Implications of illegal CFC (R11) production – update

In May 2018, scientists revealed that atmospheric levels of CFC-11 were significantly higher than expected, indicating new illegal production and use of R11. After much research, the Environmental Investigation Agency (EIA) now has released a report on the matter. Check it out below. 

R11 report

The Environmental Investigation Agency (EIA) has released their briefing to the 30th Meeting of the Parties (MOP) to the Montreal Protocol entitled ‘Tip of The iceberg: implications of illegal CFC production and Use’.

In May 2018 scientists revealed that atmospheric levels of CFC-11, a potent ozone-depleting substance banned globally since 2010, were significantly higher than expected, indicating new illegal production and use of CFC-11 occurring in East Asia.

EIA investigations quickly pinpointed that illegal use of CFC-11 in China’s polyurethane (PU) foam insulation sector was likely a major source of the new emissions. 18 out of 22 companies interviewed from 10 provinces confirmed using CFC-11 as the main blowing agent in the production of foam panels and spray foams. Traders and buyers of CFC-11 in China repeatedly stated that it was used in the majority of China’s rigid PU foam sector. The core EIA findings were backed up by an independent investigation by the New York Times as well as official Chinese government documents. A 2016 report from environmental officials in Shandong, a key area for foam production, had already warned that there was ‘still a large volume of illegally produced CFC-11 being used in the foam industry’.

A report summarising the investigations and analysing the potential drivers for the illegal trade – ‘Blowing It: Illegal Production and Use of Banned CFC-11 in China’s Foam Blowing Industry’ – was published in July 2018 and distributed to the Parties to the Montreal Protocol at its 40th Open-Ended Working Group (OEWG) meeting in Vienna.

Parties to the Montreal Protocol, including China, responded swiftly. China launched a nationwide inspection and has undertaken several enforcement actions including shutting down one illegal CFC-11 production site.

At OEWG-40, the Parties unanimously agreed a draft Conference Room Paper expressing ‘serious concern’ about the substantial CFC emissions, and requesting a number of actions to allow clear identification of the source of emissions, including analysis and further information from the Technical and Economic Assessment Panel (TEAP) and Scientific Assessment Panel (SAP).

As Parties continue their deliberations at the 30th Meeting of the Parties in Ecuador, this report offers additional information and analysis regarding the illegal use and trade in CFC-11 and looks at the broader implications for compliance and enforcement of Montreal Protocol obligations. It highlights a number of remaining gaps in the understanding of the current status of CFC-11 use, estimates the size of the new bank of CFC-11 being created and offers recommendations to the Montreal Protocol and its Parties for next steps. This report also releases new independent laboratory test results that clearly confirm the use of CFC-11 in three enterprises previously identified by EIA, reinforcing the credibility of their statements that CFC-11 was the predominant blowing agent used at these facilities.

EIA cautions Parties not to treat the issue of illegal trade in CFC-11 as an isolated enforcement issue limited to one country. A new study that provides compelling evidence potentially linking elevated levels of another ODS, carbon tetrachloride, to the illegal production of CFC-11, suggests that this is just the tip of the iceberg. The scale and impact of the illegal trade demonstrates that the Montreal Protocol’s current compliance and enforcement regime is not fit-for-purpose and requires modernization. This is particularly urgent considering the entry into force of the Kigali Amendment in 2019, which will present new challenges to all Parties. Lessons must be learned and swiftly applied to ensure that all Parties are able to comply with the critical obligations under the Protocol and maximise global efforts to combat global warming and ensure the recovery of the ozone layer.

Immediate response to the CFC-11 scandal

In response to EIA’s report, China announced a nationwide inspection on ODS compliance in July 2018, including a joint inspection with local authorities on 19 PU foam producers and a business cluster identified by EIA. In 12 of the enterprises under investigation no sales or use of CFC 11 were found but CFC-11 was found in one enterprise in polyether polyol. According to a report in August 2018, local authorities took enforcement measures and were continuing to investigate six remaining enterprises identified by EIA. However no further information has been released since this time.

According to a report from China’s Ministry of Ecology and Environment (MEE), authorities also uncovered an illegal CFC-11 production facility in Mengzhou City, Henan Province, in August 2018. The CFC production was hidden in a mechanical processing enterprise; 29.9 tonnes of illegally produced CFC-11 and about 30 tonnes of carbon tetrachloride were seized. According to the report, three suspects were arrested and two others were on the run.

It had been previously reported by a spokesperson from the Chinese embassy in the UK that local authorities uncovered two enterprises in Liaoning and Henan province that had been producing CFC-11 and CFC-12 respectively. The seized CFCs and raw materials were confiscated and local police filed charges against the enterprises and were hunting down suspects. 7 It is unclear if the Henan seizure is a separate enforcement action to the one reported by China’s MEE. Meanwhile, the China Plastics Processing Industry Association (CPPIA) launched an initiative to stop illegal CFC-11 use, stating it is the obligation of every company industry-wide to protect the environment, operate in accordance with the law, and to voluntarily boycott illegal blowing agents. Additionally, the CPPIA initiative included clearly labelling the blowing agent in raw material trading contracts and established a hotline to report illegality

The report includes

The EIA report also looks at:

  • CFC-11 found in tested PU foams
  • Understanding the unexpected CFC-11 emissions
  • Potential CFC-11 emissions from illegal use in the PU foam sector
  • Potential bank created by illegal use
  • Areas of uncertainty and unanswered questions
  • Illegal trade in CFCs and other ODS
  • The CFC-12 mystery
  • The CTC Mystery
  • Monitoring, enforcement and compliance
  • Trade in polyols
  • Disposable cylinders
  • Conclusions and recommendations

Download the report pdf



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