Surge in atmospheric CFC-11 levels points to illegal Chinese use as blowing agent

In May 2018 scientists revealed that atmospheric levels of CFC-11, a potent ozone depleting substance banned since 2010, were significantly higher than expected, leading them to conclude that new illegal production and use of CFC-11 was occurring in East Asia. Their findings were initially reported in the publication Nature.

A subsequent field study carried out by UK-based NGO Environmental Investigation Agency (EIA) has reportedly “demonstrated conclusively that the use of CFC-11 in China’s rigid polyurethane (PU) foam insulation sector, in particular in the building and construction subsector, is widespread and pervasive.”  CFC-11 is used as a foam blowing agent for the manufacture of molded foam panels and spray foam used for insulation purposes.

EIA has gathered evidence from eighteen companies in ten provinces that they use CFC-11. Detailed discussions with company executives make clear that these are not isolated incidents but instead represent common practice across the industry.

EIA’s calculations show that emission estimates associated with the level of use reported by these companies can explain the majority of emissions identified in the atmospheric study. In addition there is significant potential for illegal international trade in CFC-11 containing pre-formulated polyols for foam manufacturing in other countries.

The scale of the compliance issue is such that it cannot be treated as a series of isolated incidents according to EIA, who has urged the Government of China and the Parties to the Montreal Protocol to acknowledge the scale of this environmental crime and take immediate action to investigate further, implement legislative reform and ensure effective intelligence-led enforcement.

Traders and buyers of CFC-11 in China estimated that it is used in the majority of China’s rigid PU foam sector. A total of 18 polyol blend producers out of 21 that EIA sources spoke to confirmed using CFC-11. One, Dacheng Shengshi Tianchuang Chemical Co., even displayed a signboard declaring it was  a “farming plant” in order to disguise its CFC-112 usage.

Several companies interviewed by EIA acknowledged the illegality of their actions and explained that it was used because it was cheaper, typically by about $150/tonne, and made more effective foams. Several companies also described exporting the preblended polyol mixtures containing CFC-11.

One seller of CFC-11 gas, Yantai Jinpei International Trade Co., Ltd estimated that 70 per cent of domestic blowing agent usage was CFC-11. Further, one factory confirmed keeping a stockpile of the legal alternative to CFC-11, HCFC-141b, as “just for show” when inspections occurred.

The system houses were reluctant to disclose the exact location of the illegal CFC-11 production, but one referred to “guerilla tactics” employed by such producers who change locations frequently in order to avoid government inspections. Another systems house, Dacheng Aoyang Chemical, estimated that 99 per cent of their products used CFC-11, produced by unlicensed factories with “shady and hidden operations” based in Inner Mongolia. When questioned if CFC-11 was used nationwide the representative estimated that the total HCFC-141b volume in the market was one-tenth of CFC-11, and that only large prominent companies like appliance manufacturer Haier would use HCFC-141b (and even then, they did not oversee or audit all manufacturing).

With respect to exporting polyol formulations containing CFC-11 blowing agent, the Dacheng Aoyang Chemical representative stated “Do you know how we deal with strict export custom inspection? We get those big lumber core boards, build up a container for four barrels of [formulated polyol] and seal it carefully. Nobody at customs would open it up. Seriously, how can anyone do inspections on that? We also spread putty on those containers to make it really messy. No one cares to take a look.”

China has a growing PU foam market, estimated to represent about 34 per cent of the global market in 2011 and likely a higher proportion now given that the industry is growing faster than the global average. The rigid foam industry, comprising about 3,500 small and medium-size enterprises, is concentrated in the provinces of Shandong, Henan, Hebei and Tianjin where the majority of systems houses and foam processor are located. Nearly 57 per cent of total PU blowing agent used is pre-blended with the polyol.