Refrigerant disposal in the Netherlands: the paperwork explained

Is recovered refrigerant waste?

Recovered refrigerant sent to a processor for reclamation or destruction is normally treated as hazardous waste. In the European List of Waste it usually falls under code 14 06 01*: chlorofluorocarbons, HCFCs and HFCs. The asterisk marks hazardous waste. That brings three things with it: who may carry it, which number it travels under and which document goes with it.

Who may transport the refrigerant?

Only a company registered on the VIHB list. VIHB stands for carriers, collectors, dealers and brokers of waste. Anyone who professionally transports, collects, trades or brokers commercial or hazardous waste in the Netherlands must register with NIWO. That includes foreign companies.

The letters after the VIHB number show which activities are registered, for example VI for transport and collection. You can look up a registration yourself by company name, VIHB number or Chamber of Commerce number. As the waste producer, you may only hand hazardous waste to a carrier or collector with a VIHB number, and only for delivery to a receiver that is allowed to accept it.

What is a waste stream number?

The waste stream number (afvalstroomnummer) identifies your waste stream to the processor and to the National Waste Reporting Office (LMA). It has 12 characters and is issued by the receiving processor, provided that processor is obliged to report to the LMA. The first five characters are the processor number the LMA assigned to that processor. The processor chooses the remaining seven.

The number stands for a fixed set of data: sender, waste producer, location of origin, receiving location, the waste type with its EWC code, and the treatment method. You record those details with the processor in a contract. So you do not request a new number for every transport: later loads of the same stream to the same processor travel under the same number.

The waste producer (ontdoener) is whoever actually disposes of the waste. For refrigerant recovered during servicing or decommissioning, that can be the contractor or the equipment owner. Agree beforehand who takes that role, because the obligations follow it.

How does the consignment note work?

Every load travels with a consignment note (begeleidingsbrief). Its layout is prescribed by law in the Dutch regulation on reporting commercial and hazardous waste. The sequence:

1. 01The waste producer fills in the note, including the waste stream number, and keeps the white original.
2. 02The carrier signs it and takes the copies along during transport.
3. 03On arrival the processor weighs the load, records the final weight, signs for receipt and returns the carrier's copy.
4. 04The processor reports receipt to the LMA, via AMICE or on a form, within four weeks after the end of the month in which the waste arrived.

A digital consignment note is allowed, but only with a system that has received prior approval on behalf of the minister. The LMA publishes which digital solutions have been approved. Waste producer, carrier and processor each keep the load data, consignment notes and contract for at least five years.

Are there schemes that make this simpler?

Yes, with limits. Under route collection (route-inzameling) and the collector scheme (inzamelaarsregeling), a registered collector takes over the waste producer role on the consignment note, and a single waste stream number can cover several locations of origin. Route collection is mainly intended for non-hazardous commercial waste, and the collector scheme only applies to waste types on a fixed list. Whether either can be used for your refrigerant depends on the situation. Ask the collector rather than assume.

Which F-gas rules apply as well?

Alongside waste law, the F-gas Regulation applies. Recovery itself must be carried out by a certified technician. The operator of equipment that requires leak checks keeps a logbook recording, among other things, the quantity of refrigerant recovered and, on decommissioning, the measures taken to recover and dispose of the gas (Article 7 of Regulation (EU) 2024/573). That logbook is also kept for at least five years.

Transport is also covered by the ADR, the European rules for carrying dangerous goods by road. Refrigerant cylinders are pressurised gas containers (class 2). That sets requirements for the cylinder, the labelling and the way it is carried. Exemptions exist for small quantities, but basic rules still apply.

How Gaia Cooling takes this off your hands

When you have recovered refrigerant collected through Gaia Cooling, we arrange the processing paperwork and the transport:

• •we arrange the waste stream number with the processor receiving the refrigerant;
• •we prepare the consignment note, you check and sign it;
• •the refrigerant is collected by a carrier registered on the VIHB list;
• •you receive a record of refrigerant, weight and destination for your logbook and waste records.