1. Ozone Depleting Substance Consumption in Taiwan in 2014

    Adhering to the Montreal Protocol, Taiwan’s government has been reporting ODS consumption data to the Ozone Secretariat of UNEP since 1992. According to Taiwan’s ODS consumption record, CFCs consumption has been reduced to zero and HCFCs consumption has been decreasing since 1996. The HCFCs consumption baseline was counted at 638.156 ODP tonnes in 1996 and was reduced to 383 ODP tonnes in 2004. As Taiwan abides by the Montreal Protocol's control measures, the HCFCs consumption in 2014 was reduced to 158.483 ODP tonnes, accounting for 25% of the HCFCs consumption baseline. One of the reasons that Taiwan is able to fulfill its own reduction commitments based on the Montreal Protocol is that the Taiwan EPA has executed the HCFCs regulations and suspended specific uses step by step, including the ban of using HCFC-141b on electronics cleaning and PU foam blowing, the use of HCFC-22 as refrigerants for producing window-mounted air conditioners as well as the split type air conditioners below 7.1 kW.

    ODS producers in Taiwan ceased the production of CFCs in 1996 and HCFCs in 2006. In 2014, the imported HCFCs consisted of 158.372 ODP tonnes of HCFC-22, 0.13 ODP tonnes of HCFC-142b, 5.06 ODP tonnes of HCFC-123, 0.022 ODP tonnes of HCFC-124 and 0.394 ODP tonnes of HCFC-225. Exported HCFCs consisted of 0.495 ODP tonnes of HCFC-22.

    Methyl bromide has been allowed to be imported and used only for QPS purposes in Taiwan since 1999. In 2014, the amount of imported methyl bromide was 19 ODP tonnes. The decrease in methyl bromide importation was due to the EPA’s implementation of the quota allocation control for methyl bromide and promotion of alternatives effectively together with the Taiwan Council of Agriculture, Executive Yuan (COA).

    Starting from 2016, the EPA will begin baning the use of HCFC-22 as a refrigerant for new refrigeration units and air conditioners.

     

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    Figure 1. HCFCs consumption in Taiwan

     

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    Figure 2. Methyl Bromide importation in Taiwan

     


  2. Analysis for HCFCs Use in Taiwan 2014

    In 2014, the Taiwan EPA allocated HCFCs quota for 56 companies, of which 46 were industrial users, and 10 were suppliers. The users are companies that use HCFCs for equipment manufacturing and maintenance, and suppliers are companies that import or manufacture HCFCs for supplying the users or other dealers. The number of users is decreasing annually as more and more users follow the regulations to stop using HCFCs. In the meantime, with the decreasing amount of annual allocation, the suppliers are still striving to be qualified to receive HCFCs in order to satisfy the market demand. The numbers of companies in recent years are shown in Figure 1.

     

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    Figure 1. The growth and decline of HCFC allocated companies in Taiwan

     

    According to the HCFCs Management Regulations, the users should report their use amount, import and purchase amounts every season (before the end of January, April, July and October). The analysis of the 2014 declarations from the users shows that the total HCFCs used was 66,883 ODP kg which is about 4,227 ODP kg less than in 2013. The growth and decline of HCFC use in recent years are shown in Figure 2. The amount in refrigerant applications comprises the highest percentage at approximately 82.4% (55,141 ODP kg). The second was for applications in foam blowing at 17.6% (11,742 ODP kg). Most of the used HCFCs is HCFC-22, and the minor one is HCFC-123 and blended refrigerant R408A (R-22/R-143a/R-125, 47/46/7 % weight), as shown in Figure 3. However, few companies directly purchase AK-225 from the suppliers for cleaning purposes. In 2014, approximately 300 ODP kg AK-225 were used. The amount used in foam blowing has decreased since the EPA started to control PU foam blowing in 2004. As of 2014, only two companies were still using HCFC-22 in PS foam blowing.

     

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    Figure 2. The growth and decline of HCFC use in Taiwan

     

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    Figure 3. 2014 HCFC application distributions of allocated companies

     

    According to the declared data, refrigerants for repair and maintenance amounted to 42,883 ODP kg (77.8%); for charging new products (equipment) it was 10,692 ODP kg (comprising 19.4% of the total refrigerant use); and for newly constructed facilities it was 1,566 ODP kg (2.8%). Among the refrigerants for new products, central air conditioner production and new facility construction comprise the highest percentage, at approximately 12.61% of total used HCFCs. The second highest was for packaged air conditioners at 3.9%. The details are shown in Table 1.

     

    Table 1. The distribution of HCFC refrigerants use in 2014

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    In 2014, refrigerants for repair and maintenance amounted to 42,883 ODP kg, 372 ODP kg less than in 2013. The distribution of HCFC refrigerants for repair and maintenance is shown in Figure 4. Refrigeration in transport (vehicles and boats) comprises the most, mainly because fishing boats require more refrigerant to refill their equipment due to long working time out at sea as well as to keep for reserve. Another issue is the central air conditioning in refrigerated display cabinets. They often need more refill as maintenance due to the difficulties of leakage control. For such equipment that needs more refill amount, a well-developed and easy-to-follow maintenance procedure and training should be able to gradually reduce the leaking and demand for refilling.

     

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    Figure 4. The growth and decline of HCFC refrigerants for repair and maintenance


  3. 2016 Allocations for HCFCs Quotas and Methyl Bromide Permits in QPS Application

    Taiwan has followed the Montreal Protocol to phase out the controlled chemicals since 1989. To date, only some HCFCs and methyl bromide are allowed for some specific applications in Taiwan under permission of the EPA on the basis of the“Regulations for Consumption Management of HCFCs” (HCFC regulations) and the "Regulations for Management of Methyl Bromide"..

    According to the HCFC regulations, the limited allocations for HCFCs each year from 2015-2019 is set at 63,816 ODP kilograms, which is 10% of the national consumption baseline (638,156 ODP kg), the same as the mandate specified in the Montreal Protocol. The users and importers of HCFCs should report their actual amount used or imported every season (by the end of January, April, July and October), and the quota will be calculated based on their actual amount used, reported and audited using the principles approved by the board members. In 2016, the EPA reserved 5% of the annual limited allocation (3.191 ODP kg) for emergencies, then allocated HCFCs to the users first according to the calculated results and distributed the rest permitting amount to the importers. The total HCFCs quota of 2016 was estimated to be 60,624.8 ODP kg, in which the users accounted for 60% and the suppliers accounted for 40%. The amount of the first half year (30,934.5 ODP kg) was allocated to 44 users and 10 suppliers on October 30, 2015. The allocation amounts in recent years are shown in Figure 1.

     

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    Notice: the quota in 2016 is estimated. The actual allocation amount will be calculated by the end of April when the allocation for the second half year is finished.

    Figure 1. Allocation amount of HCFCs in recent years

     

    According to the HCFC regulations, the use of HCFCs in foam blowing and HCFC-22 refrigerant charging for new products and facilities are banned starting from January 1, 2016. Using HCFC-141b for cleaning purposes is not allowed either. The EPA once again calls all the users and suppliers of HCFCs not to charge HCFC-22 in any equipment except refilling the existing equipment when doing maintenance. Whoever violates the regulations will be punished by fines of at least 100,000 NTD and may be disqualified for HCFCs allocation according to the circumstances. Furthermore, according to Article XIII, the users shall not resell or be engaged in any HCFCs distribution business. In addition to fines for violators, the EPA can also cancel its allocation qualifications.

    On the other hand, the consumption amount of methyl bromide in Taiwan has been reduced to zero except for quarantine and pre-shipment (QPS) purposes according to the norms of the Montreal Protocol. At present, most countries can still produce and import methyl bromide for QPS purposes except the members of the EU which stopped the use of methyl bromide for QPS on March 18, 2010.

    Methyl bromide importers and users in Taiwan for QPS purposes shall apply with the EPA for permits for the second half of each year by the end of February of that year, and provide the estimated amount needed and related documents. The methyl bromide importers and users for QPS purposes applied with the EPA for permits for the first half of 2016 in August, 2015 with their estimated amount needed and related documents. The EPA convened with experts on November 24, 2015 to examine the permit applications for methyl bromide for the first half of 2016 from users and importers. The sale and purchase documents from importers and users, amounts of methyl bromide used and stock status, packing list, fumigation certificates and reports, and export data were closely reviewed and verified. The EPA subsequently calculated and approved the quota allocation for methyl bromide in QPS applications, including 20,500.0 kg of 100% w/t and 5,978.5 kg of 98% w/t methyl bromide, which is 25,978.5 kg in total, for the first half of 2016 for those applicants. Figure 2 shows the number of permits for methyl bromide in QPS applications in Taiwan over the years.

    In order to make methyl bromide usage declaration clearer, the EPA called on all importers and users to truthfully fill out "The Table of Methyl Bromide Use Record" every month. The contact details of related clients listed in the table therefore can be reviewed by the EPA at the next declaration and permit application. In addition, workers should pay attention to safety when fumigating and opening the containers.

     

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    Figure 2. Historical permitted allocations for methyl bromide in QPS use


  4. Notification of Amendment in Regulations of Management for Montreal Protocol Controlled Substances

    The Managing Directions for Montreal Protocol Controlled Substances was announced in 1989 by Taiwan’s Ministry of Economic Affairs (MOEA), setting the control measures for chlorofluorocarbons (CFCs). The directions have been amended several times to include more controlled substances including hydrochlorofluorocarbons (HCFCs), carbon tetrachloride (CCl4), Halon, etc.

    In 2003, the Air Pollution Control Act announced that the substances controlled by the Montreal Protocol including CFCs, HCFCs, CCl4, Halon, methyl bromide, etc. are specified as air pollutants and authorized the Environmental Protection Administration (EPA), Executive Yuan to prohibit and restrict air pollutants that are controlled by international environmental conventions according to Article 30. Accordingly, the EPA announced the “Regulations of the Management for Montreal Protocol Controlled Substances”, the “Regulations of the Consumption Management for HCFCs” and the “Regulations of the Management for Methyl Bromide” in order to integrate the management and control of the ozone depleting substances (ODS).

    The “Regulations of Management for Montreal Protocol Controlled Substances” was officially announced by the EPA in 2007, and the EPA handles the permitting applications for import and export of the controlled substances accordingly. Among the above, the import and export Halon fire distinguish facilities have been banned for import and export. However, the development of alternatives for civil aircraft safety particularly is limited. Hence, there is still the need to use Halon fire distinguishers in accordance with ICAO (International civil aviation organization) and the aviation norms of Taiwan, the US and the EU.

    According to the Taiwan EPA’s regulations, civil aviation companies are required to prepare relevant documents to apply for permission from the EPA before proceeding with the regular import procedures from the Industry Competent Authority and International Trade Administration as well as Customs. In order to simplify the import procedures for the industries, the EPA commenced to amend the “Regulations of Management for Montreal Protocol Controlled Substances”. After a long communication with the industries and other government agencies, the EPA officially announced the Notification of Amendment in Regulations of Montreal Protocol Controlled Substances on January 31, 2016.

    In the amended regulations, it is stated in Article 5 that Halon used for fire distinguishing in military or civilian aviation can be imported with permission only from industry competent authority, i.e. Civil Aviation Authority, the same as importing other aviation equipment. Noteworthy, the amended procedures are only applicable for the import of aviation safety purpose. Import and export of Halon agents for other uses are still required to apply for permission from the EPA as previously.

    In order to better clarify the definition in the regulations such as controlled substances, production and consumption as well as original refrigerant, the amended regulations also clearly states that the controlled ozone-depleting substances (ODS) covers the original, recovered, reused, and reclaim compounds as well as mixtures with ODS concentration more that 0.1%. In addition, the products with controlled substances inside do not include the storing containers for transport, packaging and sales.

     

    Reference:General information on Article 2, Article 5, Article 21of the Regulations for Management of Montreal Protocol Controlled Substances, available at

    http://enews.epa.gov.tw/enews/enews_ftp/105/0130/141501/1050130蒙特婁議定書列管化學物質管理辦法修正條文總說明及對照表.pdf (Chinese)