Risk Assessment of Illegal Risk Assessment of Illegal Trade in HCFCs 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?

• 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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