- The Consumer Council ("CC") is pleased to make the following submission on the Ozone Layer Protection (Products Containing Scheduled Substances) (Import Banning) (Amendment) Regulation 2009 ["the Amendment Regulation"].
- CC supports banning the import into Hong Kong of certain products containing hydrochlorofluorocarbons (HCFCs), chlorofluorocarbons (CFCs) and other ozone depleting substances and increasing the penalties for offences under the principal Regulation in Hong Kong, in order to comply with the requirements of the Montreal Protocol on Substances that Deplete the Ozone Layer.
- CC is pleased to learn from the Legislative Council Brief with File Ref.: EP 351/O4/34 that the Administration had consulted major trade associations and concerned product suppliers on the proposed bans and that they do not object to the proposal. CC is aware that a number of household electrical appliances such as air conditioners, refrigerators and freezers may contain HCFCs such as HCFC-22 (also known as R22). It is important that the views of stakeholders are tapped for a correct assessment of how the proposed ban may impact on industries, the market and consumer choice. Market readiness should determine the roll-out time for the proposed ban for the control products to render the ban practicable.
- CC observes that HCFC-free air conditioners, refrigerators and freezers are sold at higher prices. The Administration also estimates that the prices for HCFC-free air conditioners on the local market are about 10 to 25% higher than those using HCFC-22. Although consumers have been well educated to look for electrical appliances with higher energy efficiency, they may not be aware that higher-priced products with HCFC-free refrigerants are environmentally more preferable. For those who know, they may not be prepared to pay a higher price for the sake of sustainability of the environment. CC is of the view that the Administration needs to educate the public that there is more to environmental friendliness than energy efficiency, and that we need to pay more for the environment. More promotion is required to enhance public understanding and support of the environmental benefits of using HCFC-free refrigerants.
- CC welcomes the requirement under the new mandatory Energy Efficiency Labeling (EEL) Scheme for suppliers to disclose the type of refrigerants used in the products, but attention should be paid to how the information is to be disclosed. It is important that information disclosure is made in such a way that consumers can get the message easily. Consumer education should be a major focus of the Administration in promoting the green environment. With increased consumer education to raise the environmental awareness of the public on energy saving and ozone depletion, Hong Kong will be in a better position to meet its obligations towards sustainable consumption.
- Consultation Papers
- 2009.10.06
