Environmentally harmful product dumping (“environmental dumping”) of new and used low-efficiency cooling appliances with obsolete ozone-depleting and greenhouse gas refrigerants in African countries impoverishes communities, hinders economic development, threatens ecological systems, and harms public health. The use of lowefficiency cooling appliances increases energy demand, leading to higher power plant emissions and limiting affordable energy access in African countries. These low-efficiency appliances and products contain ozone-depleting refrigerants with high global-warming potential (GWP) or ozone-safe refrigerants with high GWP. Environmental dumping of these appliances and products makes it more difficult for countries to meet their international climate obligations and for the world to meet the Paris Agreement’s climate change mitigation targets. Ghana faces high levels of environmental dumping, despite a national ban on importing used cooling appliances and established efficiency standards for new air conditioners and refrigerators. Through the Energy Commission’s Office of Renewable Energy, Energy Efficiency, & Climate Change (REEECC), the government of Ghana is partnering with the Institute for Governance & Sustainable Development (IGSD) to stop environmental dumping. This article provides a list of interventions that can be implemented by Ghana, by governments in countries that export to Ghana, and by industry and other stakeholders. Notably, these actions focus on the shared responsibility of exporting countries and manufacturers by calling on exporting countries to update and enhance enforcement of their laws, and on global manufacturers to stop exporting inefficient products with obsolete refrigerants to Ghana and other African countries.
Environmental dumping is a practice historically associated with the export of hazardous product waste from a developed country for irresponsible and often illegal disposal in a developing country. Now, with the industrialization and globalization of China and other developing countries, environmental dumping can involve both developing and developed countries as origin and destination. This dumping can be especially harmful to attempts to control under the Montreal Protocol ozone-depleting and climate-forcing chemical substances and/or products requiring unnecessarily high energy consumption. While developing country Parties to the Montreal Protocol are allowed to delay their phasedown of climate-forcing and ozone-depleting hydrofluorocarbons (HFCs) during a multi-year grace period, there are advantages to earlier implementation when superior alternatives are already available at reasonable costs, as is the case for many uses of HFCs today. Thus, developing countries can benefit under the Protocol from setting controls for environmental dumping. This article aims to give policymakers, especially those in developing countries, a legal and policy “toolkit” that can be used to stop unwanted environmental dumping. It includes an examination of the history of environmental dumping, illustration of such dumping in practice, a detailed explanation and examination of the legal and policy tools, and a summary of the consequences of environmental dumping.