Before a commercial fridge, freezer or air conditioning unit leaves your site, a certified person has to recover the refrigerant, and the unit is then classed as hazardous waste. It needs a registered carrier and a consignment note, and the paperwork stays your responsibility.
Picture the week before a refit. The new display chiller is booked for Tuesday, the old one is still plugged in at the back of the shop, and a general waste firm has offered to "take it away" for a flat fee. Nobody has said who is recovering the gas, what the unit gets classified as, or who signs for it when it goes.
At a glance
| Question | What the rules say |
|---|---|
| Who recovers the refrigerant? | Operators of stationary refrigeration and air-conditioning equipment must ensure recovery is carried out by natural persons holding the relevant certificates (Article 8(1)). |
| Where does the recovered gas have to end up? | It must be "recycled, reclaimed or destroyed" (Article 8(1)). |
| Is the scrapped unit hazardous waste? | Yes. Fridges, freezers, chillers and air-conditioning units appear in the hazardous classes on the gov.uk table, in both the ozone-depleting and "Other" rows. |
| Which code applies to a commercial unit? | 16 02 11* if it contains ozone-depleting substances as foam blowing agents or coolants. 16 02 13* for other units. The household codes (20 01 23* and 20 01 35*) sit in a separate column. |
| When do you classify it? | Before it is collected, disposed of or recovered. |
| What if you are unsure? | Treat it as hazardous and POPs waste as a precaution. |
Source: Regulation (EU) No 517/2014, Article 8, on legislation.gov.uk and gov.uk, WEEE: how to classify
The gas comes out first
Pages that rank for commercial fridge recycling are mostly collection services, and they start with the lorry. The legal order starts earlier. The retained F-gas Regulation says operators of stationary equipment "shall ensure that the recovery of those gases is carried out by natural persons that hold the relevant certificates provided for by Article 10, so that those gases are recycled, reclaimed or destroyed". The list of covered equipment includes "the cooling circuits of stationary refrigeration, stationary air-conditioning and stationary heat pump equipment".
Note who the duty falls on. It is the operator, which in most cases is the business running the kit. The regulation puts the duty on the operator, so a driver with no certificate is not the answer, and a cut pipe on a rough lift is an avoidable way to lose the gas.
If the equipment holds F gas equivalent to 5 tonnes or more of carbon dioxide, there is a records duty on top. The gov.uk page on recording F gas says you must keep records for 5 years, including "what you've done to recover and dispose of gas", with the example of recording the registered waste carrier you use. It also asks users and operators to keep the name, address and certificate number of any company used to install, service or decommission the equipment. Our F-Gas regulations guide for UK businesses covers the wider duties, including leak checks.
Why a scrapped fridge counts as hazardous waste
Gov.uk is blunt about it. On its classification page, the entry for fridges, freezers, chillers and air-conditioning units says "Coolants and foam may also be hazardous", and both rows of the table are marked hazardous. That is why a commercial fridge cannot go in a skip or to a scrap yard that is not set up to handle it.
The foam matters as much as the gas, and recovering the refrigerant does not turn the carcass into ordinary scrap.
The rules are set by category, so across the equipment below the differences are mostly scale and records.
| Equipment | Refrigerant step | Waste code (industrial or commercial) | Records trigger |
|---|---|---|---|
| Plug-in commercial fridge or freezer | Cooling circuit of stationary refrigeration equipment: recovery by certified persons (Article 8(1)(a)) | 16 02 11* with ozone-depleting foam or coolant, otherwise 16 02 13* | F gas records if the charge is 5 tonnes CO₂e or more |
| Cold room condensing unit and evaporators | Cooling circuit of stationary refrigeration equipment: recovery by certified persons (Article 8(1)(a)) | gov.uk lists fridges, freezers, chillers and air-conditioning units. Ask your contractor to confirm the code for plant that is not named | As above |
| Split air conditioning | Cooling circuit of stationary air-conditioning equipment: recovery by certified persons (Article 8(1)(a)) | 16 02 11* or 16 02 13*, by the same test | As above |
| VRF or multi-split system | Same wording as split systems, applied to a larger charge | 16 02 11* or 16 02 13*, by the same test | As above, and a larger charge makes the threshold more likely to apply |
Source: Regulation (EU) No 517/2014, Article 8 for the refrigerant step, and gov.uk, WEEE: how to classify for the codes. The 5 tonnes threshold is from the gov.uk page on recording F gas, linked above. The cold room plant and VRF rows apply the category wording; neither source names those items.
The paperwork: consignment notes and transfer notes
This is the step people skip. A hazardous load needs a consignment note, not the waste transfer note you may use for general rubbish. Gov.uk's steps for producers and holders of hazardous waste are short: classify the waste, separate and store it safely, use authorised businesses, fill in your part of the consignment note, and keep a register.
The consignor has to be there on the day. The consignment note guidance says "The consignor must be present when the waste is collected. The carrier cannot complete part D for you." Part D includes confirming that the carrier is registered, and the same page says "you must check that the carrier is registered".
For non-hazardous waste the document is lighter. The gov.uk business waste page lists the duties as completing a waste transfer note for each load, checking your carrier is registered, and not allowing the carrier to dispose of your waste illegally. Gov.uk's classification table marks fridges, freezers, chillers and air-conditioning units as hazardous, so treat the consignment note as the default and let the classification confirm it.
Who is responsible for what
The honest summary is that responsibility is shared and cannot be contracted away in full. The business is the waste producer or holder, the engineer does the gas work, and the carrier moves the load. Each has a different job on the page.
| Party | What the gov.uk text puts on them |
|---|---|
| Business (producer or holder) | Classify the waste. Separate and store it safely. Use authorised businesses and "check that waste carriers are registered and waste sites have environmental permits". Fill in the consignment note parts that apply, keep one copy and give 2 copies to the carrier. Keep records for 3 years at the premises that produced or stored the waste. |
| Operator of the equipment | Ensure recovery of the gas is carried out by certified natural persons (Article 8(1)). Keep F gas records for 5 years where the 5 tonne threshold applies. |
| Certified person (engineer) | Carries out the recovery so the gas is recycled, reclaimed or destroyed (Article 8(1)). |
| Waste carrier | Register as a waste carrier. Check parts A and B of the consignment note and the waste before accepting it. Take the waste to the destination on the note, which must be an authorised waste site. Keep records for one year. |
Source: gov.uk, Hazardous waste: Producers and holders and gov.uk, Hazardous waste: Carriers. The operator and engineer rows are from Article 8(1), linked above.
Producer take-back and replacement equipment
Does the manufacturer have to take the old unit back? Gov.uk describes a financing duty, not a free skip. A producer may have, in the words of gov.uk's producer responsibility guidance, "a producer obligation to finance the cost of collection, treatment, recovery and environmentally sound disposal of non-household EEE arising from end-users". A producer compliance scheme can take on those obligations for non-household WEEE, and the scheme covers equipment placed on the market on or after 13 August 2005, and older equipment that the user is replacing with equivalent new equipment. It applies "unless alternative arrangements have been made between the producer and the business end-user".
Read that last clause twice. Your supply contract may already have settled who pays for removing the old kit. Before you order, ask the supplier of the new equipment how the old unit is being handled and get the answer in writing. Whether a particular unit and a particular purchase fall within the scheme is a question for the producer or their compliance scheme, and the Environment Agency can confirm the rules if you are unsure. Our guide to repair versus replacement helps if the real question is whether the unit has to go at all, and the HFC quota step post covers plant where the refrigerant is forcing the decision.
Air conditioning removal and old cold room plant
Air conditioning disposal follows the same chain as a fridge, but the practical problems differ. Split units have a refrigerant circuit running between indoor and outdoor parts, often through a wall or ceiling void, and the refrigerant has to be recovered by a certified person before anyone cuts a pipe. Cold room plant is bigger and often sits on a roof or in a yard.
If the system runs on R22 or R407C, the refrigerant itself can be the reason you are replacing it. Our post on repairing or replacing R22 and R407C air conditioning covers that choice. Once the decision is made, the removal still has to follow the gas, classification and paperwork steps above.
Questions to ask before you sign anything
- Who is recovering the refrigerant, and can they show the relevant certificate?
- Which waste code are they using for each item, and is the unit going out on a hazardous waste consignment note?
- What is the carrier's registration number, and where does the load end up?
- Will you receive your copy of the consignment note, and who is keeping the F gas record?
- Does your supply contract say anything about the producer taking the old equipment back?
If the answer to "who is collecting it" is a van with no name on the side, do not wave it off the forecourt.
When to call an engineer
Gas recovery is not something to improvise with a spanner and a skip. If you are replacing refrigeration or air conditioning, it is worth talking to us early about commercial refrigeration installation. Be Cool is a family-run London firm with F-Gas certified engineers, trading since 2004, and we can plan the new equipment around your site. Who collects the old unit and under which waste paperwork is something to settle in writing before the job, with whoever is doing the removal.
Frequently asked questions
Can I put an old commercial fridge in the general waste or a skip?
No. Gov.uk classifies fridges, freezers, chillers and air-conditioning units as hazardous waste, with codes 16 02 11* and 16 02 13* for industrial or commercial items. It needs a carrier and site that are authorised to take it.
Does the refrigerant have to be removed before disposal?
Yes, for fluorinated gases in stationary refrigeration and air-conditioning equipment. Article 8(1) of the retained F-gas Regulation requires recovery by natural persons holding the relevant certificates.
What is the waste code for a commercial fridge?
Gov.uk gives 16 02 11* for industrial or commercial units containing ozone-depleting substances as foam blowing agents or coolants, and 16 02 13* for other units. If you are unsure, it says to treat the item as hazardous and POPs waste as a precaution.
Do I need a consignment note for a fridge collection?
Where the waste is hazardous, gov.uk says producers and holders fill in the parts that apply to them, keep one copy and give 2 copies to the carrier. Keep your records for 3 years. Confirm your own position with the Environment Agency or your waste contractor.
Does the manufacturer have to take the old equipment back?
Not automatically. Gov.uk describes a producer obligation to finance disposal of non-household equipment, which a compliance scheme can take on, unless other arrangements are agreed with the business user. Check your supply contract.
Do I need to check the waste carrier?
Yes. Gov.uk says to check that your carrier is registered, and for hazardous waste the consignor certifies this on part D of the consignment note.
Plan the removal before the delivery date
Too often the replacement is booked first and the old unit is treated as an afterthought. Settle the gas, the classification and the carrier first, and the day itself is uneventful. Rules and guidance change, so this reflects the gov.uk and legislation.gov.uk pages as of October 2026, and the Environment Agency or your waste contractor can confirm your own position.
About the author: Ali Elm runs Be Cool Refrigeration & Air Conditioning, a family-run London firm that has been installing, servicing and repairing commercial refrigeration and air conditioning since 2004. His F-Gas certified team has delivered more than 2,000 projects across London and the South East.
Last updated: 26 October 2026
Written by
Ali Elm
Ali is the Head of Operations at Be Cool Refrigeration with over a decade of hands-on experience in HVAC and commercial refrigeration. He oversees every installation, repair, and maintenance project, making sure the work meets the highest standards. Ali holds full F-Gas certification and has worked across residential, commercial, and industrial refrigeration systems throughout London and the South East. When he is not on site, he writes these guides to help business owners and homeowners understand their cooling systems better.