Hong Kong Customs displays 82.5kg of rhino horns from South Africa and destined for Malaysia. Photo: ISD

EIA Briefing to the 91st Meeting of the Executive Committee of the Multilateral Fund (MLF)

A number of important tasks lie ahead of the Members of the Executive Committee to the Multilateral Fund (ExCom MLF) at its 91st meeting. First and foremost, the Members need to make progress on the cost guidelines for the HFC phase-down under the Kigali Amendment, including the starting point for sustained aggregate reductions, incremental operating costs and elements related to energy efficiency, refrigeration servicing sector funding and a funding window for dealing with banks of used or unwanted controlled substances.

The following briefing outlines EIA’s comment and recommendations on China’s updated reports under agenda item 7b, institutional strengthening, a number of project proposals, energy efficiency, banks and policies and procedures relating to monitoring, reporting and verification in response to the issue of unexpected CFC-11 emissions.


Agenda item 7(b): Reports on projects with specific reporting requirements

China’s Updated Reports Regarding CFC-11, CFC-12 and CTC (Doc 91/18/Add 1)

This agenda item was deferred from the 90th meeting. Three reports submitted by China deal with follow up actions and updates regarding issues relevant to the unexpected increase in emissions of CFC-11, and associated issues regarding CFC-12 and CTC. EIA is encouraged by China’s reports on implementing a number of monitoring, regulatory and enforcement actions, however serious questions remain as to whether underlying issues that led to the emissions have been fully resolved, notwithstanding the observed decline in regional CFC-11 and CTC emissions beginning in 2018.

As further detailed below, neither the independent consultant’s study dealing with circumstances that might have led to illegal production and use of CFC-11 and CFC-12, nor China’s report on the production of CTC and its feedstock uses, provide consistent and comprehensive answers regarding the origins or nature of the unexplained emissions. In particular, there is a large disparity between regional atmospherically derived estimates of CTC emissions and the potential emissions estimates in the submitted report.

New scientific observations of rising global emissions of HCFC-141b between 2017-2021 add to these questions.1 Although the regional origin of increasing global HCFC-141b emissions is not yet clear, nor is the possibility that banks are contributing to the rise ruled out, the timely coincidence of this increase with the rapid decline in CFC-11 emissions raises a possible connection between these atmospheric trends due to replacement of illegal CFC-11 with unreported illegal production and use of HCFC-141b as an alternative blowing agent.

China’s Report on Monitoring and Law Enforcement Progress

EIA notes the additional details regarding significant sampling and testing efforts undertaken in 2019 and continued efforts toward expanding local capacity for rapid detection. According to the Study on Supervision and Law Enforcement, CFC-11 was contained in products from 37 enterprises (6 combined polyether and 31 foam product enterprises) based on rapid portable testing of samples from 322 enterprises between June and August 2019. Laboratory retests confirmed illegal use of CFC-11 in 16 enterprises.

It is noteworthy that China reports that none of the 16 entities conclusively found to be using illegal CFC-11 were registered with the China Plastic Processing Industry Association (CPPIA) or had received funding from the Multilateral Fund. This seems to reinforce EIA’s findings that the illegal production and use may have been mostly occurring in the domain of underground and unregistered enterprises, outside the scope of the Government’s primary means of engagement with industry.2 The extent of this unregistered and less-understood segment of the foam market in China is highly pertinent to the question of widespread illegal production and use of CFC-11.

Of the 16 enterprises, convictions and/or dismantling of enterprise operations appears to have been limited to the one major producer, the Minghe company, and two smaller enterprises, while the majority of small foam enterprises are presumed to be still operating. Additional information regarding follow up inspections or verifications with compliance at these entities would be beneficial to ensuring these enterprises have transitioned to legal blowing agents.

EIA notes that following distribution of 50 portable detection devices to local environmental enforcement bureaus across 30 provinces in 2019, information is yet to be shared on ongoing detection, sampling, and testing efforts by local authorities. MEE launched a new round of special ODS law enforcement inspection nationwide at the end of July 2020, mainly targeted at HCFC-141b and HCFC-22 production enterprises as well as illegal production and use of CFC-11. It would be helpful to see additional updates on the scope of ongoing sampling and testing conducted after 2019 and findings from this new round of inspections will be helpful globally.

Finally, the report also states that MEE will start the construction of ODS monitoring stations in 2021 and conduct ODS monitoring in 2022 as planned. EIA looks forward to additional updates in this regard and transparent sharing of resulting data and analysis.

Study to determine regulatory, enforcement, policy or market circumstances that might have led to illegal production and use of CFC-11 and CFC-12

The study prepared by consultant ESD China Limited does not conclusively determine the circumstances that led to widespread illegal production and use of CFC-11 in the polyurethane foam sector. The study utilised on-site visits and interviews as well as an ODS market survey and a mass-balance analysis to determine the degree to which previously phased out substances have been produced and used after being prohibited.

Mass balance analysis

EIA questions the basis and key assumptions of the mass balance analysis of raw materials linked to rigid PU foam manufacturing, which is central to the study’s conclusion that “widespread production and consumption of CFC-11 in the PU foam sector during 2008-2018 is highly unlikely in China”. The analysis bases its assumptions regarding the quantities of CFC-11 that could have potentially been used and emitted on a ratio to the consumption of isocyanates (polymeric MDI), the other component of foam mixed with pre-blended polyols containing CFC- 11 or another blowing agent. This is due to a higher level of confidence in the MDI data from a smaller number of producers and importers compared with the numerous and varied polyol suppliers. This leaves the study open to a number of potential issues regarding assumed ratios and mixtures in various types of foams, particularly given the range of practices that may exist in various less well understood polyol entities. The analysis also does not seem to take into account the potential emissions factors or conversion rate of such polyol entities using a given quantity of CFC-11 in production of spray foams.

Additionally, the report indicates the mass balance analysis is based on data from the China Plastic Processing Industry Association (CPPIA), whereas information on monitoring and enforcement actions indicates that illegal CFC-11 was detected at enterprises that are not members of CPPIA. It is not immediately clear if the MDI consumption data would account for consumption by non-CPPIA enterprises. This calls into question the completeness of the analysis, if it fails to account for consumption by an uncertain market segment outside of the CPPIA’s membership. Additional clarification in this regard would be helpful to assess the validity of the mass-balance analysis outputs and conclusions.

Market trends in foam blowing agents

The study acknowledges that there appears to have been a shortfall of CFC-alternatives for foam blowing during the 2008-2010 period immediately after the CFC-11 phase-out that may have been filled by illegal trade or stockpiles. It also outlines trends in market consumption and prices of alternative blowing agents during 2008-2018, with EIA noting:

  • A tightening market and steeply rising prices for HCFC-141b were seen after introduction of the production quota system in 2013, with prices rising more than 100% from 10,000 RMB/ton in 2013 to 21,800 RMB/ton in 2018;
  • Market prices of hydrocarbon blowing agents remained much lower but were not widely used in the small foam enterprises due to safety concerns or in spray foams due to flammability;
  • HFC-245fa blowing agents were available at significantly higher prices, ranging from a low point of 29,400 in 2014 increasing to 60,000 RMB/ton in 2018. This limited the overall amount of HFC blowing agent uptake despite increasing demand under the HCFC-141b phase-out.

These market trends, including the increasing prices of other blowing agent alternatives, reflect consistently with earlier EIA hypotheses on the drivers for significant illegal use of CFC-11.3 In EIA’s view, they are equally relevant to the current adoption of HCFO/HFO alternatives to HFC, as clearly outlined in the 2022 Progress Report of the TEAP.

Law enforcement and regulatory improvements

EIA concurs with several of the key findings of the study regarding proposed law enforcement and regulatory improvements. Several of the identified findings align closely with EIA’s previous recommendations, including:

  • Strengthen efforts and frequency of routine ODS law enforcement at local levels;
  • Improve enforcement in remote areas where routine supervision and management capacity is weaker;
  • Enhance capacity and training with rapid detection equipment;
  • Necessity for a sustainable compliance mechanism after initial phase-out goals have been achieved along with better delineation of compliance responsibilities at different levels of government;
  • Punitive penal policies require strengthening, while incentive policies should be formulated to foster innovation in alternative technologies.

Updated report on the production of CTC and its feedstock uses in China

At its 84th meeting, ExCom requested an updated report on the production of CTC and its feedstock uses in the country including: (i) an update on the progress in monitoring perchloroethylene (PCE) plants that used the alkane chlorination process; (ii) any additional information relevant to the difference in emissions described in the report, and the estimated CTC emissions from China included in section 1.2.3 of the Scientific Assessment of Ozone Depletion: 2018; and noted that the Government of China was considering monitoring the PCE that used the alkane chlorination process, and to invite the Government to include in the updated report any actions taken on that matter (decision 84/41).

The updated report states that only one PCE plant uses the alkane chlorination process that produces CTC by-product. The PCE plant does not have a CTC purification unit to separate CTC from the process streams that include a mixture of CTC, PCE, and other components that are recycled directly in the reactor. Accordingly, the Government considered the risk of diversion of CTC from the plant is low and therefore has not taken any additional actions to monitor the PCE plant.

As the Secretariat notes, China’s updated report on CTC and its feedstock uses does not include information or analysis to address the difference in emissions reflected in the 2018 Scientific Assessment of Ozone Depletion and more recent scientific estimates by Lunt et al. (2018)4 and Park et al. (2021).5 The emissions estimated by the model are orders of magnitude less than those estimated by Lunt et al. Park et al. reported a decline in emissions of CFC-11 and related chemicals, including CTC, from eastern China. Nevertheless, CTC emissions estimated by Park et al. for 2018-2019 remain two and one order of magnitude higher than the estimated CTC emissions and maximum CTC emissions respectively, as presented in the updated report. Despite the science pointing to regional emissions attributable to eastern China, the Government of China continues to attribute this disparity to a global issue involving other regions and the gap in top-down vs. bottom-up estimates in global emissions. EIA recommends additional analysis of more recent atmospheric data from at least one site within China available from the Global Atmospheric Watch (GAW) at Shangdianzi, as noted by the secretariat, in order to verify other recent findings.

While real-time monitoring is reported to be in place for chloromethane (CM) facilities, there are questions as to whether the monitoring of the growing number of registered feedstock users is adequate. As the Secretariat notes, reported material conversion rates for the same feedstock uses differed across years and facilities. Feedstock uses of CTC are reported to have grown considerably (by 70%) between 2015 and 2019. Manufacture of HCC-240fa, used to make HFOs and HFC-245fa, became the largest feedstock use in 2019, accounting for approximately 40% of the CTC used as feedstock. It is also noted that CM producers have not considered technology upgrades that could further reduce the concentration of CTC in chloroform, another potential source of emissions.


Given the remaining open questions regarding resolution of the underlying issues related to CFC-11 emissions, and the continued unexplained disparity in modelled versus observed regional emissions of CTC in China, EIA recommends continued reporting on these aspects, with particular attention to:

  • Additional information regarding any follow up inspections or verifications with foam entities still operating that were found previously to be illegally using CFC-11;
  • Scope and progress of ongoing rapid detection, sampling and testing efforts by local environmental bureaus;
  • Expansion of the atmospheric monitoring network and real-time sharing of data from atmospheric monitoring as it becomes available;
  • Analysis and sharing of available data on CFC-11, CFC-12, CTC and HCFC-141b production, use and consumption;
  • Clarification of CTC feedstock use monitoring, given the inconsistent conversion rates across time and similar uses;
  • Strengthened capacity building of local governments for sustained compliance.


Agenda item 9d: Project Proposals

General comments on activities relevant to both HCFC and HFC consumption

Given the significant uptake of HFCs in Article 5 Parties, EIA recommends that agreements on all new HPMPs contain language that encourages countries to simultaneously address HFCs wherever efficient and cost-effective to do so, and that additional resources for these activities are allocated. For example, training and capacity building for customs officers, including training material, identifiers, trainer costs could encapsulate HFC elements since countries are required to implement a licensing system for the Kigali Amendment.

EIA reiterates previously expressed recommendations on servicing sector activities under HPMPs, namely that:

  • As far as possible, all servicing sector activities should be immediately applied or easily extended to include HFCs and should incentivise the uptake of sustainable low-GWP technologies, i.e. natural refrigerants. For example, certification schemes for RAC technicians should be mandatory and should include HFCs and all alternatives to HFCs.
  • Containment, labelling and reporting measures should cover HFC refrigerants and all levels of the supply chain, including provisions for storage, transport, processing, disposal, resale, recovery, recycling and reuse; reclamation of HFC blends may require more sophisticated fractional distillation than for reclaiming only HCFCs, and investments in such new reclamation facilities and recovery equipment should be designed to handle both where feasible.
  • Policies, regulations and incentives to discourage the uptake of HFC-based technologies and the development of national standards for the safe installation, transportation, storage, operation, and maintenance of energy-efficient, low-GWP RAC equipment are critical. EIA commends Eritrea’s Stage II proposal, which aims to develop RAC technical standards incorporating energy efficiency and the safe use of low-GWP technologies in the country and an RAC green procurement plan, with capacity-building workshops to promote enforcement and green procurement;
  • Bans on import of HCFC-containing equipment should be in place by 2025 at the latest, and preferably earlier, given the average lifetime of equipment.
  • Actions to enforce the HCFC phase-out can help prepare countries for challenges likely to occur with respect to the illegal trade in HFCs. EIA commends countries planning to conduct border dialogues with neighbouring countries. This type of coordination is critical for effective enforcement.

South Africa Doc 91/51

South Africa is proposing a Stage II HPMP, at the amount of US $8,690,000, plus agency support costs of US $608,300 to phase out 99.00 ODP tonnes of HCFCs in order to meet the 2025 (67.5%), 2028 (97.5%) and 2030 (100%) targets.

EIA commends South Africa for implementing and enforcing a national ban on non-refillable cylinders, as recommended by the Parties to the Montreal Protocol in Decision XIX/12. The majority of known ODS and HFC smuggling cases are facilitated by the use of non-refillable or ‘disposable’ cylinders, as their disposable nature means they can be freely traded and not traced back to the source. The cylinders result in a residual quantity of refrigerant, or ‘heel’, being emitted to the atmosphere as they must be cut or punctured before entering the waste stream. If the cylinders do not enter the formal waste stream the heel remains until the container degrades and is ultimately released. The vapour heel represents about 3% of refrigerant charge, and the liquid heel represents between 5-8%.6 South Africa estimates that more than 40,000 disposable cylinders are discarded each year.

EIA recommends that information from the assessment of the ban’s impact on economic growth, socio-economic conditions and the environment is shared with the Executive Committee. EIA supports a global ban on disposable cylinders, as they increase emissions and facilitate the illegal trade.

India (Doc 91/42)

India’s Stage III HPMP proposal aims to phase out 97.5% of HCFCs by 2030. The HPMP proposes to phase out 222.92 tonnes of HCFC-22 in the air-conditioning sector by converting 13 micro (<1 tonne), small (1-5 tonnes), and medium-sized (5-20 tonnes) room AC enterprises to HFC-32 and converting one small and two large-sized (≥20 tonnes) commercial AC and chiller enterprises to HFC-32 and HFC-448A for equipment with cooling capacity greater than 4.5 tonnes of refrigeration (TR). India also proposes to phase out 163.19 tonnes of HCFC-22 through the conversion of 41 commercial refrigeration enterprises to R-290 and R-600a, and the manufacture of process chillers in seven enterprises R-290 and HFC-448A (for larger capacity equipment).

The Secretariat has questioned the need for introducing HFC-448A in larger commercial AC equipment and process chillers, given that a shorter HPMP would allow time for further development of low-GWP alternatives. HFC-448A is an HFC/HFO blend containing HFO-1234yf and HFO-1234ze with a GWP of 1,273. In response India proposed to convert such equipment to HFC-32.

EIA also questions the choice of HFC-32 technology instead of R-290, given the high GWP of HFC-32 (2,690 over a 20-year period7) and the clear transitional nature of the refrigerant which cannot meet the requirements of the Kigali Amendment.8 Given the recently updated IEC- 60335-2-40 standard, which will allow higher charge limits of hydrocarbons in split AC and heat pump equipment, there is no justification for the MLF to fund transitions to unsustainable high- GWP technologies in room AC. This is particularly true in India, where the Godrej company has trailblazed the commercialisation of R290 split ACs. The globally installed base of R290 splits is estimated to exceed 800,0009 and 2% of the India market in 2017-18.10 Additional manufacturing of HFC-32 units will only serve to unnecessarily increase the Kigali baseline and HFC servicing needs for India, which is in Group 2 of the A5 countries.

The Secretariat estimates that the replacement of HCFC-22 by HFC-32 in residential and commercial AC manufacturing and by R-600a, R-290 and HFC-32 in process chillers and commercial refrigeration manufacturing according to the project will result in avoiding the emissions of approximately 1,344,000 tCO2-eq. based on the revised Multilateral Fund climate impact indicator (MCII). A transition to R-290 in place of HFC-32 would increase this climate benefit considerably. According to Purohit et al. (2022), a transition to propane as an energy- efficient and commercially available low-GWP alternative in split ACs could avoid 0.09 (0.06 to 0.12) °C increase in global temperature by the end of the century. This is significantly more than the 0.03 (0.02 to 0.05) °C avoided warming from a complete switch to HFC-32 in split ACs.

Nigeria Doc 91/49

Nigeria is requesting approval for stage III HPMP at a total cost of US $5,056,222, plus agency support costs of US $353,936 to phase out 17.13 ODP tonnes of HCFC-22 and meet the 67.5% reduction target by 2025. Stage III proposes to phase out the use of HCFC-22 in the RAC manufacturing sector to achieve a 67.5% reduction by 2025.

EIA is concerned that the technology choice of HFC-32 in both the commercial refrigeration and residential AC manufacturing sector conversions. Although R-290 is chosen for commercial refrigeration equipment with small charges (fridges, freezes, ice makers), HFC-32 will be used for equipment with larger charges. Similarly, in residential AC manufacturing, Doc 91/49 states that HFC-32 is selected for the conversion at Sacral Industries, while R-290 or HFC-32 is proposed for Somotex Nigeria Ltd. EIA notes that Table 8 in Doc 91/49 suggests that Somotex Nigeria Ltd has chosen HFC-32 while Sacral Industries is proposing R-290 or HFC-32. Given the large difference in the sizes of these ventures, a clarification on this would be helpful.

Either way, it is disappointing to see the continued use of MLF funds to support the uptake of HFCs that will require another transition when there are low-GWP sustainable options available. HFC-32 has a GWP of 2,690 over a 20-year period.11 We strongly urge the MLF Secretariat and Implementing Agencies to refrain from describing HFC-32 as a low-GWP refrigerant, given this is clearly not the case.

The difference in climate impact between R-290 and HFC-32 is seen clearly in the Secretariat’s estimate of the climate impact of the proposed conversions. If the total consumption of 295.02 tonnes is replaced by R-290, the climate impact will be 1.93 million tonnes CO2-eq, almost 50% more than the 1.3 million tonnes CO2-eq impact if replaced by HFC-32.

Ecuador (Doc 91/41)

The project proposes to convert domestic and commercial refrigerators at Induglob from HFC- 134a to R-600a and R-290, at a cost of US $1,283,977, eliminating annual consumption of 10.42 tonnes of HFC-134a. This represents Ecuador’s entire HFC-134a consumption in the manufacture of domestic and stand-alone commercial refrigerators.

EIA supports this project, which will cost-effectively phase out 14,901 CO2-eq tonnes of HFC-134a in manufacturing, with additional energy efficiency benefits.

The Niger (Doc 91/48)

The Niger is requesting funding of Stage 1 of their Kigali Implementation Plan (KIP), at a cost of $746,805, aiming to achieve a 10% reduction from its HFC baseline by 2029. Activities include technical assistance to commercial refrigeration SMEs, training of refrigeration technicians on the use of R-600a, awareness activities and training on commercial AC technologies, development of good practices for the MAC sector, refrigerant management and regulatory framework components. In addition, early activities to avoid uncontrolled growth of HFCs, such as a programme to support the supply of R-600a domestic fridges to health providers and R-290 residential AC units to ministries and hotels are including.

EIA supports this proposal, and encourages further serious consideration of activities to reduce the use of HFC-404A during the course of implementation of Stage 1 in the refrigeration servicing sector, given it represents 64% of total HFC consumption in CO2-equivalent terms.

Maldives (Doc 91/44)

The Maldives is requesting funding for additional activities to maintain energy efficiency in the refrigeration servicing sector, in line with decision 89/6. The activities will enhance the implementation of an existing energy efficiency labelling programme, which will enable Maldives to promote energy-efficient and low-GWP alternatives in RAC equipment and support strengthening of the country’s MEPS. EIA strongly supports this proposal.

Morocco (Doc 91/47)

Morocco’s Stage 1 HPMP phased out pure HCFC-141b in the foam and servicing sector from 2015, however the use of HCFC-141b contained in imported pre-blended polyols has increased from the starting point due to economic development. In 2021, the Government of Morocco reported the use of 104.3 tonnes of HCFC-141b contained in the imported pre-blended polyols in the PU rigid foam sector.

The largest enterprise, MPI, has selected cyclopentane as the alternative technology, will blend the polyols and cyclopentane in its own facility and co-finance part of the incremental capital costs (ICCs). The remaining enterprises selected HFOs (HFO-1336mzz or HFO-1233zd). According to Doc 91/47, it was subsequently agreed that the alternative technology for the conversion of the three small enterprises would be decided at a later date.

Given the well documented issues with HFO availability and prices,12 concerns over environmental impacts (both PFAS related and greenhouse gas emissions from their industrial production) as well as the much lower cost efficiency ($21.92/kg for HFOs versus $8.58/kg for cyclopentane), EIA does not support the proposed HFO technology choice of the three enterprises with low consumption.

Agenda item 10: Institutional Strengthening Projects, including funding levels (Doc 91/60)

Discussions at the 89th meeting recognised the need to consider increased funding levels for institutional strengthening (IS) projects in light of the significant new responsibilities required of NOUs to ratify and initiate implementation of the Kigali Amendment. The Secretariat has presented a revised reporting format and standardized performance indicators for IS projects in the current document, providing a strong basis to move forward with a decision at this meeting to increase funding levels.

EIA supports a significant increase in the level of support provided to NOUs in order to ensure sufficient capacity and staffing to implement new responsibilities. Given the Secretariat’s observation that, “Experience with the CFC and HCFC phase-out has shown that some of the most challenging activities associated with supporting compliance at the country level take place in the years immediately prior to the date of the first control measure for the substances concerned”, this should take effect immediately to ensure adequate support is available in advance of the 2024 freeze in consumption for Group 1 countries.

Additionally, EIA urges consideration of higher proportional increases to A5 Parties that are low volume consuming (LVC) countries. Given the very low level of support for some Parties – some 61 countries are funded at the minimum level of US$42,500 per year – a percentage increase in funding as has occurred with previous increases, is effectively a very small increase in real terms for these countries.

EIA does not agree that Article 5 countries with HCFC-22 production facilities will require additional IS support to develop and implement policy and regulations to control the emissions of HFC-23 by-product and ensure reporting, given the high levels of historical financial support to mitigate HFC-23 through the Clean Development Mechanism of the UNFCCC and new projects under the MLF.


Agenda item 11(b): Matters Related to the Kigali Amendment – Energy Efficiency

Criteria for pilot projects to maintain and/or enhance energy efficiency of replacement technologies and equipment in the context of the HFC phase-down (Doc 91/63)

Doc 91/63 identifies the wide range of activities that can contribute to enhanced energy efficiency, including better components, broader interventions at design, manufacture, installation and operational levels (such as doors on commercial refrigeration units), energy performance standards, improved installation and maintenance, and market/policy measures to create demand for efficient technologies. It also highlights the importance of sustained institutional coordination of NOUs with energy efficiency authorities, including standards bodies.

EIA agrees broadly with the suggested objectives of the pilot projects, namely to:

(a) Understand the benefits and risks in both the manufacturing and servicing sectors as well as the costs of relevant energy efficiency related interventions;

(b) Understand how the introduction of regulatory and policy measures would support adoption and market acceptance of energy efficient alternatives to high-GWP refrigerants;

(c) Identify challenges and opportunities related to institutional coordination with other stakeholders, including capacity of NOUs; and

(d) Identifying challenges and opportunities related to monitoring performance of energy efficient technologies/equipment.

Based on these objectives, the Secretariat has recommended a set of qualifying and evaluation criteria for pilot project proposals. EIA has the following comments:

Decision XXVIII/2 states that manufacturing projects and servicing activities that are transitioning or supporting the transition to “low- and zero-GWP alternatives to HCFCs and HFCs” should be eligible for energy efficiency funding. A generally accepted definition of low- GWP is <150, however in the context of the climate crisis and mounting concerns over the climate and environmental impact of HFOs, EIA urges ExCom to limit pilot projects and energy efficiency to truly low (GWP<5) or zero-GWP HFC-free technologies.

Operational framework to further elaborate on energy efficiency institutional aspects and projects and activities (Doc 91/64)

It is critical that progress is made on this issue at the 91st ExCom meeting. Six years have passed since the Parties to the Montreal Protocol agreed in Kigali to: request the Executive Committee to develop cost guidance associated with maintaining and/or enhancing the energy efficiency of low-GWP or zero-GWP replacement technologies and equipment, when phasing down hydrofluorocarbons.

EIA is convinced that energy efficiency related projects can be considered within existing processes of the MLF and strongly supports option 1, whereby activities are funded under regular contribution to the MLF. While energy efficiency is not a compliance obligation, the decision to include the maintenance and enhancement of energy efficiency of low-GWP and zero-GWP technologies was taken by consensus in the context of the Kigali Amendment agreement. However, this should not preclude interested donor countries from taking advantage of the systems and processes in place within the ExCom to support with additional funding. Nor should it preclude collaboration with and co-financing from other financial institutions.


Agenda item 11(c): Criteria for a funding window for an inventory of banks of used or unwanted substances and a plan for the collection, transport, and disposal of such substances (Doc 91/66)

The Secretariat’s document provides a useful basis for the ExCom to reach a decision at this meeting to create a funding window to support countries in conducting inventories and developing national plans for managing and disposing of banks of ODS and HFCs. EIA agrees with the approach of utilizing HCFC consumption baselines as a proxy to determine bands of funding levels. However, Parties may wish to discuss and further inquire as to the basis for the funding levels themselves presented in the document, which would provide only USD $40,000 up to $90,000 per country, depending on baseline HCFC consumption levels, for such activities to develop both the inventory and the national plan. Given the complexity and number of elements and extensive stakeholder consultations involved in developing such inventories and national plans as outlined in the Secretariat’s document, the ExCom should consider higher levels of funding to ensure comprehensive inventories and plans are implemented.


Agenda item 14: Overview of current monitoring, verification and enforceable licensing and quota systems developed with support of the Multilateral Fund (Doc 91/69 and 89/3)

EIA appreciates the extensive work carried out by the Secretariat on this important agenda item. As previously noted in our briefings to ExCom meetings, many of the recommendations and observations are relevant to both A5 and non-A5 Parties and should initially be considered within a broader review of the institutions and processes of the Montreal Protocol.

This review will begin in earnest in 2023, with a workshop to be held back-to-back with OEWG45, as agreed in Decision XXXIV/8 (Strengthening Montreal Protocol institutions, including for combatting illegal trade).

While discussions advance at the MOP level, parallel discussions at the ExCom concerning specific aspects related to strengthening and clarifying the monitoring and verification of existing and future projects undertaken with support from the MLF could yield useful results and feed into the MOP discussions.

EIA supports the recommendation from the Secretariat to prepare an update to document 89/3 for a future ExCom meeting, potentially extended to the 94th meeting which could then take fully into account the outcome of the workshop and any subsequent decision by the 36th MOP.

EIA also recommends that the Secretariat be encouraged to share all relevant information with the Ozone Secretariat to assist in the preparation of the workshop and ensure the issues related to support of the Multilateral Fund and the views of the ExCom are substantively addressed in that process.



1 Western, L. M., Redington, A. L., Manning, A. J., Trudinger, C. M., Hu, L., Henne, S., Fang, X., Kuijpers, L. J. M., Theodoridi, C., Godwin, D. S., Arduini, J., Dunse, B., Engel, A., Fraser, P. J., Harth, C. M., Krummel, P. B., Maione, M., Mühle, J., O’Doherty, S., Park, H., Park, S., Reimann, S., Salameh, P. K., Say, D., Schmidt, R., Schuck, T., Siso, C., Stanley, K. M., Vimont, I., Vollmer, M. K., Young, D., Prinn, R. G., Weiss, R. F., Montzka, S. A., and Rigby, M.: A renewed rise in global HCFC-141b emissions between 2017–2021, Atmos. Chem. Phys., 22, 9601–9616, https://doi.org/10.5194/acp-22-9601-2022, 2022. Available here

2 See EIA (2018). Blowing it: Illegal Production and Use of Banned CFC-11 in China’s Foam Blowing Industry. Available here.

3 EIA (2018), Blowing it: Illegal Production and Use of Banned CFC-11 in China’s Foam Blowing Industry. See p10-11 available here

4 Lunt, M. & Park, Sangho & Li, Shihong & Henne, Stephan & Manning, A. & Ganesan, A. & Simpson, Isobel & Blake, D. & Liang, Q. & O’Doherty, Simon & Harth, C. & Mühle, Jens & Salameh, P. & Weiss, Ray & Krummel, P. & Fraser, Paul & Prinn, Ronald & Reimann, S. & Rigby, Matt. (2018). Continued Emissions of the Ozone-Depleting Substance Carbon Tetrachloride From Eastern Asia. Geophysical Research Letters. 45. 10.1029/2018GL079500. Available here

5 Park, S., Western, L.M., Saito, T. Et al. A decline in emissions of CFC-11 and related chemicals from eastern China. Nature590, 433-437 (2021). https://doi.org.10.1038.s41586-021-03277-w Available here

6 RTOC (February 2011). 2010 Report of the Refrigeration, Air Conditioning and Heat Pumps Technical Options Committee. 2010 Assessment Report. UNEP. Available here

7 20-year GWP from IPCC AR6. Available here

8 Alex Hillbrand et al 2022 Environ. Res. Lett. 17 074019

9 European Commission (2020). The availability of refrigerants for new split air conditioning systems that can replace fluorinated greenhouse gases or result in a lower climate impact. Available here.

10 EESL India (2021) Market Assessment for Super-Efficient Air-Conditioners Available here.

11 20-year GWP from IPCC AR6. Available here

12 MCTOC Progress Report p49, 20202 TEAP Progress Report – Volume 1. Available here.