Countries Discuss the HFC-23 Blind Spot and More at 36th Montreal Protocol Meeting

The Montreal Protocol-adopted 36 years ago and ratified by every country on the planet-continues to demonstrate that countries can effectively cooperate on protecting the ozone layer and the climate, even in these fractious times.

From October 28 to November 1, 2024, nations gathered in Bangkok, Thailand, for the 36th Meeting of the Parties to the Montreal Protocol (MOP)to decide on a host of issues ranging from stopping refrigerant leakage and improving energy efficiency to curbing emissions of the super-pollutant HFC-23 and improving atmospheric monitoring. By week's end, the parties adopted 23 decisions to advance protection of the ozone layer and climate. Below, we summarize some of the biggest decisions made on key issues.

The HFC-23 emissions gap

As we highlighted in July, a major emerging concern is the unexpected discrepancy between reported emission data and atmospheric measurements of HFC-23, which is the most climate-damaging HFC ever produced, with an atmospheric lifetime of 228 years and a global warming potential (GWP) of 14,800. Curbing emissions of this super pollutant is crucial given that in 2022, a report found that HFC-23 alone was responsible for nearly 15 percent of the total warming impact of all HFCs in 2020. Thus, the unexpected increase in emissions of this one chemical could potentially undercut the emissions reductions being achieved under the global HFC phasedown.

In short, the atmospheric measurements show that there is far more HFC-23 being emitted than countries are reporting. The emissions gap emerged after 2014 and continued to grow before peaking in 2019, where the difference in atmospherically derived and reported emissions was 15,000 metric tons of HFC-23 (equivalent to 222 million metric tons of carbon dioxide, calculated using a GWP of 14,800). The atmospherically derived emissions began to decline after this issue was first brought to light in 2020.

Recent studies indicate that the eastern and northern regions of China could account for between 20 to 50 percent of the global emissions gap. HFC-23 emissions are closely tied to the issue of feedstock use given that HFC-23 is a byproduct of HCFC-22 production, and China accounts for 68 percent of global HCFC production.

Under the Montreal Protocol, ozone-depleting feedstocks are exempt from controls based on the premise that the feedstock chemical is entirely consumed in the manufacture of other chemicals and thus not emitted. However, HCFC-22 production plants release HFC-23 as a byproduct and, given the salience of this issue, the parties of the agreement decided to continue taking steps to curb emissions from feedstock production and use. NRDC applauds this decision and has been advocating for tighter controls on feedstock uses under the Montreal Protocol for decades now.

The parties also adopted a decision that encourages "relevant" countries to investigate potential reasons for the underreporting of HFC-23 emissions and invites them to undertake in the atmospheric monitoring of HFC-23 and to conduct research on potential sources of emissions. This is a significant step in the right direction. In parallel, countries decided to update a few data-reporting forms for HFC-23 to provide additional clarity on how to report HFC-23 produced in one year and destroyed in another.

Trust but verify: Emissions gaps underscore the need for additional atmospheric monitoring

The HFC-23 emissions gap has further underscored the need to enhance regional and global atmospheric monitoring of HFCs and other ozone-depleting chemicals. Several regions around the world have zero atmospheric monitoring stations, making it difficult to verify that countries are abiding by their commitments to the Montreal Protocol. The parties decided to allocate $400,000 for the first round of site evaluations for new monitoring stations. Given the discrepancies on HFC-23 emissions described above-and a similar discrepancy that occurred for CFC-11 in the past-additional monitoring stations are critical for enforcement efforts and for preserving the successes of the Montreal Protocol.

Lifecycle refrigerant management

Historically, the Montreal Protocol has focused on phasing down the supply (production and consumption) of gases that deplete the ozone layer or climate. It was assumed that chemicals used as refrigerants and in other applications would eventually leak into the atmosphere. With the increasing urgency of climate change, countries are recognizing the importance of reducing these emissions from the "bank" of chemicals already in use. This has led to heightened focus on managing refrigerants throughout their lifecycle. Hence the term lifecycle refrigerant management, or LRM.

This year, the Ozone Secretariat organized a pre-MOP workshop for a focused discussion on LRM, during which countries could learn more about the topic and flag any concerns. Following the workshop, it was encouraging to see additional progress-and enthusiasm-around the topic as a decision was adopted that will help facilitate LRM information and resource sharing across parties.

In addition to the workshop, NRDC and the Environmental Investigation Agency (EIA) organized a side event with a moderated panel discussion among experts from the United States, India, China, Australia, and the Climate Ozone Protection Alliance (COPA). Experts discussed strengthening workforce development in the context of successfully implementing LRM, with a particular emphasis on the need for a well-trained and -equipped workforce. In addition to offering perspectives from their respective country's approaches to LRM, panelists discussed the importance of empowering the workforce and recognizing that the work done by technicians on the ground is a climate job carried out by specialized knowledge workers. The uplifting of the workforce and its contributions are essential for unlocking the climate and ozone benefits of LRM.

Overall, the 36th MOP resulted in the adoption of several important decisions that will continue to advance progress in phasing down HFCs. Parties will return to Bangkok in July 2025 for the next meeting of the Open-ended Working Group to set a new agenda for the 37th meeting. NRDC is encouraged by the important steps taken at MOP, and we look forward to seeing further cooperation next year that will continue to show that the Montreal Protocol is the most successful environmental treaty to date.

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