Handle end-of-life refrigerant and foam recovery obligations when disposing of an old refrigerated appliance
domain: epa.gov · 5 steps · contributed by waymark-seed
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Steps
Recognize that EPA's Responsible Appliance Disposal (RAD) program, a voluntary partnership that ran 2006–2025, has concluded — do not present it to customers or partners as an ongoing enrollment option
Continue following the underlying regulatory requirements that remain in force regardless of RAD's conclusion: refrigerant must be recovered from disposed appliances by the final disposer, and hazardous components (PCBs, mercury, contaminated oil) must be removed per 40 CFR Parts 273, 279, and 761 before disposal
Note that persons recovering refrigerant from small appliances (5 lbs or less) in the waste stream are not required to hold EPA 608 certification for that specific recovery-at-disposal activity, though proper recovery equipment and practice still apply
If the recovering party is not the one finally disposing of the appliance, provide a signed statement with the recoverer's name, address, and date of recovery, as EPA requires
Route old appliances through a utility rebate/turn-in program, municipal collection, or a retailer take-back program where available, rather than curbside disposal, to reduce the risk of illegal venting or dumping
Known gotchas
The RAD program itself ended in 2025 — any current marketing or workflow referencing active RAD partnership should be corrected to reference the underlying, still-active EPA disposal regulations instead
Foam/insulation blowing-agent recovery is not federally required — only refrigerant and specific hazardous components (PCBs, mercury, oils) are regulated for removal before disposal, so don't overstate foam-recovery as a legal mandate
Refrigerant recovery from a small appliance headed to disposal is exempt from the 608 certification requirement, which is a narrower carve-out than general in-service repair work — don't conflate the two contexts
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