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China Strengthens Lifecycle Management of Ozone‑Depleting Substances and HFCs

IGSD / 09 February 2026

On 9 February 2026, the China Ministry of Ecology and Environment (MEE) issued the Circular on Further Strengthening the Management of Ozone-Depleting Substances (ODSs) and Hydrofluorocarbons (HFCs), which takes effect on 1 March 2026. The Circular covers the full lifecycle management of ODSs and HFCs, including production (including by‑production), sales, consumption, servicing, end‑of‑life recovery, reclamation, and disposal. Overall, it serves as an important government document supporting the implementation of the Regulation on the Administration of ODSs, related to China’s obligations as a Party to the Montreal Protocol on Substances that Deplete the Ozone Layer and its Kigali Amendment. (IGSD’s English reference translation of the Regulation on the Administration of ODSs is available here.) 

Key provisions in the Circular include:

  • Production quota licensing: Entities producing controlled substances for controlled consumption and feedstock shall submit an application by 31 Oct. each year for the quota for the following year.
  • Sales record‑filing: Sellers of controlled substances (including polyol blends and blended refrigerants) shall file a record with the municipal-level ecology and environment authority in the city where they are located. For renewals, the sales record shall be filed between Dec. 1 and Jan. 31 of the following year.
  •  Consumption quota-licensing or record‑filing: large-scale HCFC consumers (≥100 t/yr with baseline records) and certain CTC consumers shall apply for consumption quota licensing (submit applications by 31 October each year for the following year’s quota). Other consuming entities, including feedstock users, air conditioner manufacturers/installers, PU foam users of polyol blends, fire suppression product manufacturers, lab reagent and electronic gas purification entities, and quarantine and treatment entities using controlled substances such as methyl bromide, shall complete record‑filing (for renewals, consumption records shall be filed between Dec.1 and Jan. 31 of the following year).
  •  Record‑filing for servicing and end‑of‑life recovery, regeneration, and destruction: Entities engaged in servicing and dismantling/scrap handling of systems containing controlled substances, and entities conducting recovery, reclamation, or destruction activities shall complete record‑filing at the city level for servicing/dismantling and at the provincial level for recovery, reclamation, or destruction.
  • Control of by-produced carbon tetrachloride (CTC): Methylene chloride producers with CTC by-production and entities with CTC feedstock design use exceeding 1,500 t/yr are required to install automatic monitoring equipment, connect it to the ecology and environmental authorities’ monitoring network, and ensure data accuracy.
  • Control of by-produced HFC-23: Facilities with HFC-23 by-production are prohibited from emitting HFC-23 directly. If the by-produced HFC-23 is not used as feedstock or for other permitted purposes, it must be destroyed using required technologies. The facilities are required to develop an HFC-23 monitoring plan, and carry out standardized measurements and periodic reporting in accordance with the Technical Specification for Accounting Methods and Reporting of By-product Trifluoromethane Emission from Chlorodifluoromethane Production Facility (HJ 1420—2025) (effective as of 1 March 2026). Furthermore, the facilities shall take measures for leakage detection and repair to reduce fugitive HFC-23 emissions.
  • Record keeping and reporting via the national system: Producers, sellers, users, servicers, end-of-life handlers, and recovery, reclamation, and destruction entities shall use the ODS Information Management System for quota applications or record-filing, retain complete original records for at least three years, and report data quarterly (production, sales, and consumption: within fifteen working days after the quarter’s end) or annually (servicing or end-of-life recovery, reclamation, and destruction: within thirty working days after the year’s end).
  • Strengthened enforcement: Ecology and environment authorities will prioritize inspections and supervision in relevant sectors, using automated monitoring, cross-agency data screening, big-data analytics, and on-site checks to identify violations, especially unlicensed or over-quota production or sales, improper buying or selling, illegal consumption of phased-out substances or unlicensed/over-quota consumption, and failure to meet record-keeping or filing requirements.

Additional IGSD resources related to this topic:

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