Transcript Illegal Trade in ODS

Risk Assessment of Illegal
Trade in HCFCs
Introduction to EIA
Profile:
• Established in 1984
• Offices in London and Washington DC
• Specialise in exposing environmental crime
- illegal logging and trade
- illegal trade in endangered species
- smuggling of controlled chemicals
EIA/UNEP Risk Assessment
• Aim: collation of cases and smuggling
methods used, regulatory issues, future risk,
recommendations to minimise risk
• Timeline: June to August
• Output: 4 page briefing for NoUs and
customs
Comparison with CFC smuggling
Similar Conditions
• Different phase-out schedules
• Production/consumption controls in key
non-Article 5 markets (EU/US), coupled
with on-going demand (servicing etc.)
• Rapid production growth in Article 5
countries
• Low price – R22 = $2.5kg
Better prepared this time?
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Licensing systems
iPIC
UNEP Compliance Assistance Programmes
Customs training
Industry awareness
Risk Indicators
• Rapidly rising production in Art. 5. Overtook non-Article 5
in 2004. China: 1997 produced 1,500 ODP tonnes. 2007 =
27,500.
• Data discrepancies: 2008 Singapore to India (40 tonnes vs.
420 tonnes)
• Demand: EU 2007 R22 sales around 20,000 tonnes. 2010
industry estimate deficit of 15,000 tonnes, recycled only
15%.
• UK: 2009 70% of firms surveyed has one or more systems
reliant on R22. Compared with previous year sales did not
fall and reclamation did not increase as expected.
• One major supermarket 25% of refrigeration systems =
HCFC
Illegal Trade in HCFCs
Illegal trade in HCFCs already
happening
• 2009: Miami Florida. Kroy Corporation
illegally imported 11 shipments of HCFCs
(30,000 cylinders). Misdeclaration (HFCs)
and double-layering. Parallels with CFCs
• Europe – notorious CFC smuggler offering
“recycled” HCFCs for sale from China
• Seizures in India, and blends containing
HCFCs in Thailand and Philippines
Current Trade
• One website had 246 sell offers for “R22
refrigerant gas”. 230 from Chinese firms
• Several of the sellers not listed as licensed
to export
• EIA enquiries to Chinese sellers: aggressive
sales, low prices ($2-3 per kg), willing to
supply to EU market despite import ban
Preventing Illegal Trade
• HCFC phase-out plans (quotas, limits on
products containing HCFCs)
• Expansion of iPIC
• Limit export to producers, not agents
• Customs training (smuggling methods,
HFCs)
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