China’s plan to address fluorochemical emissions might be promising

Man-made fluorochemicals include gases that deplete the ozone layer as well as some of the most potent greenhouse gases known to man. These chemicals are produced only in a handful of countries, with China and the United States making up the lion’s share. China is the world’s largest producer and exporter of hydrofluorocarbons (HFCs), accounting for more than 70 percent of all global HFC production, more than half of which is exported.

Earlier this month, a decree by China’s State Council announced a revision to the rules governing China’s management of ozone-depleting substances. Effective March 1, there will be new controls aimed at emissions from industrial facilities producing fluorochemicals, including both ozone-depleting substances and hydrofluorocarbons, which are potent greenhouse gases.

The rules mandate safe disposal of substances produced incidentally during manufacturing and require entities producing or using substantial amounts of such substances to install automatic monitoring equipment linked to the monitoring network of the environmental authority. These revised rules also introduce severe penalties for illegal acts related to these substances. Any facility found in violation of the rules would be subject to significant fines and confiscation of illegal materials, and may have production suspended for failing to install and properly operate monitoring equipment. 

These updates are in line with the Kigali Amendment to the Montreal Protocol, which China ratified in 2021, formally committing to a global effort on reducing production and use of HFCs. However, the requirements for automatic monitoring and broad emission controls  in production facilities are a significant step beyond what is required under the global treaty.

This action appears to be a response to recent findings that show such production facilities within China are the likely source of significant unexplained emissions that continue to plague the Montreal Protocol.

The Montreal Protocol, considered a successful international environmental treaty, has played a crucial role in environmental protection for over 35 years by phasing out over 99 percent of ozone-depleting substances, also slowing global warming as these gases also have high climate impact. 

Despite this success, recent reports indicate unexpected and significant ongoing emissions linked to unregulated fluorochemical industrial processes. These unexpected emissions have included illegal production and use of a potent banned ozone-depleter, CFC-11, plus rising emissions of several other chlorofluorocarbons used only in production processes to make other fluorocarbon gases, and record high emissions of a potent manufacturing byproduct HFC-23, among others. This raises significant concerns about the need to address gaps and loopholes to secure the ozone layer’s recovery and enhance the treaty’s contribution to addressing climate change.

In 2018, scientists reported unexpected CFC-11 emissions and EIA investigations traced the source to illegal production and use of CFC-11 in the polyurethane foam sector in China. A nationwide enforcement effort in China quickly followed, resulting in a sharp decrease in emissions, but not before causing five years of massive climate and ozone depletion.

However, recent atmospheric observations indicate broader unreported fluorochemical greenhouse gas emissions. Some of these emissions are from illegal production and use of CFC-11, but the primary ongoing sources appear to be emissions of feedstocks, byproducts and intermediates in fluorochemical production processes, which are not fully controlled by the Montreal Protocol.

EIA estimates that these avoidable fluorochemical GHG emissions from production processes are as high as about half a billion tons of carbon dioxide equivalent per year. The Kigali Amendment also required parties to destroy or otherwise eliminate all HFC-23 emissions, “to the extent practicable,” but global studies show a continued mismatch between observed and reported HFC-23 emissions.

Last year, we used cutting-edge infrared detection equipment to uncover fluorochemical companies in the U.S. emitting unknown or unreported HFCs and other gases. This pointed to the urgent need for better monitoring, reporting, and enforcement to prevent these emissions.

Despite the success of the Montreal Protocol in phasing out ozone-depleting substances, emissions from fluorochemical production processes have been overlooked and unregulated for too long, presenting a significant and avoidable opportunity for cost-effective mitigation. After years of campaigning, the last meeting of parties to the Montreal Protocol made some crucial decisions that brought attention to this problem, which could potentially generate new data for re-evaluating exemptions from production and consumption controls.

The announcement by China for direct monitoring of emissions could be a significant step in that direction. Emissions reductions have yet to be reported from China, and it remains to be seen if this regulatory revision leads to tangible results, especially in lowering emissions of HFC-23, whose climate impact is 12,000 times that of carbon dioxide.

But this new revision, along with additional atmospheric data, could help resolve some of the open questions on how much of the record global HFC-23 emissions are coming from Chinese facilities versus other sources. If the Chinese government decides to share this data with the global community, that would be a massive act of leadership by China toward improving transparency and enforcement of emissions controls globally.

Avipsa Mahapatra is the director and Christina Starr the senior manager of the Environmental Investigation Agency Climate Campaign, which focuses on reducing global super-pollutant emissions, including hydrofluorocarbons.