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Investigators find illegal CFC-11 use in China’s polyurethane industry

Concept - Ozone ©Megaloman1ac -

An NGO investigation has uncovered the illegal and widespread use of CFC-11, or trichlorofluoromethane, by Chinese manufacturers for rigid polyurethane foam.

And the use of the substance could be the cause of a recently detected rise in ozone-depleting substances in the atmosphere.

The investigation by the Environmental Investigation Agency (EIA) found use of CFC-11 as a blowing agent in the production of the foam – used predominantly as insulation by the construction industry.

The agents are a key ingredient and help it expand and enhance insulating properties. They can be a liquid or a gas that is dissolved in the precursors and expand to form the foam, once  injected or sprayed.

The EIA, a campaign group specialising in undercover investigations, says there is "significant potential" that pre-mixed polyols, used as a component in foam manufacturing, containing CFC-11 have been traded internationally.

CFC-11 was restricted under the original agreement of the Montreal Protocol on reducing use of ozone-depleting substances in 1987. Production and consumption should have stopped internationally by 2010 under the agreement. Reports indicated that manufacturing and use had done so by 2006.

The investigation was partly prompted by a study published in Nature in May. This showed there had been rapidly increasing levels of atmospheric CFC-11 between 2012 and 2016.

The EIA speculates that much of the increase can be explained by the activities in China. By 2011, the country’s large and growing market in polyurethane foam was already estimated to be a third of the world total.


Undercover EIA investigators contacted 25 polyurethane companies across China. Out of the 21 that responded, 18 from ten different provinces openly admitted the illegal use. Nearly all gave estimates ranging from 70%-100% as the proportion of blowing agents made up of CFC-11.

Several factors seem to have prompted the illegal manufacture, including:

  • lower costs;
  • CFC-11’s greater effectiveness as a blowing agent;
  • the relative simplicity of production; and
  • the need to add flame retardants to CFC-11 alternatives for new fire safety laws.

The report also notes the limited incentives for compliance. Penalties under China’s State Council Order No 573 (Ozone Depleting Substances Management Regulations), in force since June 2010, include confiscation and fines of between $750 and $150,000 depending on volumes, with no scaling up for repeat offences.

Avoiding detection

The dispersed character of production has made regulating the industry particularly challenging for the Chinese authorities. There are an estimated 3,500 small and medium enterprises producing the foam.

The investigation uncovered steps that companies take to avoid discovery. Many said they regularly move facilities, which are often in anonymous factories. Several used sites in Inner Mongolia beyond the reach of Chinese inspectors.

One company admitted it received tip-offs from local inspectors and then halted production and hid workers until the inspection was over.

The findings have been corroborated in interviews with Shandong province officials. Shandong is a centre of illegal production and the authorities raised the difficulties of dealing with illegal CFC-11 production, last year, in an online presentation. In 2015, they announced the closing down of 15 illegal facilities.


The investigation found limited direct evidence of exports, but several companies told investigators they exported by mislabelling polyols containing CFC-11. They also adopted measures, such as sealing containers, to discourage inspection.

The report suggested a likely way would be to trade in the polyols mix, known as component 'A' or 'white agent'. About 60% of polyurethane blowing agent is distributed as part of this mix, which is combined with the isocyanates in component 'B' or 'black agent' to produce the polyurethane foam.

Exports under the HS codes for "other polyethers" and "polyurethanes" could potentially include significant amounts of polyols with CFC-11, according to the report. UN figures show Chinese exports from 2012-16 averaging 413,000 and 128,000 tonnes annually for the two codes respectively.

Exports were mainly to other Asian countries and the Middle East, but included the US and Turkey.

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