Preventing Illegal Trade

A successful phase-down of HFCs depends on robust implementation and enforcement of the Montreal Protocol and associated domestic implementation by countries. The illegal production, use and trade in banned or controlled ozone-depleting substances and greenhouse gases used in the cooling sector remains a critical obstacle to international efforts to limit the worst impacts of climate change.

EIA has about three decades of experience investigating and exposing illegal production and criminal trade that endangers our environment and climate, including in ozone depleting and climate damaging coolants. We will continue to work to expose and document the extent and nature of any illegal production, use, and trade in synthetic fluorinated chemicals to inform the institutional and policy responses needed to prevent future reoccurrences and ensure full realization of these critical climate mitigation benefits.

Following scientific findings that detected unexplained rising emissions of CFC-11, an EIA investigation revealed widespread illegal use in China’s foam industry. Our initial findings published in Blowing it: Illegal Production and Use of CFC-11 in China’s Foam Blowing Industry exposed eighteen companies that reported widespread illegal use of the banned substance as a blowing agent in producing polyurethane foams used in building insulation and other applications.

Our subsequent report Tip of the Iceberg: Implications of Illegal CFC Production and Use reinforced our initial findings by providing hard evidence of CFC-11 use in lab tested foam samples gathered in China, analyzed the potential magnitude of the new ‘bank’ of CFC-11 foams created by this illegal use, and outlined unanswered questions regarding the potential extent of this environmental crime.

EIA has called for a comprehensive review of the monitoring and enforcement regime of the Montreal Protocol while also urging Parties to take action individually to ensure robust domestic laws and enforcement, including exploration of modernized national traceability systems that could provide end-to-end visibility of production, transport and use of controlled substances.

Objectives:

• Investigate and expose illegal trade
• Identify key drivers
• Strengthen monitoring and enforcement regimes