How is the dumping of inefficient equipment affecting efficiency progress?

Differing regulatory frameworks open the door to inefficient equipment dumping

The efficiency of appliances available for purchase varies substantially across different markets globally. IEA market data shows that between emerging markets alone the differences are very large. For example, the median efficiency of air conditioners in the sub-Saharan Africa region is only 3.1 W/W, while it is 4.7 in Southeast Asia, close to the 5‑6.5 W/W the NZE Scenario foresees by 2030. At the same time, household budgets for the purchase and use of appliances differ strongly due to global wealth and income inequalities. The result is that access to efficient appliances that reduce household energy expenditure is very unevenly distributed.

In addition, lower efficiency equipment, both new and second-hand, is typically exported to lower-income countries, thereby hindering the local market's ability to develop more efficient products. This practice, known as environmental dumping, has been defined by the Duke University School of Law as “the practice of exporting to another country or territory products that contain hazardous substances; have environmental performance lower than is in the interest of consumers or that is contrary to the interests of local and global commons; or can undermine the ability of the importing country to fulfil international environmental treaty commitments”. Dumping therefore includes the export of equipment that is treated as waste in the receiving country, equipment that is sold on second-hand markets, or new first-hand equipment that is of inferior environmental and energy consumption performance. The impact of dumping appliances goes far beyond environmental concerns. The embedded inefficiency of these products leads to higher energy bills for consumers and drives up energy demand, straining power systems and requiring new investment in generation capacity. As a result, critical resources are diverted from vital sectors such as health and education, hampering socio-economic development in low-income countries.

Outdated used equipment is flooding markets in lower-income countries, leading to a dominance of inefficient appliances

Every year large quantities of used equipment are exported to countries and regions with weaker regulatory frameworks, especially to the sub-Saharan Africa region. These appliances would be in large part disposed of as electronic waste for recycling in their origin countries but are sold as second-hand equipment instead. Due to their low upfront costs, these appliances are often preferred by consumers, leading to efficiency losses and creating health and environmental issues. For example, refrigerants that are ozone-depleting and are powerful greenhouse gases (e.g. CFCs, HCFCs and HFCs) are typically found in older refrigerators. Furthermore, waste management systems in importing countries frequently become overburdened by the influx of old equipment, leading to substantial waste management challenges that pose further risks to human health and the environment.

To address these challenges, Ghana implemented a ban on the import of used refrigerators and ACs in 2013. This ban, combined with MEPS and labels for new models resulted in three consecutive years of a drop of two-third in refrigerators’ average electricity consumption, which now stands at only one-fourth of the levels before the ban. After existing stock had been sold off, and thanks to these controls, the share of used imported refrigerators on the market decreased from 71% in 2012 to 6% in 2014 and 1% in 2023. International co-operation and experience sharing on how to handle non-compliant imports are helpful to enable countries in the region to protect their markets. 

Imports and average consumption of imported refrigerators in Ghana, 2005-2023

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The ban has been equally successful for used ACs, which represented only 1% of total AC imports in Ghana in 2023. The average energy consumption of ACs on the market was 18% lower in 2023 than the level observed before the ban. Between 2010 and 2023, the implementation of energy efficiency policies for appliances in Ghana, including the second-hand import ban and MEPS, delivered electricity savings of over 20 000 GWh, equivalent to 89% of current annual electricity generated in the country. Ghanaian households saved about USD 345 on average in electricity bills, totalling USD 2 billion overall. Furthermore, the electricity savings from 2010 to 2020 allowed 1 160 MW of additional capacity expansion to be delayed, equivalent to nearly one-third of the total thermal generation capacity in 2022.

Electricity and cost savings due to refrigerators and air conditioners compliant with energy efficiency policies in Ghana, 2009-2023

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Appliances not in line with standards in producer countries are exported to regions with weaker regulations

Bans on imported second-hand models do not prevent international manufacturers from selling new but inefficient appliances that use outdated technology. This practice can also be considered as dumping. Governments can help avoid this through standards and labelling programmes – Kenya has MEPS in place, as well as a comparative label scaled from 1-5 stars, for both air conditioners and refrigerators. However, current IEA analysis reveals that nearly all air conditioners and most refrigerators on sale barely meet minimum energy performance standards. The scarcity of high-efficiency models limits consumer choices and undermines efforts to reduce energy consumption.

Energy efficiency label levels of refrigerators and air conditioners on the market in Kenya, 2023

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Despite a conception that lower-efficiency appliances offer lower purchase prices for consumers, new IEA analysis shows that efficient models in the sub-Saharan Africa region are not necessarily more expensive than inefficient ones. This suggests that cost may not be the primary barrier to adopting energy efficient appliances. A closer examination of appliance imports suggests that international manufacturers may be taking advantage of lower market barriers in emerging economies to engage in inefficient equipment dumping. Kenya imports almost 90% of its air conditioners from China, the United States, India, the European Union, the United Kingdom, and Korea. In most of these countries, devices sold with a 1-star label in Kenya would not comply with the local MEPS in the manufacturing countries; this often also applies to 2‑star devices. These inefficient devices and their supply chains seem to be maintained purely for export to countries with weaker regulations.

Minimum energy performance standards levels in manufacturing countries and market share of air conditioners in Kenya compared to Kenya Energy Efficiency Label levels, 2024

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As in Kenya, over 110 countries have MEPS for ACs in place, making it a common policy option for restricting the import and production of inefficient appliances. However, their implementation requires a regulatory framework and effective institutions for market surveillance and enforcement. Many lower-income countries do not have the institutional capacity to enforce MEPS or classify products on the market using energy efficiency labels. Inefficient, outdated equipment finds its way onto the market when these frameworks are missing or not sufficiently enforced. While this dynamic can be observed primarily in regions such as sub-Saharan Africa, inefficient equipment dumping also happens in other regions. For example, in the absence of MEPS and labels for fans for household use, a 2021 study shows that 95% of fans imported into the European Union originate in China, with just over half of products on the market complying with MEPS in China. 

Good policies and international co-operation are needed to prevent the practice of inefficient equipment dumping

Governments have several options to address the dumping issue as part of a policy package covering equipment and appliances. Policies might target second-hand equipment originating from electrical waste meant for recycling, or new equipment exported by global manufacturers making the most of differences in regulations. Effective options include:

  • Ban the imports of second-hand products for major consuming appliances.
  • Design and regularly update MEPS and energy labels. For new first-hand models, a regulatory framework sets energy efficiency rules at a desired level, preventing exporters from putting equipment of inadequate efficiency on the market.
  • Harmonise MEPS and labels at regional level. When the same regulations apply in several neighbouring countries, they are easier to enforce. Countries can share technical capacities and testing facilities, they can co-organise controls at borders, they have a higher bargaining power in import negotiations, and they reduce the risk that equipment enters the country via neighbours with less strict regulations. Regionally harmonising regulations by adopting one framework also supports manufacturers and allows industry to optimise product lines and plan investments. For example, the Southern African Development Community1 officially approved harmonised regional MEPS for air conditioners and residential refrigeration appliances in 2024. A reduction in annual electricity consumption of nearly 8 TWh is expected, equivalent to four 500 MW power plants, saving 6.5 Mt CO₂ emissions by 2040 and reducing consumers’ electricity bills by USD 840 million annually.
  • Engage with exporting manufacturers: In the same way that governments train and support local manufacturers when passing new regulations, engaging with global exporting manufacturers on standards and labels can facilitate enforcement and prompt industry alignment. Manufacturers also have an important role to play in both minimising the impacts of their operations and improving the efficiency of their products globally. 
  • Use other frameworks and tools as inspiration: Montreal Protocol signatories came to a landmark Decision XXXV/13 in October 2023 by engaging both exporting and importing parties in addressing the problem of dumping of products containing substances that deplete the ozone layer (HFCs and HCFCs). This decision opens up the potential to use multilateral funds to prevent non-compliance in the importation of prohibited cooling equipment. It also urges parties to prohibit the export of cooling equipment that would also be prohibited in the market of the exporting party.

Acknowledging the importance of the issue and the responsibility of all countries in dumping problems, in July 2024 the United Nations Secretary-General’s Call to Action on Extreme Heat included a call to “prevent dumping of new inefficient equipment that uses obsolete refrigerants”.

References
  1. Angola, Botswana, Comoros, Democratic Republic of the Congo, Kingdom of Eswatini, Kingdom of Lesotho, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Seychelles, South Africa, United Republic of Tanzania, Zambia, and Zimbabwe.