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After more than three decades of undeniable success, the Montreal Protocol is being tested.

Three years after the adoption of the Kigali Amendment, the Environmental Investigation Agency (EIA) said there is an urgent need for the agreement to undergo a comprehensive fitness check.

Put simply, it's time to take stock because not enough is being done.

In its briefing to the 41st Open-Ended Working Group of the Parties to the Montreal Protocol in Thailand this month, the EIA said its time to consider what additional actions can be taken by the Parties at the upcoming meeting in Italy.

The 31st Meeting of the Parties to the Montreal Protocol on Substances that Deplete the Ozone Layer (MOP 31) is scheduled to convene in Rome this November.

“The Parties should also consider advancing the energy efficiency agenda in ways responsive to the urgency of
the climate crisis. It is time to reinvest in the Montreal Protocol,” the briefing note said.

“With the discovery of illegal production and use of CFC-11 last year and the Kigali Amendment coming into force at the beginning of 2019, we urge the Parties to the Montreal Protocol to take a very serious look at the current monitoring, reporting and verification requirements and procedures of the Montreal Protocol and initiate a comprehensive fitness check.”

There are a number of reasons why the EIA has questioned the ability of the Parties to effectively enforce Montreal Protocol commitments.

From high emissions of CFC-11 in China to the growth of illegal refrigerants in Europe and Asia, compliance is clearly a problem.

The EIA also raised the issue of destroying ODS and HFC banks claiming very little has been done to date.

“We further urge Parties to address the time limited opportunity of managing and destroying ODS and HFC banks, explore ambitious fast-action scenarios for capturing additional climate mitigation, and examine all unintentional by-products of new refrigerants," the note said.

The EIA has called for a comprehensive evaluation by the Parties of the costs and approaches to the management of ODS and HFC banks including recovery, reclamation and disposal.

“The evaluation should include a review of national legislation and best management practices in countries with high recovery and destruction rates,” the briefing note said.

At the same time the EIA believes more needs to be done to ensure frameworks are in place to support flammable refrigerants, including those classified as A2L.

The EIA described the introduction of higher charge limits for hydrocarbons by the International Electrotechnical Commission (EIC) as a “significant breakthrough”.

“The charge limit increase from 150 to 500g will enable more widespread uptake of energy efficient low-GWP hydrocarbons across the commercial refrigeration sector,” the EIA said.

The amendment had been in development since 2014 and the introduction of the changes will see A3 refrigerant charge sizes increase to 500g and A2L refrigerants to 1.2kg.

In the briefing note, the EIA said updates to safety standards are critical to enable market uptake of low and zero GWP refrigerants and to leap frog HFCs.