管制及削減氫氟碳化物的諮詢文件

5 September 2023

Mr TSE Chin Wan, BBS, JP Secretary for Environment and Ecology Environment and Ecology Bureau 16/F, East Wing, Central Government Offices 2 Tim Mei Avenue, Tamar Hong Kong

Dear Mr Tse, 

Re: Proposal to Regulate and Phase Down Hydrofluorocarbons for Implementation of the Kigali Amendment to the Montreal Protocol

The Hong Kong General Chamber of Commerce welcomes the Bureau’s proposal to regulate and phase down Hydrofluorocarbons (HFCs), which are powerful greenhouse gases with high global warming potential (GWP), to fulfil Hong Kong’s international obligations under the Kigali Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer (the Amendment).

While the proposal could mitigate climate change through the incremental removal of HFCs, we suggest that the Government take into account the operational practicalities that businesses would be faced with in implementing the Amendment and defer the implementation of the ban on sale and supply, as well as on-product labelling requirement to allow businesses more time to comply with minimal disruptions.

These and other comments are set out in the attached. We hope you will find our comments useful.

Yours sincerely,

Patrick Yeung

CEO