resend - didn't see original post > -----Original Message----- > From: Crane, Lauren > Sent: Thursday, January 04, 2001 11:15 AM > To: '[email protected]'; [email protected] > Subject: HCFC ban in Europe - EC reg 2037/2000 > > Summary =========================== > > The EC "ozone regulation" No. 2037/2000 does, indeed, prohibit the use of > HCFC's as early as 1/1/00. In fact, some uses of HCFC's as early as > 1/1/96. The trick to reading this regulation is to understand that the > prohibition dates are scheduled according to the use of the HCFC. There > are different dates, for example, for HCFC's used as solvents, aerosols, > and refrigerants. The refrigerant use is, itself, broken down into > different use sectors (i.e. Military Vehicles, Public Transport > Air-conditioning).... > > Before you can determine when your products use of HCFC will be > prohibited, you must determine how the regulation speaks of your > product...not always an easy task. > > Since the regulation is focused on the EU it is more difficult to find the > language pointed towards manufacturers outside the EU who are selling into > the EU. Note, for example, that "producer" in this document means a > producer of HCFC (or other banned material), NOT a producer of equipment > that utilizes the material. (ref article 2). > > As with most EU legislation, the primary burden of compliance is on those > people in the union. Therefore, the burden is on the importer of equipment > utilizing banned materials, not specifically on the exporter outside the > EU. Of course, many US based companies have a Euro affiliate, and share > reputation and "bottom line" or have contractual agreements not to get the > Euro guys in trouble with "the law." > > Also note that this regulation seems to include reporting requirements for > those who IMPORT HCFC's and related materials into the EU. Article 4 and > or Article 6 describes this. So if you export equipment that utilizes > HCFC's, but it is imported EMPTY of the HCFCs, you are pretty clear of > obligations. However if you export HCFC containing equipment, even during > the period before prohibition for your particular product, the importer of > your equipment probably has reporting responsibilities. > > The body that must receive these reports, and how import quota's are > determined are unclear to me at this time. I need to re-read the > regulation 10 or so more times. > > Attached is an analysis I did for a "chiller" that uses HCFC's in its > primary cooling cycle against the prohibition requirements of article 5. > It is a specific case study, but may be useful to you. > > <<Analysis of CFC directive.doc>> > > I do not know how a "regulation" is different from a "directive." - more > to learn ! > > The two amendments to this regulation to not change the base document in a > large way. > > Details =========================================== > Found by searching at "Directory of Community legislation in force" > (http://europa.eu.int/eur-lex/en/lif/ind/en_analytical_index_15.html) with > key word "2037/200) selecting 'legislation in force' and 'consolidated > legislation' check boxes on search page. > > > The basic act > http://europa.eu.int/eur-lex/en/lif/dat/2000/en_300R2037.html > > A first amendment > http://europa.eu.int/eur-lex/en/lif/dat/2000/en_300R2038.html > > A second amendment > http://europa.eu.int/eur-lex/en/lif/dat/2000/en_300R2039.html > > Lauren Crane > * Principal Safety & Compliance Engineer > * Ion Beam and Thermal Processing Systems > * Axcelis Technologies Inc. > * 108 Cherry Hill Dr. > * Beverly, MA 01915 > * 978.787-9745 [email protected] >
Analysis of CFC directive.doc
Description: MS-Word document
