returned or recovered refrigerants/halons/F-gases in gas recovery containers. There is no fee for submitting a PAN. However, PANs can only be submitted and acknowledged 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
  • the material is brought to a facility authorised to accept it ***
  • no venting or leakage occurs
  • the waste will eventually be recycled, reclaimed or destroyed at an authorised facility in accordance with the relevant legislative requirements for the specific gas type. 

How to complete a Prior Annual Notification 

Step 1: Register as a User on www.edenireland.ie (this is a once-off exercise). Follow our Guidance Manual Part 1 for First Time Users of the ODS & F-gas Compliance System Application 

Step 2: Access the ODS & F-gas Compliance System on www.edenireland.ie and submit a PAN online. Follow our Guidance Manual Part 2 for the ODS & F-gas Compliance System Application This process only takes a few minutes to complete. 

PANs are issued on an annual basis, covering the period from 1st April to the 31st March of the following year.  Therefore, you should renew your PAN every year. Once you are registered, you will receive automatic reminders by email. 

Register of Prior Annual Notifications 

The EPA maintains a register of Prior Annual Notifications received and acknowledged by the EPA in accordance with Article 30(1) of the Waste Management (Collection Permit) Regulations 2007.  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. 

This register is available to download at this link

Learn More 

Download EPA Position on Waste Refrigerant Gases (November 2009) 

Download the Information Leaflet for Collection and Transport of Waste Refrigerants 

Download the current list of Prior Annual Notifications received and acknowledged