Technical Support Document for 2013 Methyl Bromide CUE Rule EP-W-10-032

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1. Supply Chain Factor Analysis

1.1 Introduction

Since 2004, U.S. methyl bromide producers’ estimate of the time needed to re-establish methyl 

bromide production in the United States following a major domestic supply disruption has changed, 

prompting a reassessment of the inventory needed to mitigate potential supply shortages following 

such an event. In the event of a loss of domestic methyl bromide production capacity, the supply 

shortfall of methyl bromide for domestic consumption is estimated based on the amount of methyl 

bromide needed in excess of the amount that can be expected to be imported from foreign producers 

to satisfy domestic demand over the period required to restore domestic production capacity. The 

quantity of metl bromide authorized by the Parties to the Montreal Protocol for critical uses in the 

United States in 2013 (and the amount on which the projected 2013 methyl bromide demand is based) 

is 562,326 MT. To meet demand not expected to be satisfied by imports during the time required to 

re-establish domestic production would require domestic methyl bromide inventories of 

approximately 3–70% of the annual 2013 demand or between 17 and 394 MT. This document 

explains the process by which this inventory calculation was reached.

This analysis assumes that the methyl bromide supply (i.e., the lost domestic production capacity) 

will be re-established. However, it is important to note that in the event of a major loss of domestic 

production, whether U.S. methyl bromide production companies decide to re-establish methyl 

bromide production capacity or to reconfigure their facility to produce methyl bromide would be an 

individual company business decision. For example, if the methyl bromide shortfall is such that the 

price of methyl bromide increases and some users choose to switch to alternatives, the demand for 

methyl bromide may decrease. Under these circumstances, producers may choose to continue to 

purchase and transship methyl bromide from foreign suppliers, to not re-establish methyl bromide 

production capacity, and to instead re-direct production lines to manufacture other, potentially highervalue chemicals. In brief, the market response to a methyl bromide plant failure and the subsequent 

response of domestic and foreign methyl bromide manufacturers could follow a number of different 

scenarios. Additionally, chemical manufacturers that are not currently producing methyl bromide 

would face geographical limitations to producing methyl bromide, since they would need to be 

located in the vicinity of a source of elemental bromine, found principally in underground brine 

deposits in Arkansas and Michigan. Quantitative analyses of these alternative scenarios are not 

provided in this report.

The potential for importing methyl bromide following a major domestic supply disruption depends on 

three key parameters: (1) the estimated total foreign production capacity for methyl bromide; (2) the 

amount of the foreign-produced methyl bromide that would be available to U.S. customers 

considering worldwide demand; and (3) the availability and capacity of specialized shipping 

containers needed to import methyl bromide taking into consideration the logistics of shipping methyl 

bromide from foreign suppliers to the U.S.
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1.2 Foreign Production Capacity

The amount of methyl bromide that can be imported into the United States depends on foreign 

production capacity and existing claims on that capacity (i.e., existing contracts between foreign 

manufacturers of methyl bromide and foreign consumers). As of 2006, Israel, Japan, and China were 

the only countries other than the United States that were still producing methyl bromide.1 The 

calculation of methyl bromide production capacity in China, Israel, and Japan is based on 

consumption data reported to UNEP. In 2009, the estimated amount of methyl bromide produced for 

all uses was 24,258 MT.

1.3 Worldwide Demand

Calculated worldwide demand for methyl bromide in 2013 is presented in Table 1 based on U.S. and 

foreign critical use, QPS, and feedstock demand. Demand for critical use for both U.S. and nonArticle 5 foreign users is assumed to be the amount authorized for critical uses in 2013 at the 23rd

Meetings of the Parties. The 2010 consumption of methyl bromide for controlled uses by Article 5 

countries was calculated based on data reported to UNEP for years 2006-2011. A steady rate of 

decline in demand since 2006 (approximately 760 MT per year) was projected out to 2013 to estimate 

future Article 5 consumption (see Section 3). Worldwide consumption of QPS methyl bromide is 

based on data reported in 2011 to UNEP. U.S. and foreign demand for feedstock methyl bromide, 

which are assumed to be the same for 2009, is based on UNEP (2010).2 

In summary, total worldwide consumption of methyl bromide in 2013 is based on 2013 critical use 

allocations, data reported by UNEP (2010), and data reported to the UNEP Ozone Secretariat,

3

and is 

projected to be approximately 18,335 MT (including U.S. consumption).

 

1

France discontinued methyl bromide production as of 2006 and Romania in 2004. Methyl bromide production 

in France and Romania was not included in the calculation of foreign production capacity because it is 

assumed that capacity for methyl bromide production no longer exists or could not be restored in a 

reasonable time frame in those countries. Romania closed its methyl bromide production facilities in 2004, 

and the Albemarle Port de Bouc facility in France has been reconfigured as of 2006 to produce fine 

chemicals and is no longer producing methyl bromide. (Sources: UNEP. 2006. 2006 Report of the Methyl 

Bromide Technical Options Committee: 2006 Assessment. Available at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/index.shtml.

2 UNEP. 2010. 2010 Report of the Methyl Bromide Technical Options Committee: 2010 Assessment. 

Available at: http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/MBTOC-AssesmentReport-2010.pdf.

3 UNEP Data Access Center. Last accessed November 20, 2012 at: 

http://ozone.unep.org/new_site/en/ozone_data_tools_access.php.
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Table 1. Estimated Total Worldwide Methyl Bromide Demand in 2013, in Metric Tons

Methyl Bromide Use

Annual Methyl 

Bromide Demand 

(MT)

U.S. Consumption of Critical Use Methyl Bromide a562

Non-Article 5 Foreign Consumption of Critical Use Methyl Bromide a49

Article 5 Consumption of Critical Use Methyl Bromide b1,636

Worldwide Consumption of QPS Methyl Bromide c9,680

Worldwide Consumption of Feedstock Methyl Bromide d6,408

TOTAL 18,335

Totals may not sum due to independent rounding.

a Critical Use methyl bromide, as authorized for critical use in 2013 at the 23rd Meetings of the Parties. Available at: 

http://ozone.unep.org/new_site/en/committee_documents.php?committee_id=1

b UNEP Data Access Center. International Methyl Bromide Consumption Data, 2006-2011. Last accessed November 20, 

2012 at: http://ozone.unep.org/new_site/en/ozone_data_tools_access.php

C UNEP Data Access Center. Methyl Bromide QPS Consumption Data, 2011. Last accessed November 22, 2012 at: 

http://ozone.unep.org/new_site/en/ozone_data_tools_access.php

d Demand in 2013 for feedstock methyl bromide was assumed to be equal to reported consumption for these applications in 

2009. Source: UNEP. 2010. 2010 Report of the Methyl Bromide Technical Options Committee: 2010 Assessment. 

Available at: http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/MBTOC-Assesment-Report-2010.pdf.

Foreign methyl bromide production capacity is estimated to be greater than total worldwide 

consumption of methyl bromide in 2013, based on 2013 critical use allocations, data reported by 

UNEP (2010),4data reported to the UNEP Ozone Secretariat.

5

 Therefore, foreign production should 

be adequate for meeting U.S. critical use needs, as well as the rest of demand worldwide, if U.S. 

methyl bromide production is shut down. The foreign production capacity estimate is not provided in 

this public document because that information could be used to estimate information about the 

production capacity of individual companies.

1.4 Availability of Shipping Containers

Imports and exports of methyl bromide require specialized shipping containers, or isotanks, of which 

there are a limited number. Because manufacturing new methyl bromide isotanks is a slow process, it 

may be difficult or impossible to quickly manufacture significant numbers of new isotanks in 

response to a production failure. As a result, in the event of a domestic supply disruption, the United 

States would have to depend on the existing capacity of isotanks to import methyl bromide for U.S. 

customers and transship methyl bromide for foreign customers from foreign manufacturers.

 

4 UNEP. 2010. 2010 Report of the Methyl Bromide Technical Options Committee: 2010 Assessment. Available at: 

http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/MBTOC-Assesment-Report-2010.pdf

5 UNEP Data Access Center. Last accessed November 20, 2012 at: 

http://ozone.unep.org/new_site/en/ozone_data_tools_access.php.
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While methyl bromide imports have the potential to offset all of the methyl bromide needed for 

domestic critical use (and formerly obtained from domestic production) for the estimated period, 

some short-term supply deficit would be experienced in the U.S during the timeframe required to 

complete the first import shipment if adequate domestic inventories are not available. 

The timeframe for future shipments of methyl bromide to the United States is also a crucial element 

in the analysis of importing methyl bromide to the United States following a major U.S. production 

failure. The shipping timeframe determines not only how long it will take for the first shipment of 

methyl bromide to arrive, but also the number of round trips (or “turns”) the isotanks can make in a 

given timeframe, thereby impacting both the speed at which methyl bromide can reach the United 

States and the total quantity of methyl bromide that can be imported before U.S. methyl bromide 

production is resumed. Based on information provided by industry representatives, it is estimated that 

it would take 15 weeks for the first shipment of methyl bromide to reach the United States following 

a domestic production failure. 

1.5 Estimate of Supply Shortfall

With sufficient foreign production capacity to meet U.S. and worldwide critical use needs, the 

limiting factor in the event of a major loss of domestic production capacity becomes the shipping 

container capacity available to import the foreign methyl bromide into the United States and the 

logistics of such shipments. Assuming that U.S. critical users will require the 562 MT authorized for 

critical uses in 2013, the available shipping containers and estimated shipping capacity would be 

adequate to fulfill U.S. critical use methyl bromide demand; however, ramping-up foreign production 

and adjusting shipping routes to transition the United States from a major exporter to a major 

importer would take time. Therefore, the United States would be without newly produced or imported 

methyl bromide for a certain time period—estimated to be 15 weeks—after a domestic production 

failure (based on information from industry representatives). Meeting demand during this time period

would require domestic methyl bromide inventories of approximately 3 to 70% of the annual 2013

demand or between 17 and 394 MT. These inventory estimates represent the range of critical use 

demand over the time period preceding the first shipment of imports, depending on the season in

which the major loss of domestic production capacity occurred. The season in which the domestic 

supply disruption occurs will affect the inventory needed because the rate of methyl bromide use is 

not constant throughout the year.

In order to estimate the supply chain factor for 2013, the following assumptions are retained from the 

previous analysis: 

1. Foreign production of methyl bromide would be sufficient to meet U.S. critical use needs (as 

well as the rest of worldwide demand) should U.S. methyl bromide production be shut down. 

2. Given the availability and capacity of methyl bromide shipping containers and shipping 

logistics, it would take 15 weeks for the first shipment of methyl bromide to reach the United 

States following a domestic production failure.

Using these assumptions and data presented in Table 2, we estimate the necessary domestic methyl 

bromide inventories during the 15-week period in which the U.S. would be without newly produced 

or imported methyl bromide, in the event of a major loss of domestic production capacity. We use the 
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data on seasonal production of critical use methyl bromide from 2006 to 2011 to calculate the average 

proportion of methyl bromide produced per week in each quarter. Quarterly production data for 2006 

to 2011 show consistent patterns in the level of production throughout the year; these are likely the 

result of normal variation in methyl bromide demand at different times of year. For example, critical 

use methyl bromide used for pre-plant and post-harvest applications would be in the highest demand 

immediately prior to the growing season. The average proportion of methyl bromide produced per 

week in each quarter is multiplied by the allocated amount of critical use methyl bromide 

consumption in the U.S. in 2013 (562 MT) and 15 weeks to compute the average 15-week demand for 

methyl bromide in 2013. The resulting upper and lower bounds reflect seasonal differences in the 

level of production and critical use demand.

Table 2. 2013 Supply Chain Factor Calculation 

Quarter

Average 2013 15 week 

demand (MT)

(A)

Percent of 2013 

demand

(B)

1 394 70%

2 148 26%

3 90 16%

4 17 3%

Notes:

A = Average proportion of CUE pre-plant and postharvest methyl bromide produced per week in quarter 

562 MT (2012 U.S. consumption of critical use methyl bromide) × 15 (time required to obtain new foreign supplies of 

methyl bromide).

B = A ÷ 562 MT (2012 U.S. consumption of critical use methyl bromide). 

Domestic inventory requirements vary depending on the time of year in which a disruption occurs. If 

a supply disruption occurs in the fourth quarter of the year, the inventory requirement is expected to 

be at the lower end of this range. If the disruption occurs in the first quarter, the inventory 

requirement is expected to be at the higher end of the range. For a disruption during the second or 

third quarters, the required inventories would fall between the two extremes. EPA estimates that 

critical use production in the first 15 weeks of each year (the peak supply period) currently accounts 

for approximately 70% of annual critical use methyl bromide demand. EPA, therefore, estimates that 

the peak 15-week shortfall in 2013 could be 394 MT.

1.6 Limitations

There are several limitations associated with the estimate of 17 MT to 394 MT of inventory needed to 

meet a supply shortfall resulting from a sudden domestic supply failure. First, it should be noted that 

the pre-2005 inventory is held by multiple companies, and the sale of that inventory is governed by 

market forces. Hence, in the event of a production failure, the stockpile could be purchased by any 

user (i.e., critical use/non-critical use, QPS, feedstock, or foreign users). Most likely, the stockpile 

would go to the user willing to pay the highest price in time of short-term global shortage. Second, 

there may also be existing contract agreements that must be honored. As a result, there is no 

guarantee that the existing pre-2005 inventory of methyl bromide will flow towards U.S. critical uses 

in the case of a production failure. Third, it is not clear that a contingency plan exists amongst the 
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various methyl bromide producers as to how to respond to a major supply disruption. Thus, the 

reallocation of shipping containers to import methyl bromide into the United States may not occur 

smoothly over the first weeks or months while the various manufacturers, shippers, and customers 

sort out their arrangements. Finally, characteristics such as the purity of the pre-2005 inventory of 

methyl bromide could affect users’ ability to use this inventory to meet their needs for methyl 

bromide; however, these characteristics are not known. For example, some of the methyl bromide 

held in inventory may be intended for pre-plant uses may be pre-mixed with chloropicrin in 

compressed gas cylinders and therefore could not be used for post-harvest fumigation.

 
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2. Estimate of Future Pre-phaseout Methyl Bromide Inventory

In past supply chain factor analyses, in order to estimate the future available methyl bromide 

inventory, EPA applied a simple linear fit of past pre-phaseout methyl bromide inventory using 

Microsoft Excel software. As shown in Table 3 and Figure 1 below, this method predicts negative 

inventory amounts for 2012 and 2013. These projections are no longer useful in projecting amounts 

be held by companies in the United States as of January 1, 2013.

Table 3. Linear Projection of Methyl Bromide Inventory, in Metric Tons, 2004 - 2013

Year Reported Projected

2004 16,422 14,581

2005 12,994 12,719

2006 9,974 10,856

2007 7,941 8,993

2008 6,458 7,131

2009 4,273 5,268

2010 3,063 3,406

2011 1,803 1,543

2012 1,249 -320

2013 -2,182

Figure 1 shows the reported and projected inventory graphically.
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Figure 1. Projected Linear Trend of Methyl Bromide Inventory, 2004 - 2013

As shown in Table 4, the drawdown of pre-phaseout inventory for all uses has never exceeded 42% of 

the prior year’s inventory and has never been less than 16%. In absolute terms, largest amount of 

annual drawdown on inventories was 2,303 MT. In the proposed rule, EPA estimates that 42% (more 

than has been recorded to-date) of the amount on-hand at the beginning of 2012 will be sold in 2012. 

Table 4. Drawdown on U.S. Pre-phaseout Inventories, 2006 – 2012

Year

On-Hand at 

Beginning of Year

(MT)

Drawdown 

During Year

(MT)

Percent 

Drawdown

On-Hand at 

End of 

Year (MT)

2006 9,974 2,303 23% 7,671

2007 7,671 1,213 16% 6,458

2008 6,458 2,185 34% 4,273

2009 4,273 1,210 28% 3,063

2010 3,063 1,260 41% 1,803

2011 1,803 554 31% 1,249

2012 1,249 634 

(Projected)

42%

(Projected)

615 

(Projected)

Note: Drawdown for 2012 projected based on the highest percentage drawdown recorder to-date. 

-5,000

-2,500

0

2,500

5,000

7,500

10,000

12,500

15,000

17,500

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Reported

Projected
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Based on these projections, no more than 634 MT of pre-phaseout inventories would likely be sold in 

2012 and 615 MT will be on-hand at the beginning of 2013.

In the proposed rule, EPA estimates the amount of inventory used in 2012 on critical uses. On 

average only 59% of the CSAs allocated for a control period are reported as sold in that control 

period. The highest proportion of sold-to-allocated CSA was 70% as recorded in 2011 (see Table 5).

In the proposed rule, EPA projects that 70% of the amount of CSA allocated in 2012 would be sold 

for critical uses. The result is an estimate of 184 MT of pre-phaseout methyl bromide inventories sold 

for critical uses in 2012.

Table 5. Critical Stock Allowance Usage, 2006 - 2012

Year Allocated CSA 

(MT) Sold CSA (MT)a Sold CSA to Allocated CSA

2006 1,136 784 69%

2007 1,915 922 48%

2008 1,730 1,047 61%

2009 1,919 1,127b59%

2010 1,028 613 60%

2011 555 386 70%

2012 263 184 (Projected) 70% (Projected)

Average 61%

a Methyl Bromide 2005-2011 Accounting Frameworks. Available at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0277-0059

b According to the accounting framework, 1,135 MT of CSAs were used. Reports received after the Framework was 

submitted to UNEP indicate that 1,127 MT were used.

Since 2006, the amount of prior year inventory used through the expenditure of CSAs has ranged 

from 8% to 26% (see Table 6). Based on the projection in Table 5 of 70% of allocated CSA being 

sold in 2012, EPA estimates that 15% of the prior year inventories will be used through expenditure 

of CSAs. 

Table 6. Expenditure of Pre-phaseout Methyl Bromide Inventories and Sold CSA, 2006 

- 2012

Year

On-Hand at 

Beginning of Year

(MT)

Sold CSA 

(MT)

Percent 

Expended

2006 9,974 784 8%

2007 7,671 922 12%

2008 6,458 1047 16%

2009 4,273 1127 26%

2010 3,063 613 20%

2011 1,803 386 21%

2012 1,249 184 

(Projected)

15%

(Projected)
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In the proposed rule, EPA estimates the amount of pre-phaseout inventory used in 2012 on noncritical uses. The annual amounts of pre-phaseout methyl bromide inventories used for non-critical 

uses have varied with no discernible pattern since 2006 (see Table 7).

Table 7. Expenditure of Inventories for Non-critical Uses, 2006 - 2012

Year

On-Hand at 

Beginning of 

Year (MT)

Non-Critical 

Uses (MT)

Percentage of NonCritical Uses to 

Inventories

2006 9,974 1,249 16%

2007 7,671 561 9%

2008 6,458 1,139 27%

2009 4,273 267 9%

2010 3,063 647 36%

2011 1,803 168 13%

2012 1,249 450 (Projected) 36% (Projected)

Based on Methyl Bromide 2005-2011 Accounting Frameworks. Available at: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0277-0059

In 2010, 36% of the total prior year inventory was sold for non-critical uses. On a weight basis, this 

was equal to 647 MT. In 2006, much more inventory (on a weight basis) was sold for non-critical 

uses, 1,249 MT, but this comprised only 16% of the total start of year inventory that year. As a result, 

the average proportion of prior year inventories of 17% does not provide enough information for 

estimating the likely amount of inventories used for non-critical uses in 2012. Using the highest 

proportion of inventories used for non-critical uses between 2006 and 2011, the proposed rule

estimates that 36% of the total start of year inventory would be used for non-critical uses in 2012. 

This is equal to 450 MT.
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3. Projection of Article 5 Methyl Bromide Consumption

Table 8 presents the projection of Article 5 methyl bromide consumption through 2013. Article 5 

consumption in 2002 through 2011 is from UNEP Data Access Center (2012). The consumption 

values for 2012 and 2013 are projected based on the 2006-2011 consumption trend.6 The 2006 

Assessment of the Methyl Bromide Technical Options Committee supports this projection method. 

As shown in Table 8, consumption in 2013 is projected to be about 1,636 MT. This value is used to 

calculate the total worldwide methyl bromide demand in 2013.

Table 8. Methyl Bromide Consumption in Article 5 Countries (MT), 2002 - 2013

Year

Reported Article 5 

Consumption of Critical 

Methyl Bromide

Projected Article 5 

Consumption of Critical 

Methyl Bromide

2002 12,579

N/A 2003 11,755

2004 10,531

2005 9,497

2006 6,952 6,949

2007 6,224 6,190

2008 5,495 5,431

2009 4,435 4,672

2010 4,038 3,913

2011 3,164 3,154

2012 2,395

2013 1,636

 

6 There seems to be a clear break in the trend between 2005 and 2006, and as a result, we projected the Article 5 

consumption data for 2012 and 2013 using data from 2006 – 2011.