Promote the establishment of a full life cycle management system for ozone-depleting substances

China – Fulfilling the Montreal Protocol and its Kigali Amendment

The year 2024 marks the freeze year for China to implement the Kigali Amendment and impose total control on the production and use of hydrofluorocarbons (HFCs). The Ministry of Ecology and Environment, in conjunction with multiple departments, has established a control system. The production quotas for HFCs issued in 2024 and the quotas for domestic use have been significantly reduced compared to the previous year. Meanwhile, strictly implement the management of HFCs import and export licenses to prevent multiple batches of potential illegal trade. Through measures such as improving the legal and policy system, strengthening regulatory and law enforcement efficiency, and enhancing scientific and technological research, positive progress has been made in the compliance control of HFCs, making outstanding contributions to global climate and environmental governance

 

Promote the establishment of a full life cycle management system for ozone-depleting substances

China has launched a national program for fulfilling its commitments to address climate change and protect the ozone layer

Recently, with the approval of The State Council, the Ministry of Ecology and Environment, the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Commerce, and the General Administration of Customs jointly issued the “National Plan for China’s Implementation of the Montreal Protocol on Substances That Deplete the Ozone Layer (2025-2030)” (hereinafter referred to as the “National Plan”).

According to a responsible person from the Department of Atmospheric Environment of the Ministry of Ecology and Environment, the “National Plan” closely follows the requirements of the implementation targets and the current development status of domestic industries. It adheres to the synergy of protecting the ozone layer and responding to climate change, and conducts actions to phase out and reduce ozone-depleting substances (ODS) and hydrofluorocarbons (HFCs) by industry and substance. Promote the establishment of a full life cycle management system covering production, sales, use, maintenance, recycling, regeneration, destruction and import and export.

The National Plan, as a top-level design document, provides policy support and technical guidance for the relevant industries to fulfill their obligations. Zhuang Xiangning, deputy director of the Quality, Safety and Environmental Protection Department of the China Petroleum and Chemical Industry Federation, said, “The National Plan is a guiding document for China to fulfill the Protocol and its amendments over the next six years. It provides fundamental guidance for the future compliance work of the fluorine chemical industry and also points out the direction for the industry’s green and low-carbon transformation.”

Representatives from multiple industry associations stated that they will study and formulate relevant policies, regulations and standards for the control of ozone-depleting substances in the industry.

Clarify the three major performance targets

Since China joined the Montreal Protocol on Substances that Deplete the Ozone Layer (hereinafter referred to as the Protocol) in 1991, it has earnestly fulfilled all international obligations, and has cumulatively phased out approximately 628,000 tons of ODS, accounting for more than half of the total phase-out by developing countries, earning widespread praise from the international community.

In 2021, China announced its decision to accept the Kigali Amendment Protocol and strengthen the control of non-carbon dioxide greenhouse gases such as HFCs. In 2024, the “Decision of The State Council on Amending the Regulations on the Administration of Ozone-Depleting Substances” was officially implemented, stipulating that “the competent department of ecological environment under The State Council, in conjunction with relevant departments of The State Council, shall draft the ‘National Plan for China’s Implementation of the Montreal Protocol on Ozone-Depleting Substances’, and implement it after approval by The State Council.” A responsible person from the Department of Atmospheric Environment of the Ministry of Ecology and Environment stated that formulating and releasing the “National Plan” based on this is an important measure to implement the decisions and plans of the Central Committee of the Communist Party of China and The State Council. It is also an inevitable requirement for comprehensively strengthening the management of ODS and HFCs and achieving the national compliance targets. It is of great significance for promoting the green, low-carbon and high-quality development of related industries.

The controlled substances determined by the National Plan include nine types of substances: perchlorofluorocarbons (CFCs), halon, carbon tetrachloride, methyl chloroform, hydrobromofluorocarbons, bromochloromethane, methyl bromide, hydrochlorofluorocarbons (HCFCs), and HFCs. Among them, the first eight types of substances are ODS that have a destructive effect on the ozone layer, while the ninth type of substances, HFCs, have no destructive effect on the ozone layer and are greenhouse gases with a high global warming potential (GWP).

It is understood that at present, China has completely phased out the production and use of seven types of ODS for controlled purposes, including CFCs, halon, carbon tetrachloride, methyl chloroform, hydrobromofluorocarbons, bromochloromethane and methyl bromide, and is gradually reducing and phasing out HCFCs and HFCs. The National Plan clearly sets out the following compliance goals: First, continuously prohibit the production and use of ODS for controlled purposes that have been phased out, further consolidate the achievements, and ensure sustainable compliance. Second, the production and usage of HCFCs for controlled uses will be reduced by 67.5% and 73.2% of the baseline values respectively in 2025, and by 97.5% of the baseline values in 2030. Thirdly, the production and usage of HFCs for controlled uses will both be reduced by 10% of the baseline values in 2029.

Strict law enforcement, supervision and inspection

To achieve the compliance goals, the National Plan has put forward four major action measures and eleven specific tasks.

Strengthen source control and strictly manage the production and sale of controlled substances. Quota licensing management shall be implemented for production units with controlled uses of controlled substances, those exempted from controlled uses, and production units selling controlled substances for raw material uses. Implement a filing management system for sales units and require them to sell strictly in accordance with the classification of the controlled substances’ uses. Strengthen the management of by-product control materials and stipulate that units with a large quantity of by-products should install automatic monitoring equipment.

Strengthen process control and intensify the management of the use of controlled substances. Quota licensing or filing management shall be implemented for the units using HCFCs and HFCs for controlled purposes, and the time nodes for reduction in each industry shall be clearly defined. Among them, the polyurethane foam industry, the extruded polystyrene foam industry and the industrial cleaning industry will prohibit the use of HCFCs as foaming agents, solvents and cleaning agents as of July 1, 2026. All other industries will completely phase out the use of HCFCs for controlled purposes by 2030. Starting from July 1, 2029, the automotive industry has banned the use of refrigerants with a GWP greater than 150 in the air conditioning systems of newly applied and announced M1-class vehicles. It encourages the research and application of alternative technologies for natural working refrigerants in the automotive, home appliance, industrial and cold chain logistics sectors.

Improve the end-of-pipe treatment and strengthen the management of maintenance, recycling, regeneration and destruction. The maintenance units of refrigeration equipment, refrigeration systems and fire extinguishing systems containing controlled substances, as well as the units engaged in the recovery, regeneration and destruction of controlled substances, shall be subject to filing management. The scope of filing management and the requirements for data submission shall be clearly defined. Improve the operation level of refrigeration maintenance and the recovery and regeneration of refrigerants, and establish a traceability and flow management system for refrigerant regeneration products.

Strengthen the management of imports and exports and prevent and control risks in material trade. Implement quota licensing management for the import and export of controlled substances and standardize the issuance of approval forms for the import and export of controlled substances. Except for special uses such as exempted controlled uses and raw material uses, enterprises are no longer allowed to import HCFCs and controlled substances that have been clearly phased out by the state. Utilize the trade confirmation means in import and export approval to prevent potential illegal trade and enhance the ability to investigate and crack down on illegal trade cases.

To implement the action measures and achieve the national compliance targets, the National Plan clearly states that it is necessary to strengthen mechanism building, improve the compliance management system, accelerate the research and promotion and application of substitutes and alternative technologies, and promote green substitution and energy efficiency improvement in a coordinated manner. Strengthen capacity building, establish an assessment system for performance effectiveness and early warning assessment, strictly enforce law and conduct supervision and inspection, and enhance the capacity of scientific and technological support. Improve the standard and technical specification system, strengthen the capacity building of emission statistics and accounting, actively play the guiding role of finance and banking, and support the green and low-carbon transformation of industries.

Multiple industries have made positive statements

According to the relevant provisions of the Protocol and the Kigali Amendment, China still needs to carry out the elimination and reduction activities of HCFCs and HFCs at present. The production and supply of these two types of substances in China account for more than 80% of the world’s total. As Zhuang Xiangning said, “China is undoubtedly the leading role on the stage of fulfilling the Protocol.” The fluorine chemical industry, as the vanguard in fulfilling its obligations, bears even greater responsibility. With the official release of the “National Plan” and the continuous improvement of related management systems, China’s fluorine chemical industry and related industries are bound to move towards a greener, low-carbon and sustainable direction.

Wang Lei, the secretary-general of the China Household Electrical Appliances Association, believes that the “National Plan” provides clear policy guidance and technical support for China’s home appliance industry to continuously carry out compliance actions and promote the elimination, reduction and substitution of controlled substances.

Chen Shihua, deputy secretary-general of the China Association of Automobile Manufacturers, said that the formulation of policies and regulations and the establishment of a standard system are important institutional guarantees for the automotive industry to achieve the HFCs reduction target. The China Association of Automobile Manufacturers will actively cooperate with government departments to study and formulate relevant policies, regulations and standards for the control of HFCs in the automotive industry, establish and improve the management system for the use, maintenance and recycling of HFCs, and provide policy guarantees for the reduction and replacement of HFCs.

Li Jiang, the president of the China Refrigeration and Air Conditioning Industry Association, said that all sectors of the industry will take the “National Plan” as a guide, actively pay attention to the development trends of domestic and international policies, regulations, standards and technologies, continuously increase investment in research and development, strengthen the construction of an independent innovation system, adhere to the alternative technology route suitable for China’s national conditions, and orderly promote the green transformation and upgrading of the industry.

Meng Qingjun, deputy secretary-general of the China Plastics Processing Industry Association, said that foam enterprises should, in accordance with the requirements of the National Plan, actively make good use of the information management system for ozone-depleting substances, operate legally, resolutely resist and report the production, sale and use of illegal foaming agents, and achieve the goal of completely phasing out HCFC-141b on schedule.

Zhou Xiaomeng, the dean of the School of Safety Science and Engineering at Civil Aviation University of China, believes that technological substitution and regulatory upgrading need to be guaranteed by institutional innovation. The National Plan provides a policy framework for the fire protection industry, but it is still necessary to further refine the supporting rules. Relevant technical standards and norms should be formulated and revised as soon as possible to promote the application of new clean and efficient fire extinguishing technologies in the fire protection industry and develop a dual certification method for environmental protection and efficiency of new fire extinguishing products. In collaboration with industry associations, an action plan for the replacement of HFCs in the fire protection industry was released, clearly defining phased goals and guiding enterprises to transform in an orderly manner. Strengthen policy incentives and provide equipment purchase subsidies to units that adopt environmentally friendly fire extinguishing systems. Carry out demonstration applications of new, efficient and clean fire extinguishing technologies in some areas to form replicable experience models.