As announced in a previous blog post, all importers and logistics organisations in Australia are to comply with a ban on importing hydrochlorofluorocarbon (HCFC) gas and equipment unless provided a license.
This has been part of a global phase-down of HCFC and the wider initiative to reduce greenhouse gas emissions in the country as required in the Montreal Protocol on Substances that Deplete the Ozone Layer.
That said, here are some key points that importers must zero-in on to quickly and effectively ensure compliance with the new standards.
1. Phase-downs are not total bans.
Bear in mind that reduction is the current objective of the new requirements and not total elimination. There will still be exceptions that importers can use to ensure smooth processing. (Again, licenses can still be secured to allow importation provided that requirements are satisfied.)
2. Phase-down primarily focuses on bulk gas.
HCFC gas that is being transported in bulk quantities (such as cylinders and tanks) are the ones primarily covered by the phase-down. That means that as of the coming year, you are to hold quota on these specific types of HCFC imports.
3. Gas imported as part of pre-charged equipment is treated separately.
HCFC contained as part of imported equipment is not subject to the same treatment as bulk HFC imports. The phase-down that covers them will only apply in the state of their manufacture and importers are to account for them there prior to shipping.
4. Banning of HFC equipment imports still being deliberated.
There is no official word that HCFC equipment will be completely banned in the near future but importers are still reminded that it can happen. Consultation with the industry and advancement of alternative technologies would certainly pave the way to it.
5. Bans and phase-downs only applicable to new equipment.
Lastly, even in the event of a total ban on HCFC equipment, any pre-existing equipment inside the shutdown will not be affected. Servicing will still continue, as will replacement procedures in the case of leaked refrigerants.
All things considered, now is as good a time as any to call your supply chain managers and logistics partners on how to move forward in light of increasing restriction on greenhouse gas emitting equipment and the possibility of their eventual phase-out.