LABELLING REFRIGERANT CYLINDERS

OzonAction Technical Brief

Why set up national legislation on labelling refrigerant cylinders?

he Montreal Protocol on Substance Labels contain written and usually also graphic that Deplete the Ozone Layer is phasing information. They can be affixed to, printed Tout ozone-depleting hydrochlo­ ­ro­fluo­ro­ on, engraved on or glued to the cylinders and carbons (HCFCs) and has begun phasing down their packaging. Legislation on the labelling of high global warming hydrofluorocarbons (HFCs) refrigerant cylinders should provide the specific that are mainly used as refrigerants. Gradually, wording of the information and the layout of these controlled substances are being replaced pictograms to ensure the safety of the cylinders by ozone- and climate-friendly refrigerants, and the durability of the labels. some of which are flammable, toxic or operate at high pressures. Refrigerants are contained in Countries allowing the import or placing on the different types of cylinders such as small cans or market of refrigerant cylinders without labelling, ISO containers, transport or recovery cylinders, with incomplete or with misleading labelling refillable or non-refillable cylinders etc. might not be able to ensure the health and safety of users. They might also face challenges Labelling of refrigerant cylinders is needed to in monitoring and controlling trade in controlled provide information about the cylinders and substances as required by the Montreal Protocol. their contents, to allow easy identification of refrigerants and to ensure their safe and Labelling is becoming even more important proper handling. Such information is relevant with the increasing number of new refrigerants for importers, wholesalers, distributors, service and blends, which led to the discontinuation companies / end-users and enforcement of the AHRI system of cylinder colours1. As a authorities throughout the life cycle of the result of this, labelling has become the principal cylinders and the refrigerants, e.g. during identification method for refrigerant cylinders production, transport, trade, storage, use, and their contents. recovery / recycling / reclaim and disposal. Labelling of refrigerant cylinders also facilitates the monitoring of trade, maintaining trade statistics and reporting the consumption of controlled substances as required under Article 7 of the Montreal Protocol.

Discontinued AHRI colour system for refrigerant cylinders

1 UNEP OzonAction’s publication “Legislative and international guidance documents such as policy options for HFCs”2 recommends manda­ tory­ the “UN Globally Harmonized System of labelling of refrigerant cylinders to be implemented Classification and Labelling of Chemicals prior to the freeze of the HFC consumption at the (GHS)”3 and the “UN Recommendations on baseline level. For most developing countries (i.e. the Transport of Dangerous Goods Model those in Article 5 group­ 1), the HFC freeze will start Regulations (TDG)”4. The UN Economic on 1 January 2024. Commission for Europe’s website provides comprehensive information on these guidance This technical brief encourages Governments documents and an overview of national and National Ozone Officers to establish or legislation based on them.5 amend national legislation requiring mandatory labelling of refrigerant cylinders and explains These guidance documents define the labelling what information should be included in elements in accordance with the classification refrigerant cylinder labelling. of the refrigerants. The globally harmonized system classifies chemicals by hazard types and assigns relevant signal words, pictograms, hazard and precautionary statements to be included on labels and in the Safety Data Sheets. Commonly traded refrigerants are classified as pressurized gases (compressed, liquefied, refrigerated liquefied gases), flammable gases or toxic gases and require a labelling that reflect Grey refrigerant cylinders without labelling their classification.

Labelling contributes to safe transport, Concerning the transport of refrigerant cylinders, storage, handling and use of refrigerants labelling should be based on the classification of the refrigerants and the means of transport. This Refrigerants are subject to regulations on can be achieved through the implementation chemicals. Labelling of chemicals informs of the of the “Recommendations on the Transport of hazards, safety precautions, storage conditions Dangerous Goods” and separate international and emergency responses associated with their legal instruments depending on the means of transport, storage, handling and use. Ignoring transport (e.g. road, rail, air, maritime transport or these instructions might cause harmful effects on inland waterways). These include, for example: on people and the environment. The content uu International Maritime Dangerous Goods of the labels depends on the classification Code (IMDG Code) of the chemicals based on their physical and uu International Civil Aviation Organisation chemical properties, the risk of health hazards Technical­ Instructions for the Safe Transport as well as transport and handling requirements. of Dangerous Goods by Air (ICAO TI) For refrigerant cylinders, the labels should uu European Agreement concerning the Inter­ provide safety advice, indicate the names of the national Carriage of Dangerous Goods by refrigerants they contain and their environmental Road (ADR) properties, and inform about the technical uu Regulations concerning the International parameters of the cylinders. Tran­sport of Dangerous Goods by Rail (RID) uu European Agreement concerning the Inter­ When establishing national legislation on national Carriage of Dangerous Goods by labelling, Governments might draw on Inland Waterways (ADN).

2 Under these regulations, refrigerants are of dangerous goods. The packaging instructions classified as “Class 2 dangerous goods” with normally require the use of UN performance- three sub-divisions “2.1: Flammable gases”, tested and certified packaging that should be “2.2: Non-flammable and non-toxic gases”, or marked accordingly. “2.3: Toxic gases”.

UN markings of pressure cylinders

UN markings for refillable pressurized cylinders include manufacturing marks at the top (m, n, Labelling of cylinders containing HFC-227ea, a controlled chemical used as fire suppressent, foam blowing agent o, p), operational marks in the middle (i, f, g, j, and increasingly in new refrigerant blends to suppress h) and certification marks on the bottom (a, b, the flammability of the other components, e.g. R-461 or 6 R-470. This labelling provides information on the safety of c, d, e) . Not all the markings are required at the transport like the UN number and dangerous goods label. same time and depend on the cylinder type and It also includes the chemical name and safety warning as required by the legislation on chemicals. substance contained in the cylinder.

The table on page 4 shows examples of For non-refillable pressure cylinders, the same classification and labelling according to the “UN markings shall be applied except for g, h and m. Globally Harmonized System of Classification The serial number (o) may be replaced by the and Labelling of Chemicals (GHS)” and batch number. In addition, the words “DO NOT the “European Agreement concerning the REFILL” are required. International Carriage of Dangerous Goods by Road (ADR)” for HFC-32, HCFC-22 and National legislation may require certification ammonia. Information required by the globally of pressurized cylinders in accordance with harmonized system and the transport regulations international or national standards. Some are reflected in the cylinder labelling. The table countries have national certification systems has an indicative character. The responsibility for pressurized gas cylinders. For example, the of classifying and communicating hazards lies EU requires compliance of refrigerant cylinders with manufacturers, importers and distributors. with the “Transportable Pressure Equipment Directive”7 providing for the π (Pi) marking, Labelling informs about properties of the US with DOT standards8, and China with GB refrigerant cylinders standards9.

Refrigerants need cylinders that are appropriate to the chemical and physical properties of different gases, in particular in terms of maximum operating and test pressures for safe transport, storage and use. The “UN Model Regulations on the Transport of Dangerous Goods” provide packing instructions for various classes Markings of a GB certified cylinder

3 corner border

Symbol (liquid, half white; lower attacking a hand spilling from two spilling from glass vessels and glass vessels Background: upper Background: and a metal): black Figure ‘8’ in bottom ‘8’ in bottom Figure half black with white ADR label Background: red Background: Background: green Background: Figure ‘2’ in bottom corner ‘2’ in bottom Figure Figure ‘2’ in bottom corner ‘2’ in bottom Figure black white Symbol flame: Black or white Symbol (skull and Figure ‘2’ in Figure Background: Background: Symbol gas cylinder: Black or white crossbones): crossbones): bottom corner bottom ADR labelling gases Hazard Hazard category Corrosive Corrosive Flammable substances Toxic gases Toxic non-toxic gases non-toxic Non-flammable,

ADR gases gases Class 2 2.3: Toxic Toxic 2.3: Division 2.2: classification 2.1: Flammable non-toxic gases non-toxic Non-flammable, Class 2 Division Class 2 Division The labelling includes the relevant UN number and hazard class label. UN number and hazard The labelling includes the relevant environment Precautionary statements Precautionary indicating how the product should indicating how the product be handled to minimize risks to the risks to minimize be handled to user but also to other people and the user but also to P210: Keep away from heat, hot from away P210: Keep surfaces, sparks, open flames and No smoking. other ignition sources. Do not P377: Leaking gas fire: extinguish, unless leak can be safely. stopped P387: In case of leakage, eliminate all ignition sources. place. in a well-ventilated P403: Store P403: Store in a well-ventilated place. in a well-ventilated P403: Store Contact with Other hazards: cause liquid may evaporating of skin. or freezing frostbite layer. for the ozone Dangerous cause the containers to Heat may explode. P210: Keep away from heat/sparks/ from away P210: Keep open flames/hot surfaces. No smoking. gloves/ protective P280: Wear protective protection/face clothing/eye protection. gas, vapours. P260: Do not breathe the to release P273: Avoid P377: Leaking gas fire: environment. Do not extinguish, unless leak can be safely. stopped if P381: Eliminate all ignition sources do so. to safe (…) HFC-32 (Difluoromethane, UN 3252) HFC-32 (Difluoromethane, Ammonia (ammonia anhydrous, UN 1005) (ammonia anhydrous, Ammonia HCFC-22 (Chlorodifluoromethane, UN 1018) HCFC-22 (Chlorodifluoromethane, Hazard statements Hazard indicating the nature indicating the nature and degree of the risks and degree H220: Extremely H220: Extremely flammable gas H280: Contains gas may under pressure; explode if heated H280: Contains gas may under pressure; explode if heated. H420: Harms public health and the by environment in the ozone destroying upper atmosphere. H280: Contains gas may under pressure; explode if heated. H221: Flammable gas. if inhaled. Toxic H331: H314: Causes severe skin burns and eye damage. to toxic H400: Very aquatic life. GHS labelling DANGER DANGER WARNING “WARNING” if necessary “DANGER” or Signal words

Toxic Toxic Cat. 1 Cat. 4 layer – layer pressure Gas under the ozone the ozone the aquatic environment Hazardous to to Hazardous to Hazardous

chemical Hazard Pictograms Hazard there can be more than can be more there pressure pressure one pictogram for a given for a given one pictogram Corrosive Corrosive Flammable Gas under Gas under gas gas GHS Cat.1 Cat. 1 – Cat. 2 pressure – pressure Serious eye Serious eye Gases under Gases under Gases under liquefied gas Acute toxicity Acute toxicity classification Aquatic hazard Aquatic hazard Flammable gas (acute) – Cat. 1 damage – Cat.1 Skin corrosion – Skin corrosion Flammable gases pressure -liquefied pressure (inhalation) –Cat.4 pressure - liquefied pressure Six GHS labelling elements: 1) Product identifiers (of a substance or hazardous components in a mixture, i.e. CAS number, i.e. CAS number, components in a mixture, identifiers (of a substance or hazardous Six GHS labelling elements: 1) Product statements, 5) Precautionary statements and 6) Identity of 4) Hazard 3) Signal word, pictogram(s), chemical name), 2) Hazard or importer)the supplier (manufacturer

4 The following photo shows a cylinder containing R-143a intended for release onto the EU market without labelling. The cylinder lacked any certification markings that could have demonstrated its suitability for HFC-143a. The cardboard packaging provided information related to maritime transport of dangerous Markings of a π (Pi) certified cylinder goods (see “IMO 2.1”).

Markings of a DOT certified ISO container

Labelling facilitates monitoring of trade in refri­gerants

Setting up legislation on the labelling of refrigerant cylinders supports the Montreal Protocol objectives as it helps distinguish R-143a refrigerant cylinder declared for release onto the EU market without labelling between controlled, exempted and non- controlled substances, facilitates the prevention In order to comply with the EU legislation, of illegal trade, and provides an indication of the labelling information related to safety the environmental properties of the controlled of transport, safety of handling and storage, substances. conformity of cylinder, and requirements of the F-gas legislation should have been displayed on Some countries like the EU member states, the R-143a cylinder as shown in the table below. Turkey and Bahrain have introduced labelling Safety of handling and storage requirements for refrigerant cylinders. The EU (classification and hazard communication) member states and Turkey require specific Product identifier 1,1,1 trifluoroethane, R-143a information for controlled substances indicating and/or CAS 420-46-2 either that they are “hazardous to the ozone Hazard pictogram(s) layer” or “contain fluorinated greenhouse gases”. Where applicable, “exempted uses” Signal word DANGER must be indicated, e.g. whether the substance is Hazard statements H220: Extremely flammable gas. reclaimed, recycled or destined for destruction, H280: Contains gas under for use in military equipment, feedstock use, pressure; may explode if heated. Precautionary statements P201: Keep away from heat, metered dose inhaler production, process agent sparks, open flame, and hot use, essential laboratory or analytical use. For surfaces. No smoking. HFCs, including blends, also the global warming P410: Protect from sunlight P403: Store in a well-ventilated potential (GWP) and the quantity in weight and place.

CO2 equivalent must be indicated. Supplier details Supplier details

5 Safety of transport F-gas regulation on controlled substances UN number UN 2035 Industrial or chemical name R-143a or 1,1,1 trifluoroethane Dangerous goods 2.1 Contains fluorinated Contains fluorinated greenhouse classification greenhouse gases gases Relevant labels GWP GWP 4470 Quantity in weight 12 kg

CO2 equivalent 53.64 CO2-equivalent tonnes Conformity of cylinder (markings) If relevant, the exempted use Manufacturing, operational Cylinder-related markings and certification marks Conformity marking, e.g. π (Pi)

The following photo shows the actual label of The text fields beside the photo explain the an HFC-134a cylinder declared for customs information contained in the label. clearance to be released onto the EU market.

Actual label

1) UN number: 3159 9) Industry name: R-134a 2) Dangerous good classification: 10) GWP: 1430 2.2.A 11) Chemical name: 3) Hazard 1,1,1,2- tetra­ ­­flu­ pictogram o­ro­ethane­

4) Dangerous goods 12) Contains transport label fluorinated greenhouse 5) Signal word: gases WARNING 13) Supplier 6) Product identifier: CAS number 7) Hazard statement: Contains gas under (blurred) pressure; may explode if heated 8) Precautionary statement: Avoid release to the environment. Store in a well-ventilated place. Actual label of an HFC-134a cylinder declared for customs clearance to be released onto the EU market

The label contains information as required by and packaging of substances and mixtures the provisions on transport of dangerous goods, (CLP)”10 labelling requirements and the EU the “EU regulation on classification, labelling F-gas legislation:

Provisions on transport of EU regulation on classification, labelling and packaging of EU F-gas legislation dangerous goods substances and mixtures (CLP) 1) UN number: 3159 3) Hazard pictogram: Symbol of cylinder with red border 9) Accepted industry 2) Dangerous goods 5) Signal word: WARNING designation for F-gases: classification: 2.2A 6) Product identifier: CAS number (811-97-2) R-134a 4) Dangerous goods 7) Hazard statement: Contains gas under 10) GWP: 1430 transport label: Symbol pressure 11) Chemical name: of gas cylinder on green 8) Precautionary statements: Avoid release to the 1,1,1,2-tetrafluoroethane background environment. Store in a well-ventilated place 12) Reference that it contains 11) Hazardous components: fluorinated greenhouse 1,1,2-tetrafluoroethane gases 13) Supplier details (blurred) Information contained in the label of the HFC-134a cylinder

6 Concerning the EU requirements, the label lacks As shown by the example above, even a detailed reference to the quantity in weight and CO2 label might not meet all requirements. Label equivalent. The EU requires that the labelling templates can assist industry to use compliant should be in the language of the member state of labelling and enforcement officers to verify destination, thus the cylinder could be placed on conformity. The following label template was the market in Germany, Poland and Slovakia. The jointly drafted by Turkey’s National Ozone Unit label contains reference to the Kyoto Protocol, and industry. It is part of a brochure for customs which is not required by the EU legislation. officers on the requirements of the Turkish F-gas legislation. The template is used by some of the The same set of information would be required Turkish companies. for such a cylinder by the Turkish legislation. It also requires that precautionary statements in the labelling are written in the national language.

Label template jointly developed by Turkey’s National Ozone Unit and industry

How to set up labelling requirements?

In general, labelling requirements regulate the Compulsoriness of refrigerant cylinder following elements: labelling 1) Compulsoriness: Degree to which it is obligatory to provide information Voluntary labelling allows producers, importers, 2) Explicitness: Degree of detail to which distributors to decide what information, if any, information must be presented will be displayed on the refrigerant cylinders and 3) Standardisation: Degree to which the / or the packaging. Mandatory labelling requires information must be provided in a uniform that certain information must be displayed. format. Legislation needs to specify what is subject to mandatory labelling, the stage of the cylinder life cycle when mandatory labelling applies, and

7 sanctions for failure to comply with the labelling manufacturers are best positioned to provide requirements. comprehensive and accurate information about their cylinders and know whether they Refrigerant cylinders are subject to labelling comply with specific requirements. They are according to the legislation on chemicals and primarily responsible for providing conformity transport rules. Also, the packaging should markings. Legislation might also impose certain be labelled according to the transport rules obligations on importers and distributors, indicating UN numbers, proper shipping including obligations related to labelling. Their names11, orientation arrows, hazard symbols, roles could be defined in the legislation on market handling labels, etc. surveillance, in the legislation on chemicals, or in the legislation for controlled substances. The Cylinders containing controlled substances possible roles of these stakeholders might be as might require additional labelling as per follows: national legislation which should specify the type of cylinders to be labelled. In the EU, such uu Manufacturers of cylinders destined for requirements cover all “fluorinated greenhouse refrigerants ensure the compliance of gases containers”.12 cylinders under a chosen certification scheme and declare compliance through conformity Controlled substances (such as ODS or HFCs) mar­kings on the cylinders, label the cylinders contained in products or equipment are not as suitable for particular refrigerants, and controlled under the Montreal Protocol, but provides relevant conformity documentation. countries may introduce provisions for products uu Producers of refrigerants ensure that or equipment containing or relying on controlled refrigerants are filled into suitable cylinders substances, including labelling requirements. that allow for safe storage, use and transport. The EU and Turkey require the labelling of such If producers place refrigerants on the market products or equipment similar to that of bulk they should provide relevant labelling. F-gases. uu Importers of refrigerants ensure that the imported refrigerant cylinders are compliant At which stage labelling might be checked? under a certification scheme applicable in a Checking the compliance of labelling might given market and that cylinders are imported be carried out on the market. Imported goods and labelled as required by the legislation can also be inspected at the time of customs on chemicals of the importing country. If clearance, if customs authorities have relevant specific labelling for controlled substances competencies. In the EU and in Turkey, they can is required, the importer should meet these check compliance of the cylinders as well as conditions as well. labelling related to the legislation on chemicals and the F-gas legislation. There are also other stakeholders that perform operations such as recovery, recycling, reclaim Who should be responsible for ensuring or disposal / destruction of refrigerants. compliance with the labelling requirements? Such operations might require specific types Refillable refrigerant cylinders can be used for of recovery or transport cylinders, and the different types of refrigerants and must provide national legislation should define the labelling necessary information about them during requirements for these stages of the cylinder the life cycle (production, import, distribution life cycles. / wholesale, servicing / end-use). Cylinder

8 Explicitness of the information to be Standardisation of the labelling provided by the labelling The labelling requirements may specify to what If refrigerants are already subject to legislation extent the information should be provided on chemicals, the labelling regulations for in a uniform manner, i.e. using specific controlled substances should not duplicate wording13, language(s) and location14 and such requirements. The legislation should durable labels to ensure that they are clearly specify the content of the labels. There may also readable, understandable and non-removable15. be rules simplifying the content of the labels. The EU and Turkey have specified durability For example, in the EU, there should not be require­ments for labelling in their legislation more than six precautionary statements in the on chemicals and that related to controlled labelling of dangerous chemicals. substances, whereas Bahrain’s durability requirements apply to all refrigerants. Generally, metal plates welded on the cylinder, engravings, and paint are considered indelible. Paper and glued labels do not meet these conditions.

Examples of labels with limited durability

Glued label (indicating “difluoromethane”) on an ISO container

Glued paper and plastic labels

Taped paper label on an ISO tank with an additional statement in Polish reading “Contains fluorinated greenhouse gases”, which is a requirement of the EU Glued paper label F-gas legislation

9 Examples of more durable labels

Label fixed with metal rivets Painted label

Enforcement action related to refrigerant labelling

The following cases were detected by Polish Customs and show examples of non-compliance with the EU labelling requirements for HFC cylinders, posing risks related to the safety of transport and the use of refrigerant cylinders. Non-compliant labelling also undermined the goals of the EU F-gas legislation which requires labelling of HFCs to distinguish controlled substances, to inform on their environmental properties and to facilitate enforcement of the legislation. The existing EU and national legislation allowed taking enforcement measures.

Case 1: Non-compliant cylinders without The lack of identification of the refrigerant on the labelling – refrigerant had to be filled into cylinders posed risks for the safety of transport. compliant cylinders with proper labelling As per the customs declaration, they contained HFC-125, whereas the cylinders were certified for HFC-134a. The cylinders did not comply with the directive on transportable pressure equipment and there was no documentation on multimodal transport that would allow the movement of non-compliant cylinders in the EU. The importer was required to fill the refrigerant into compliant cylinders that were labelled according to the EU F-gas legislation before they could enter the EU market.

10 Case 2: Non-compliant cylinder with ADR Case 4: Refillable cylinders without labelling label only – the refrigerant had to be filled into had to be properly labelled compliant cylinders with proper labelling

The ADR label allowed for preliminary identification of safe transport requirements. The cylinders did not comply with the directive on transportable pressure equipment. In addition, there was no documentation on multimodal As per the customs declaration, the green transport that would allow the movement of non- cylinders contained HFC-134a and the pink compliant cylinders in the EU. As per customs cylinders HFC-410A. Lack of labelling did not declaration, the cylinder contained HFC-134a allow for the identification of the substances but it was not labelled as required by the F-gas once the cylinders were taken out of the legislation. The importer was required to fill the cardboard boxes. Before release for free refrigerant into compliant cylinders that were circulation, the cylinders had to be labelled in labelled according to the EU F-gas legislation compliance with the EU F-gas legislation and before they could enter the EU market. the legislation on chemicals.

Case 3: Smuggled cylinders without labelling Case 5: Smuggled non-refillable HFC cylinders or mislabelled were sent back were sent back or confiscated

Testing of the cylinders with a refrigerant The non-refillable cylinders were labelled HFC- identifier showed that the cylinder labelled 404A and HFC-507, refrigerants controlled under “propane” actually contained HFC-134a, and the the EU F-gas regulation and subject to import cylinder without labeling contained HFC-404A. quota. As the EU prohibits customs clearance Persuant to the EU and national legislation, and placing on the market of non-refillable F-gas both cylinders were sent back to the country of cylinders, which either contain or are designed dispatch. for F-gases, the fact that they were non-refillable

11 cylinders with a F-gas labels was sufficient for country of dispatch. The bluish cylinders had customs to take enforcement measures. No been declared for release for free circulation testing was needed. The cylinder on the left and triggered a court case. The cylinders and had been smuggled and was sent back to the refrigerants were confiscated by the State.

Conclusion

There are multiple benefits of mandatory the DOT standards in the US or the GB standards labelling requirements for refrigerant cylinders in China. related to identification, health, safety, environment protection, trade monitoring, Additional labelling requirements supporting enforcement, equipment operation and the implementation of the Montreal Protocol consumer protection. might be introduced in a new or revised environmental legislation, e.g. related to As a starting point, interested Governments / controlled ODS or F-gases. They might require National Ozone Officers could identify labelling information allowing the identification of requirements already applicable to chemicals controlled substances such as industrial or in their countries, e.g. specific chemicals chemical names, specific wording such as legislation on classification and labelling, and “Contains ozone-depleting substances” or international legal instruments related to the “Contains fluorinated greenhouse gases”, transport of dangerous goods already signed. If environmental characteristics such as ODP not yet done, the implementation of such legal or GWP, quantity in weight, CO2 equivalent for instruments might be considered. HFCs, exempted uses, etc.

Subsequently, the gaps in terms of labelling Competencies should be assigned to customs information to be provided on refrigerant service, environmental inspectorate and other cylinders should be analysed considering enforcement agencies and penalties be defined. the international guidance documents such as the “UN Globally Harmonized System of Relevant stakeholders such as importers, who­ Classification and Labelling of Chemicals” and lesalers,­ distributors, service companies / end- the “UN Recommendations on the Transport of users and enforcement authorities should be Dangerous Goods Model Regulations” and the aware of the labelling requirements. Stakeholder specific national context. meetings, dedicated webpages of the govern­ ment / national trade associations or a brochure National legislation might require certification like that produced in Turkey might be useful of pressure cylinders in accordance with information tools. Generic labelling templates international or national standards. Examples might be elaborated to facilitate compliant of such national standards include the EU-wide labelling by the industry and enforcement by the system requiring the conformity π (Pi) marking, authorities.

12 Glossary

Carbon dioxide equivalent tonnes (CO2-eq.t.): (CFCs) and high global warming potential. They Quantity that describes, for a given amount of are banned in developed countries and currently greenhouse gas, the amount of carbon dioxide being phased out in developing countries. that would have the same global warming ability, Hydrofluorocarbons (HFCs): when measured over a specified period of time. Global warming substances controlled by the Chemical Abstract Service Number Montreal Protocol. They do not deplete ozone (CAS number): layer and are widely used as alternatives to CFCs Number assigned by the US Chemical Abstract and HCFCs. They are currently phased down Service to identify a chemical. under the Kigali Amendment to the Montreal Cylinder: Protocol. In this technical brief, the term cylinder is used Ozone depleting substances (ODS): synonymously to the term container. Chemicals destroying the stratospheric ozone Controlled substances: layer when leaking into the atmosphere. Chemicals listed in Annexes A, B, C, E and F to the They are controlled under the Montreal Montreal Protocol, whether as pure substance Protocol and include substances already or contained in mixtures. banned (chlorofluorocarbons, halons, carbon Fluorinated gases (F-gases): tetrachloride, methyl bromide) and substances Hydrofluorocarbons (HFCs), perfluorocarbons currently being phased out (HCFCs). (PFCs), and sulphur hexafluoride­ (SF6) are Safety Data Sheet (SDS): collectively called fluo­rinated gases. They are Document that provides information about synthetic, powerful greenhouse gases. the hazards of a chemical and advice about Global warming potential (GWP): safety precautions. SDS provides more detailed Ratio of global warming caused by a specific information about the chemical and hazards amount of substance to the global warming than the label. caused by the same mass of carbon dioxide. UN number: Thus, the GWP of carbon dioxide is 1. Four-digit number that identifies dangerous Hydrochlorofluorocarbons (HCFCs): goods and hazardous substances such Ozone-depleting­ substances controlled under as explosives, flammable liquids or toxic the Montreal Protocol with lower ozone- substances in the context of international depleting potential than chlorofluorocarbons transport.

Sources

Bahrain: uu Regulation (EU) No 517/2014 of the European uu Resolution No. 1 of 2020 with respect to Parliament and of the Council of 16 April Management of Refrigerants, Refrigeration 2014 on fluorinated greenhouse gases and Units and Air Conditioning Units repealing Regulation (EC) No 842/2006: European Union: https://eur-lex.europa.eu/legal-content/EN/ uu Regulation (EC) No 1005/2009 of the TXT/?uri=CELEX%3A32014R0517 European Parliament and of the Council of 16 uu Commission Implementing Regulation September 2009 on substances that deplete (EU) 2015/2068 of 17 November 2015 the ozone layer: establishing, pursuant to Regulation (EU) https://eur-lex.europa.eu/legal-content/EN/ No 517/2014 of the European Parliament TXT/?uri=celex%3A32009R1005 and of the Council, the format of labels

13 for products and equipment containing uu Regulation on Classification, Labelling and fluorinated greenhouse gases: https:// Packaging of Substances and Mixtures eur-lex.europa.eu/legal-content/EN/ entered into force upon publication in the TXT/?uri=OJ%3AJOL_2015_301_R_0009 Official Gazette No. 28848 of 11/12/2013 Turkey: uu Brochure of Turkey’s National Ozone Unit uu By-Law on ODS in Official Gazette dated prepared in cooperation with UNIDO and 7.4.2017 and numbered 30031 based on the joint publication of AREA, EPEE uu By-law on F-gases in Official Gazette dated and EFCTC entitled “Protect your business – 1.1.2018 and numbered 30291 buy refrigerants from safe sources”.

Endnotes

1 OzonAction factsheet on refrigerant cylinder the case of pressure cylinders for compressed colours: www.unep.org/ozonaction/ gases, the working pressure in bar. (j) In the resources/factsheet/refrigerant-cylinder- case of pressure cylinders for liquefied gases colours-what-has-changed and refrigerated liquefied gases, the water 2 OzonAction publication “Legislative and capacity; (k) Relevant for UN 1001 acetylene, policy options for HFCs”: dissolved; l) Relevant for UN 3374 acetylene, www.unep.org/ozonaction/resources/ solvent free. publication/legislative-and-policy-options- Manufacturing marks (see Section 6.2.2.7.4): control-hydrofluorocarbons (m) Identification of the cylinder thread (e.g. 3 UN Globally Harmonized System of 25E). (n) Manufacturer’s mark; (o) Serial Classification and Labelling of Chemicals number assigned by the manufacturer; (p) (GHS): https://unece.org/about-ghs In the case of steel pressure cylinders and 4 UN Recommendations on the Transport of composite pressure cylinders with steel liner Dangerous Goods Model Regulations (TDG): intended for the carriage of gases with a risk https://unece.org/about-recommendations of hydrogen embrittlement, the letter “H” and https://unece.org/rev-21-2019 showing compatibility of the steel. 5 Overview of national legislation based on 7 Directive 2010/35/EU of the European the GHS and TDG guidance documents: Parliament and of the Council of 16 June https://unece.org/ghs-implementation-0 2010 on transportable pressure equipment: 6 UN Recommendations on the Transport https://eur-lex.europa.eu/legal-content/EN/ of Dangerous Goods - Model Regulations: TXT/?uri=celex%3A32010L0035 https://unece.org/rev-21-2019 (see Volume II, 8 US Department of Transportation standards Part 6) 9 Chinese Guobiao standards Certification marks (Section 6.2.2.7.2): (a) 10 Regulation (EC) No 1272/2008 on UN packaging symbol; (b) Technical standard classification, labelling and packaging of used for design, manufacture and testing; substances and mixtures implementing GHS (c) Character(s) identifying the country in the EU: of approval; (d) Identity mark or stamp of https://eur-lex.europa.eu/legal-content/EN/ the inspection body; (e) Date of the initial TXT/?uri=celex%3A32008R1272 inspection. 11 Proper shipping name is the standard Operational marks (see Section 6.2.2.7.3): (f) technical name as provided by the Test pressure in bar; (g) Mass of the empty “Dangerous Goods List” of the UN pressure cylinder; (h) Minimum guaranteed Recommendations on the Transport of wall thickness of the pressure cylinder; (i) In Dangerous Goods – Model Regulations:

14 https://unece.org/rev-21-2019 (see Volume I, 14 For example, the location might be adjacent Part 3). to the service ports for charging or recovering 12 In the EU, “container” is defined as “a product the refrigerant or on that part of the product which is designed primarily for transporting or equipment that contains refrigerant. or storing fluorinated greenhouse gases”. 15 The EU F-gas legislation defines that the 13 The EU regulation 2015/2068 provides exact label should remain securely in place on the wording for the labelling of substances for cylinder under normal operational conditions, exempted uses, e.g. “For use in military throughout the entire period during which it equipment only”, “For feedstock use only”, contains refrigerants. “Imported for destruction only”, etc.

Acknowledgements Produced as part of the activities of the Montreal Protocol Network for Europe and Central Asia (ECA network) Author: Anna Kobylecka (Polish Customs) Overall coordination: Halvart Koeppen External review: Ecem Bahcelioglu, Janusz Kozakiewicz, Alex Pachai Internal review: Jim Curlin, Ezra Clark, Khaled Klaly, Halvart Koeppen Editing: Jim Curlin, Ezra Clark, Jean Paul Martial Translation: Aram Ohanian Page layout: Vardan Dallakyan Photos: © Polish Customs Adminstration

OZONACTION 1 Rue Miollis, Building VII OZFS/2021/03/1 UNEP Law Division Paris 75015, France [email protected] www.unep.org/ozonaction15