Actions at European level to combat the illegal trade of HFCs

Various actions to tackle illegal imports of HFCs in the European Union are progressively being implemented: raising awareness of policy makers, good practice guidelines and a “single window” at the disposal of customs in particular.
The illegal trade of HFC refrigerants continues to a burning issue. Even though this figure is disputed by the European Commission, it has been estimated by refrigerant producers such as Chemours that the illegal trade in HFCs could have accounted for as much as 20% of the annual F-gas phase down quota in 2018 [1].

During a F-gas Roundtable in Brussels on October 14, 2019 hosted by EPEE, the group of refrigerant producers, EFCTC, recalled that beyond undermining the European F-gas Regulation’s aim to phase down HFCs, “use of illegal HFCs carries with them safety, health and environmental risks and must be stopped as soon as possible”. However, action taken so far by the European Commission and member states to tackle the illegal trade in HFCs has been described as an “extremely positive start” by EFCTC’s chairman Nick Campbell. (2) At the Roundtable, Bente Tranholm-Schwarz, deputy Head of Unit in DG Climate Action in the European Commission, stressed that the issue needed to be addressed by the Council of Ministers and that discussions should take place with experts from Member States and enforcement authorities [2]. This includes working with Poland to develop best practice guidance for customs. On the eastern border of the EU, Poland is indeed one of the countries on the frontline of the illegal refrigerant trade. In this regard, faced with what Poland has described as a “massive inflow of illegal HFCs”, the Polish National Revenue Administration and Customs Authorities were prompted to take action in the second quarter of 2018. During that time, customs officers intercepted 425 separate shipments that were in contravention of the European F-gas Regulation. This included smuggling of HFCs, non-compliant labelling and importation outside of the quota system. In total, this involved over 107 tons of HFCs [3].

Other actions by the European Commission concern the development of the customs “Single Window” automatic control system with DG Clima for taxation and customs union to enable interactive verification of imports at the border [4]. This system, which should be operational by 2021, will allow a real-time count of the available quota for each importer.

EC actions also include discussions on data sharing with China and Turkey which are considered – with Russia, Ukraine and Albania – to be countries from which non-quota HFCs enter directly the EU.