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In an effort to provide insight into six Southeast Asian (SEA) markets at risk of environmental dumping, CLASP and IGSD assessed the RAC markets for Indonesia, Malaysia, the Philippines, Singapore, Thailand, and Vietnam. The six countries represent 90% of the regional SEA market.

Currently energy efficiency policies in Southeast Asia lag behind the innovation in RAC technology and the policies of surrounding countries. As low-efficiency and high global warming potential refrigerants are banned in markets around the world, SEA is at risk of becoming a dumping ground for obsolete appliances manufactured by multinational companies that are banned in their own domestic markets. Rolling out and enforcing national energy efficiency policies coupled with accompanying measures would halt this trend.

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.

This paper describes how the Ghana Energy Commission and the Environmental Protection Agency’s National Ozone Unit have joined forces in a comprehensive strategy to access and implement low-global warming potential (GWP) and energy-efficient cooling technologies that protect the Earth’s climate and stratospheric ozone layer. This strategy, in line with the objectives of the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol): 1) integrates upgraded energy efficiency labels with refrigerant metrics; 2) strengthens minimum energy performance standards (MEPS); 3) prohibits the dumping of used cooling appliances; 4) uses the OzonAction informal Prior Informed Consent (iPIC) mechanism to facilitate communications among national authorities on the import and sale of appliances containing or using obsolete refrigerants scheduled for phase out or phase down under the Montreal Protocol; and 6) asks Parties to the Montreal Protocol to enact and enforce regulations that help stop the dumping of used and new cooling equipment in export-market countries wanting to leapfrog obsolete appliances that waste energy and force climate change.

The demand for air conditioners that provide thermal comfort is steadily growing across the African continent as consumers seek to improve their quality of life in the face of urbanization and rising global temperatures. Since 2016, Africa’s market for new split room air conditioners has grown by approximately 5%, annually. As manufacturing and industrialized economies place increasingly stringent standards on room ACs sold domestically, while allowing continued export of technology that cannot legally be sold in the country of export as a consequence of failure to meet environmental, safety, energy efficiency, or other product standards, importing countries risk becoming dumping grounds for inefficient, environmentally harmful products using obsolete refrigerants. Weak or non-existent energy performance standards and the lack of proactive anti-environmental dumping policies in many African countries have facilitated environmentally harmful dumping of inefficient, high-global warming potential cooling products into African markets.

This report details the extent of the problem across ten countries in North, West, East, and Southern Africa, ultimately providing policymakers with a set of solutions to encourage a transition toward highly-efficient, sustainable cooling technologies.

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.

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