PCB Compliance Triage: class, duties and deadlines for every unit in your PCB inventory
PCB Compliance Triage is a free tool for utilities and industrial sites that hold PCB-containing equipment. List one row per unit with its lab result and choose the country: the tool gives each unit its class, duties, deadlines and a route, under Stockholm, EU or US rules, inside your browser.
How it works
- Choose the country of the site. The country sets the rules: the 27 EU member States get the EU profile, the United States gets 40 CFR 761, and the other Parties to the Stockholm Convention get the Convention base. For a country that has not ratified the Convention, the Convention rules are shown as an international reference, with a notice that only national law applies. You can change the rules by hand.
- Add one row per unit. Tag, equipment type, PCB result in mg/kg, lab method, liquid quantity in litres or kg, and status (in service, stored for reuse, or waste) are enough. Details such as year of manufacture, liquid type, sealed tank or the date of a previous retrofill refine the result when you have them.
- Read the dossier. A live summary counts the units by class, the units past a deadline, the estimated kilograms of PCB in the inventory and the next dated deadline. For each unit the dossier gives the class, the duties, the deadlines (marked overdue when already past), an action and a route: retrofill with reclassification where it is allowed, otherwise disposal. Each rule shows the article or section it comes from.
You can print the dossier or save it as PDF. Seetalabs® keeps nothing: to continue later, save the inventory to a file on your computer and open it next time.
Method and standards
The tool applies three sets of rules, each as written in its source text:
- Stockholm Convention, Annex A Part II (text as of 2025), with the Basel Convention technical guidelines for PCB wastes. Equipment is sorted into the Annex A priorities: above 10 % PCB and above 5 L, above 0.05 % (500 mg/kg) and above 5 L, above 0.005 % (50 mg/kg) and above 0.05 L. The Convention sets 2025 for ending the use of PCB equipment and 2028 for the environmentally sound management of PCB liquids and equipment.
- European Union: Directive 96/59/EC and Regulation (EU) 2019/1021 Annex I and Article 7, read on the consolidated text of 1 January 2026, where the PCB entries are unchanged.
- United States: 40 CFR Part 761, edition of 1 July 2024, with the classes PCB Transformer (500 ppm or more), PCB-Contaminated Electrical Equipment (50 to 499 ppm) and non-PCB, and the presumptions of 761.2 for equipment that was never tested.
Thresholds are applied to the letter. The Stockholm Convention and the EU Directive say "more than" 50 and 500 mg/kg, so 50 and 500 are excluded. The Basel waste entry, the EU waste limit and 40 CFR 761 say "or more", so 50 and 500 are included. The same unit at exactly 50 mg/kg can therefore fall on different sides of the line in different texts, and the tool shows it.
Lab results are checked before they are classified. The thresholds refer to total PCB. Total PCB by IEC 61619:1997, EN 12766-2:2001 Method A or gas chromatography by Aroclor is used as reported. EN 12766-2 Method B (five times the sum of six congeners, clause 4.2.1) is used as an estimate in the Stockholm and EU profiles and is not classified under 40 CFR 761. A sum of other congeners, such as the EU-7 set, is not total PCB and is not classified. When a result lies within the reproducibility of the method from the 50, 500 or 100 000 mg/kg thresholds (R = 2 + 0.25 x for IEC 61619 and Method A), the tool asks to repeat the analysis before deciding.
Retrofill estimate. For a transformer in good condition the tool estimates the PCB content after one retrofill cycle as 10 % of the initial content, the return from the paper after 90 days reported for distribution transformers by UNEP (2002), section 9.4.4. The test after 90 days in service decides the reclassification.
Worked example
Three units from the tool's own test cases, assessed on 26 September 2026:
| Unit | Input | Stockholm | EU | USA |
|---|---|---|---|---|
| Transformer in service | mineral oil, 350 mg/kg by IEC 61619, 800 L | S3: priority (iii) | E3: PCBs 0.005 to 0.05 %, above 5 dm³; the 31 December 2025 date of Regulation 2019/1021 is shown as overdue | U5: PCB-Contaminated Electrical Equipment |
| Askarel transformer | 600 000 mg/kg, 1 200 L | S1: priority (i) | E5: PCBs above 0.05 %, inventory equipment | U6: PCB Transformer; quarterly inspection, annual with containment for 100 % of the liquid |
| Retrofill candidate | transformer, 400 mg/kg, 900 L, good condition | retrofill allowed | retrofill allowed | retrofill allowed |
For the retrofill candidate the tool expects about 40 mg/kg after one cycle (10 % of 400), which is below the 50 mg/kg line of all three texts. The reclassification still depends on the test after 90 days in service.
The first row shows why the EU profile needs both dates. For a unit between 0.005 % and 0.05 %, the Directive lets it run to the end of its useful life, while the Regulation sets removal from use by 31 December 2025 "without prejudice to" the Directive. The tool shows both and leaves the choice to the national competent authority.
Limits
The result is an indication for planning, and it is not legal advice. National transpositions and state rules can be stricter, and the competent authority decides. The Stockholm dates of 2025 and 2028 are subject to review by the Conference of the Parties, and decisions after the 2025 text are not included. In the EU profile the tool does not say whether the Directive or the Regulation date prevails.
What it does not do: national rules (the Irish EPA guidance appears only as an example of practice), PCT and PCBT, dioxin-like PCBs in TEQ, import of lab files, and cost estimates.
Frequently asked questions
Is equipment at exactly 50 mg/kg PCB-contaminated?
It depends on the text. The Stockholm Convention and Directive 96/59/EC say "more than" 50 mg/kg, so 50 is outside; 40 CFR 761 says "50 or more", so 50 is inside. At 50 mg/kg the tool also asks for a repeat analysis, because the result lies within the reproducibility of IEC 61619.
Can I classify a unit from the sum of seven indicator congeners?
No. The thresholds refer to total PCB. EN 12766-2:2001 Method B multiplies the sum of six congeners by 5; a seven-congener sum such as EU-7 includes PCB 118, so multiplying it by 5 is not Method B. The tool marks such a result as not classifiable and asks for total PCB.
Which EU deadline applies to a transformer between 50 and 500 mg/kg?
The tool shows two: end of useful life under Directive 96/59/EC Article 9(2), and removal from use by 31 December 2025 under Regulation (EU) 2019/1021 Annex I Part A. Ask the national competent authority which one it applies.
How much PCB is left after one retrofill?
The estimate is 10 % of the initial content after 90 days in service, a figure reported for distribution transformers (UNEP 2002, section 9.4.4). For 400 mg/kg that is about 40 mg/kg. Power transformers may differ, so the measured result after 90 days decides.
Next: the retrofill candidates
PCB Compliance Triage answers the regulatory question for an inventory, one session at a time. If a unit is a retrofill candidate, the Ester Retrofill & Fire Risk tool checks the fire point and fire distances after a refill with ester, and the PCB class of the drained oil.
The same transformers need their condition followed year after year: Ronin AI does it for the fleet from the laboratory reports. Discuss Ronin AI
<p>The tool runs in your browser. It makes no network requests, and Seetalabs® does not store or see the inventory you enter.</p>
<a href="/tools/disclaimer/">Disclaimer</a>
Tool version 1.0.0. Seetalabs®.
