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China's Ministry of Ecology and Environment (MEE) has recently issued the National Plan (2025–2030) for China’s Compliance with the Montreal Protocol on Substances that Deplete the Ozone Layer, a comprehensive strategy to reinforce the management of ozone-depleting substances (ODS) and hydrofluorocarbons (HFCs). The plan provides a guiding framework for China’s industries to align with international environmental obligations over the next six years, addressing both ozone layer depletion and climate change.
Background
As a Party to the Montreal Protocol, China has actively fulfilled its obligations to phase out ODS, cumulatively eliminating approximately 628,000 tons of ODS—over half of the global reduction by developing countries. Since the Kigali Amendment entered into force in 2021, HFCs, potent greenhouse gases with no direct ozone-depleting effects, have been added to China’s regulatory scope. The new National Plan aims to strengthen lifecycle management of ODS and HFCs, driving a green transition in key industries such as fluorocarbon chemicals, home appliances, automotive, refrigeration, and firefighting.
Key Regulatory Requirements
1. Nine Controlled Substances
The Plan specifies nine categories of controlled substances listed in the China’s List of Controlled Ozone-Depleting Substances:
CFCs (Chlorofluorocarbons)
Halon
CTC (Carbon Tetrachloride)
Methyl Chloroform
Hydrobromofluorocarbons
Bromochloromethane
Methyl Bromide
HCFCs (Hydrochlorofluorocarbons)
HFCs (Hydrofluorocarbons)
While the first 8 substances deplete the ozone layer, HFCs—though ozone-safe—act as potent synthetic greenhouse gases, with global warming potentials (GWPs) up to tens of thousands times higher than CO₂.
2. Two Usage Categories
Controlled Uses: Applications where the substances remain chemically unchanged and eventually enter the atmosphere, such as refrigerants, foaming agents, solvents, or fire suppressants. These are subject to strict total quantity controls.
Feedstock Uses: Substances used as raw materials in chemical reactions to produce other chemicals. These are exempt from quantity controls.
3. Core Target
Ban on Production/Use: Except for exempted applications, the production and use of 7 phased-out substances (CFCs, Halon, CTC, Methyl Chloroform, Hydrobromofluorocarbons, Bromochloromethane, and Methyl Bromide) in controlled uses shall be prohibited.
Phased Reduction: Gradual cuts to HCFCs and HFCs in controlled uses shall be implemented.
Strategies and Actions
1. Source Control
Production/Sales Management: Implement quota licensing for production and registration for sales.
Byproduct Management: Strengthen oversight of incidental production of controlled substances.
2. Process Control
Home Appliances: From Jan 1, 2026, ban the production of refrigerators and freezers using HFCs as refrigerants.
Foaming: From July 1, 2026, prohibit HCFCs used as foaming agents.
Automobiles: From July 1, 2029, new M1-class vehicles (passenger cars) must avoid refrigerants with GWP >150, promoting natural refrigerants (e.g., CO₂).
3. End-of-Life Management
Enhance oversight of maintenance, recovery, and disposal processes. Establish a traceability system for refrigerants to track their lifecycle.
4. Import/Export Regulations
Enforce quota licensing for imports/exports of controlled substances.
Note: Revised Administration Measures for the Import and Export of Ozone-Depleting Substances (effective May 1, 2025) now apply to the listed substances. Enterprises must submit annual import/export quota applications by October 31 each year, including applications, annual plans, and business licenses for first-time applicants.
For further details, refer to the full text of the National Plan.
