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New Report: Curbing 90 Billion Tons of Super-Pollutant Emissions


20 October 2022, Washington, DC — Minimizing refrigerant leaks and maximizing end-of-life recovery and reclamation can avoid fluorocarbon emissions equivalent to 90 billion metric tons of CO2 this century and help avoid climate catastrophe, according to a new report released today by Institute for Governance & Sustainable Development (IGSD), the Environmental Investigation Agency (EIA), and the Natural Resources Defense Council (NRDC).

The report, The 90 Billion Ton Opportunity: Lifecycle Refrigerant Management, lays out this significant opportunity for federal and state policymakers, major corporations, and equipment owners and operators. Embracing Lifecycle Refrigerant Management can prevent fluorocarbon emissions equal to nearly three full years of global energy-related carbon dioxide emissions today.

“We humans have manufactured these potent pollutants that are being needlessly released when we have both the know-how and a huge value proposition for industry and the public to capture them,” said Christina Starr, Senior Policy Analyst from the Environmental Investigation Agency, and a co-author of the report. “The science clearly tells us we need faster and deeper HFC emission reductions to avoid dangerous climate tipping points and remain below 1.5°C of warming, and this is a very real opportunity to get them.”

“Refrigerant releases are an invisible climate culprit. Lifecycle refrigerant management provides clear and tangible interventions that can prevent the release of billions of tons of CO2e emissions across the refrigerant value chain to help us stave off the worst impacts of climate change,” said Christina Theodoridi, Industrial Policy Advocate for the Natural Resources Defense Council and co-author of the report.

Even as the world moves to climate-friendlier refrigerant gases under the Kigali Amendment to the Montreal Protocol, a huge and still-growing legacy of old, climate- and ozone-damaging gases continues to amass in nearly every nook and cranny of the world. The report outlines ways to get those fluorocarbon gases back into tanks and properly reused or disposed of. In the U.S., the American Innovation and Manufacturing (AIM) Act – the legislation that phases down HFCs by 85 percent over the next 15 years – contains new provisions yet to be implemented regarding just that.

“The AIM Act grants EPA the authority to minimize leaks and maximize recovery, reclaim, and destruction. This makes a wide range of options available at the federal level to make lifecycle refrigerant management a climate policy priority,” said Durwood Zaelke, President of the Institute for Governance & Sustainable Development.

Many in industry agree that reducing wasteful refrigerant leaks and increasing the amount of refrigerant reclaimed is a worthy goal. “Increasing refrigerant reclamation is a win-win for businesses and the environment,” says Bruce Ernst from A-gas, a refrigerant reclaimer who was also a technical advisor to the report’s authors.

The U.S. Environmental Protection Agency last week released a Notice of Data Availability requesting public feedback on current fluorocarbon recovery and reclamation practices, marking the start of national policymaking in this important area. EPA also released a proposed rule extending its HFC allowance allocation framework, which is responsible for administering the phasedown of virgin HFC supply, to the years 2024-2029.

The full report is here.

A blog post on the report is here.



Refrigerants are commonly used in home air conditioners, refrigerators, and heat pumps. They are also found in vehicle air conditioners and commercial and industrial cooling equipment. Many refrigerants are super-polluting hydrofluorocarbons (HFCs), which are thousands of times stronger greenhouse gases than CO2. Older refrigerators and air conditioners pose an even greater risk since they can contain ozone depleting substances such as chlorofluorocarbons (CFCs) and hydrofluorocarbons (HCFCs) as refrigerants, which are also potent greenhouse gases.

Refrigerants can be recovered and reused, or destroyed once they are no longer needed. Unfortunately, refrigerants are instead often vented to the atmosphere at the end of a product’s useful life, contributing to climate pollution and, in the case of older refrigerants, ozone layer damage. Although intentionally releasing refrigerants that harm the environment is illegal in the United States, noncompliance widespread. That, paired with the lack of a comprehensive policy framework for recovery and reuse have resulted in low levels of refrigerant recovery relative to what’s possible. Unrepaired leaks also are a major—but fixable—source of refrigerant waste and emissions.

Without a robust lifecycle refrigerant management regime, approximately 90 billion metric tons of CO2-equivalent of ozone-depleting and HFC refrigerants will be released by the end of this century. This includes refrigerant already in use today, and refrigerant expected to be produced through 2100 under the current phasedown schedule of the Kigali Amendment to the Montreal Protocol.

The Montreal Protocol on Substances That Deplete the Ozone Layer is a legally binding treaty that was signed by President Reagan in 1987 and approved unanimously by the Senate in 1988. The treaty is widely regarded as the most successful global environmental treaty. Over its 35 years of operation and several amendments, the Montreal Protocol has phased down nearly 100 chemicals that damage the stratospheric ozone layer and put the Earth’s protective ozone layer on the path to recovery. Because ozone depleting CFCs and HCFCs also were also extremely potent greenhouse gases, the Montreal Protocol saved the planet from catastrophic climate change as well as from ozone layer destruction. According to United Nations Environmental Programme, “if ozone-depleting chemicals had not been banned, we would be looking at a global temperature rise of an additional 2.5°C by the end of this century. This would have been a catastrophe.”

Under the 2016 Kigali Amendment to the Montreal Protocol on Substances That Deplete the Ozone Layer, upstream production and consumption of HFCs will gradually be phased down 85% by mid-century, avoiding up to 0.5°C of warming this century. On September 21, the United States Senate voted in favor of ratifying the Kigali Amendment with bipartisan support. The US joins over 135 other countries, including China and India, that have also ratified the Kigali Amendment.

As with prior Montreal Protocol Amendments, the Kigali Amendment focuses on phasing down new refrigerant production; it does little to ensure that existing refrigerant already contained in appliances and equipment be dealt with in an environmentally responsible manner. For this reason, the AIM Act – U.S. implementing legislation – takes specific steps to authorize U.S. Environmental Protection Agency to be more ambitious in mitigating leaks and maximize refrigerant reclamation than what may strictly be required by the treaty.