The economic motive for ODS smuggling is clear.Production of chemicals that are still widely-sought isbanned in industrialised countries, while production incertain developing countries has soared. For instance,one kilo of CFC-12 costs around C12 in the UK but canbe bought in China for C1. Similarly a kilo of halon 1301in the US costs upward of $25, but is on sale for just $8 inChina.

Given that the phased approach adopted under theMontreal Protocol creates fertile ground for a blackmarket to grow, the issue of enforcement becomes cru-cial. The US approach has been to set up a proactiveinter-agency task force to tackle the ODS smugglers,bringing together the Environment Protection Agency,customs service, Federal Bureau of Investigation, andDepartment of Justice. As a result there has been a seriesof high-pro"le prosecutions, with one smuggler sen-tenced to almost "ve years in prison.

In Europe attempts to detect illegal shipments andprosecute smugglers have been hampered by a lack ofcross-border co-operation. It was only last year thatSpain "nally introduced legal sanctions against ODSsmugglers. Yet a series of initiatives are emerging whichshould greatly curtail the illegal trade in ODS. The Euro-pean Union is in the "nal stages of adopting a sales anduse ban for both CFCs and halons, the US is in theprocess of tightening up its ODS import regulations, andthe G8 forum of the world's leading economies is

strengthening international e!orts to combat environ-mental crime, including ODS smuggling.

As a result of its exhaustive investigations EIA believesthere is a pressing need for an enforcement committee tobe established under the aegis of the Montreal Protocol.Such a committee would compile annual reports into theillegal trade and disseminate best practice to counter it.Progress on this issue was made at the meeting of theparties held in Beijing last December.

The Montreal Protocol is a landmark agreement, rep-resenting the most successful e!ort by governments tocounter a human-induced environmental problem. Yetits achievements are being undermined by the illegaltrade. Steps taken now to tackle the smugglers will notonly strengthen Montreal, but will create an importantprecedent for the enforcement of future multinationalenvironmental agreements such as the Kyoto Protocolon greenhouse gases.

Julian Newman1

Environmental Investigation Agency, 69-85 Old Street,London EC1V 9HX, UK

E-mail address: eiauk@gn.apc.org

1 Julian Newman is an investigator at the EnvironmentalInvestigation Agency, an international non-governmental or-ganisation based in London and Washington DC.

New Directions: Will illegal trade in CFCs and halons threatenozone layer recovery?

Halon-1301 (CBrF3) and CFC-12 (CCl

2F2) are major

ozone depleting substances (ODSs) that are still increas-ing in concentration in the background atmosphere (seeFraser et al., 1999, Journal of Geophysical Research 104,15985}15999 and Montzka et al., 1999, Nature 398,690}694). This is in spite of a ban, under the MontrealProtocol, on their production in the developed worldsince the mid-1990s. Emissions of H-1301 and CFC-12continue from their large banks ("xed "re-"ghting sys-tems, old refrigeration and air conditioning units) in thedeveloped world and from legal use in an expandingmarket in the developing world. The phasing out ofproduction of CFCs and halons in the developing worldis not due until 2010. The inclusion of expected develop-ing world consumption of CFCs and halons over the nextdecade into global emission models suggests that theonset of measurable ozone recovery may not occur untilapproximately 2020, according to the World Meteoro-logical Organisation's Scientixc Assessment of OzoneDepletion: 1998 (Madronich et al., 1999, WMO ReportNo. 44, Geneva, (Chapter 11).

Julian Newman, in this issue, reports that there isan illegal trade, between developing and developedcountries, of over 20,000 tonnes per year of CFC-12 andH-1301. If emitted to the atmosphere, these additionalCFCs and halons will further delay ozone recovery. Thistrade is reported to occur via incorrect labelling of newCFCs and halons, produced in the developing world, aseither HFCs or as recycled product. These are in re-sponse to demand for CFCs and halons to service exist-ing equipment, largely in the developed world. In theabsence of an illegal trade, this demand could be satis"edlegally, albeit expensively, from recycled CFCs andhalons.

So how signi"cant is a possible trade of this magni-tude? The 1997 world production of CFCs and halons(largely CFC-12 and H-1211) in developed (10%) anddeveloping (90%) countries was approximately 200,000ODP (ozone depletion potential) weighted tonnes peryear according to the United Nations EnvironmentProgramme (http://www.unep.org/ozone). The amountof CFCs and halons stored in refrigeration and air

3038 New Directions / Atmospheric Environment 34 (2000) 3037}3039

Fig. 1. The global CFC and halon bank (in 106 OPD-weightedtonnes). Data from the Alternative Fluorocarbon Environ-mental Acceptability Study (see http://www.afeas.org/produc-tion}and}sales.html) and Fraser et al. (1999).

conditioning systems plus "re "ghting installations wasapproximately 2,000,000 ODP tonnes, comprising 55%CFCs and 45% halons (see Fig. 1). Assuming the re-ported illegal trade is ODP weighted and sourced fromunreported production, it represents an additional 10%of global production of CFCs and halons, but only about1% of the global bank of CFCs and halons.

The maximum future cumulative CFC and halon re-lease could be comprised of the existing bank (i.e.2,000,000 tonnes) plus the remaining production that willoccur until 2010 (when global production is meant tocease). Assuming an average production of 100,000tonnes per year over the next 10 years, total future ODSrelease could be 3,000,000 tonnes. The cumulative releasefrom 10 years of illegal trade (assuming it continues at thereported level) will be 200,000 tonnes } an additional 7%.Future emissions of ODSs will be dominated by releasesfrom the banks (60}65%) with new production ac-counting for 30% and illegal trade about 7%. The im-portance of the halon bank in future ozone loss has beendemonstrated in the WMO Report. They estimate that

halon released from the existing banks (if all released)would be responsible for 15% of ozone depletion overthe next 50 years, whereas illegal production of 20,000ODS tonnes per year of CFCs over the next ten years willincrease ozone depletion over the next 50 years by 1%.

Newman suggests that the Montreal Protocol shouldbe strengthened to address this issue of illegal trade. Thissuggestion deserves further investigation as illegal tradecould represent a small, but signi"cant, direct threat toozone recovery and should be discouraged. A more sig-ni"cant step that could be taken to hasten ozone recov-ery would be to minimise future emissions of CFCs andhalons from their respective banks, which are locatedlargely in the developed world. Technologies exist tocapture, recycle or destroy CFCs and halons from exist-ing equipment, but the costs are relatively high and theglobal level of this activity in recycling/destruction isdisappointingly low. Cheap CFCs and halons, illegallyimported into the developed world, represent a signi"-cant threat to relatively expensive CFCs and halonsobtained from recycling activities.

Illegal trade in CFCs and halons at current reportedlevels is a small threat to ozone layer recovery. What itdoes threaten, however, is the viability of #edgling e!ortsin CFC and halon recovery, recycling and destruction.Preventing the CFCs and halons in the existing banksfrom being released is the most signi"cant step that canbe taken to hasten recovery of the ozone layer.

P.J. Fraser1CSIRO Atmospheric Research/CRC for Southern

Hemisphere Meteorology, PMBd1Aspendale, Victoria 3195, Australia

E-mail address: paul.fraser@dar.csiro.au

1Dr. Paul Fraser is a Senior Principal Research Scientist withthe Commonwealth Scienti"c and Industrial Research Organ-isation (Atmospheric Research Division) in Australia, with 25years involvement in investigating CFCs and other ODSs, andtheir impact on ozone depletion.

1352-2310/00/$ - see front matter ( 2000 Elsevier Science Ltd. All rights reserved.PII: S 1 3 5 2 - 2 3 1 0 ( 0 0 ) 0 0 0 9 4 - 7

3039New Directions / Atmospheric Environment 34 (2000) 3037}3039