EVENTS AND EXHIBITIONS
INCORPORATING COLD CHAIN
SADC countries unite to control
ozone depleting substances
By Ilana Koegelenberg and DEA
Noting the recent revelations that emissions
of the phased out R11 refrigerant have
climbed 25% since 2012, suggesting illicit
manufacturing in violation of the Protocol, has
again raised the issue of the link with illegal
trade in CFCs. There is growing evidence
of an increasing illegal trade in HCFCs with
seizures of HCFCs continuing around the
world. Recently, a number of countries
have been experiencing misdeclaration
of mislabelled refrigerant. In relation to the
illegal trade of HCFCs, monitoring of the
trade of ozone depleting substances (ODS)
at the national level and ODS trade between
countries are key focal areas.
There are two main aspects that need to
be considered in relation to the illegal trade
in HFCFs:
a. Monitoring of ODS trade at national level
While all countries have licence and
quota systems that cover HCFCs, their
implementation and enforcement vary
considerably from country to country. Results
from verification of HCFC consumption in some
countries show discrepancies between ODS
trade statistics maintained by the National
Ezra Clark of UNEP also handed out a quiz
during the workshop to test the various
countries on their knowledge on the topic at
hand.
b. ODS trade between countries
In most regions, comparison of reported
import and export data indicates significant
discrepancies in what countries report. For
example, several countries report significantly
less import of HCFC22 than the exporting
counties declare. These discrepancies could
result from, inter alia, illegal trade or incorrect
or false application of licencing, or the trade of
ODS that is recognised by one country, but not
by another trading country (especially border
trade, which is a big challenge for the customs
to control in situations where there is a porous
land border).
The above issues could be addressed to
some degree through better cooperation
between NOU and customs to improve
implementation of the national licence
and quota systems. Moreover, it is common
that a customs authority can only inspect
1–2% of containers it receives. It is therefore
of great importance that the containers
selected for inspection are those most likely
to contain smuggled goods, while shipments
most likely to be in compliance are cleared
without inspection. While the implementation
of intelligence-led enforcement and/or
risk profiling is common in many customs
authorities (sometimes integrated into
electronic/single window customs systems),
a number of countries in the region do not
use such an approach and ODS does not
feature systematically, if at all, in the risk
profiling criteria.
To assist A5 countries to address these
issues and challenges, a number of NOU and
Ezra Clark of UNEP steered the workshop on day two.
BACKGROUND
Ozone Unit, licensing authorities, and the
Customs Department, which are attributed to
the following:
◊ Incorrect declaration of HS codes
(misdeclaration or unintentional use of
incorrect codes) during the customs
clearance process, in particular where
an ODS shipment is cleared in the same
batch with other commodities.
◊ Customs clearance is granted to
importer/exporter without valid license
issued by authority.
◊ Illegal trade of ODS / smuggling the
shipment.
◊ Lack of effective monitoring mechanism
to track the actual trade of ODS after
the license is issued to importer/exporter.
In some cases, the trade does not take
place in accordance with the issued
license, for example the importer fails to
import ODS within validity of the license,
or imports/exports less/more than the
allowance in the license.
◊ Lack of periodic reconciliation of data
with the National Ozone Unit (NOU),
licensing authorities, and the Customs
Department.
One of the bilateral sessions in progress in a room next door to the workshop.
S
ADC countries such as Angola,
Botswana, Lesotho, Malawi, Mauritius,
Mozambique, Namibia, Seychelles,
South Africa, Eswatini, Tanzania, Zambia,
and Zimbabwe all gathered together from
24 to 26 October 2018 at the Birchwood
Hotel in Johannesburg. The ‘National Ozone
Unit and Customs Twinning workshop and
Border Dialogues for countries of the SADC
region — Africa Anglophone Network’
gathered officials from the various national
ozone units, environmental inspectors, and
customs from the countries involved.
In October last year, United Nations Environment OzonAction, in collaboration with the local
government, organised a successful workshop to strengthen coordination and controls of ozone
depleting substances in the SADC region.
All ears for Ezra Clark’s explanation of answers to the test.
customs twinning meetings with
selected countries was proposed.
These meetings are aimed at
covering two main areas: (1)
strengthening the cooperation
between countries, and (2), more
specifically on particular border-
related issues (border dialogues).
COLD LINK AFRICA • March/April 2019
Following the meeting, the countries
had to report their border dialogue
activities as an approved part of their
HCFC Phase-Out Management Plan
(HPMP) Montreal Protocol funded
country projects.
Continued on page 29
www.coldlinkafrica.co.za
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