Secretariat’s report
on ODS sales for uses onboard ships
As requested by Decision XXIII/11, the
Secretariat’s report (32/3 and 32/INF4) includes
the results of:
 our review of historic documents on previous
guidance provided to the parties
 our review of parties’ submissions
 our consultations with IMO and WCO
Guidance previously provided
on ODS sales to ships
Decision III/9 (1991) and Decision V/5 (1993)
“the quantities of controlled substances used for
refilling the refrigeration and fire-extinguishing
systems on ships in ports should be regarded as
forming part of consumption of the country with
jurisdiction over the port and should therefore not
be included in its exports figures”
While this specific language was deleted from the
reporting format in 1997 (decision IX/28), most reporting
parties indicated that they are following this guidance
Guidance previously provided to parties…cont.
No guidance has ever been provided on how to
treat ODS that are supplied to a ship in
quantities that are sufficient to meet its
servicing requirements but are not in fact used
for servicing, or, that are supplied to ships in
quantities obviously over the level necessary to
meet their servicing requirements
 As a consequence, some parties are
treating such a supply differently
Summary of main findings
based on the responses of 21 reporting parties
(incl. the EU on behalf of its 27 member States)
 Most parties seem to be conforming to the guidance
 Three parties differentiate between ODS provided
for servicing ships’ equipment and ODS simply
supplied to ships (in quantities that meet or
exceed servicing requirements) but not necessarily
used to refill in port;
 A few parties specified that they have no official
statistics on the sales/uses of ODS on flag ships
as those are not accounted for in their licensing
systems
Reported data on use of ODS on ships
(Decision XXIII/11, para. 8)
Based on data submitted by 3 parties
ODS
2008
2009
Banks
242 a
Exports
14.4 b
608 c
2010
483 c
a
HCFC amount reported by one party
b Primarily HCFCs reported by one party
c Total HCFC amount reported by two parties
To date 3 parties have specified ODS exports to
foreign flag ships in some of their A7 reports; totals
(primarily HCFCs) range from 37 MT in 2005 to 67 MT
in 2010
Main concerns
expressed by parties in their submissions
 Treating ODS supply to foreign flag ships as
exports to the flag states could lead flag states
into non-compliance
 Lack of recording of ODS supplied to flag ships
could provide a loophole for illegal trading as
such amounts might be passed on to other flag
ships in high seas or other ports
Additional findings
Guidance previously provided to parties concerned
also ODS treatment in:
 Free-trade zones (Decisions III/9 and V/5)
 Trans-shipment as opposed to imports and reexports (Decisions IV/14 and IX/34)
No Parties specifically addressed these
provisions in their response to decision XXIII/11
TEAP reports
Traditionally, RTOC reports have provided information
primarily on the types and estimated amounts of
refrigerants used on board ships
Consultations with IMO
Relevant Framework: Annex VI of the International
Convention for the prevention of Pollution from ships
(MARPOL)
 Ships
over 400 GT are required to record non sealed
ODS-containing systems and equipment, and to
maintain a record book registering the amounts of ODS
used for supply, recharging, repair, discharge and
disposal operations
 IMO has no mandate to review those log books; any
enforcement is undertaken by port State control officers
in ports of states that are parties to Annex VI of
MARPOL
Consultations with WCO
Relevant framework: Revised Kyoto Convention on the
Simplification and Harmonization of Customs Procedures

The trade of ODS for use on board ships or the use
itself is not specifically addressed
 It is
recommended that ODS amounts supplied to
vessels be recorded on any relevant declaration
required by Customs authorities; however, WCO has
no mandate to review

There exists no international compliance obligation

ODS nomenclature is now included in the WCO
framework to facilitate data collection and comparison
Thank you!