Seek relevant **regulations** regarding the use of F113, F22, and F141b as raw materials
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Recently, the company is undergoing an environmental impact assessment. An experienced expert determined that the intermediate product contains F113, stating that it belongs to a category of industries that should be phased out. We explained to this expert that it is an intermediate product that does not leave the production process but is used directly as raw material for the next stage of production; however, he would not agree with us. Is there any regulation similar to this, allowing such products to be used as intermediates without leaving the production process? Thank you all.
F113** is under strict control, mainly due to illegal transactions in the market
When used as a raw material, **there should be no restrictions, but supervision needs to be strengthened to prevent it from being sold as a product.
It is not possible to use a CFC-113 unit in new projects, even for intermediate products； **Only enterprises that previously manufactured these products are approved to use them as intermediate raw materials for producing other products
One can refer to the approach used for tetrafluoroethylene monomer TFE and use it as a comparison to see if there is any similarity.
The two are not comparable at all. TFE is used as an intermediate product because it cannot be transported, and its storage is extremely dangerous; therefore, it must be converted into other products through polymerization, cracking, or addition reactions. F-113, on the other hand, was developed with funding from the World Bank – the owners have the right to exclude China from producing or selling it. How can it be compared to TFE?
What is the raw material before TFE?