Update on illegal HFC trade in Europe

An EIA investigation highlights the different smuggling routes used to illegally import HFCs into Europe and shows which refrigerants are most frequently sold in this way. 

As part of the F-Gas regulation, the European Union must reduce the use of gases with a high global warming potential (GWP). Following the ban on HCFC and CFC gases, HFCs must also be drastically reduced, with some key milestones. In particular, from January 1, 2020, fluorinated gases with a GWP of 2500 or more are prohibited for the servicing and maintenance of refrigeration equipment, with a few exceptions, such as for military equipment or equipment intended for cooling applications below -50°C. 



However, this system has led to the emergence of an illegal trade in refrigerants, as:some companies are importing HFCs outside the quota.  


The Environmental Investigation Agency (EIA) published an investigation last July into the illegal trafficking of HFCs in Europe.  


EIA investigators posed as middlemen seeking to supply Western European clients with HFCs outside of regulatory quotas. They identified two main smuggling routes through Romania: one from Ukraine, the other from Turkey. In one of the of illegal import methods identified, refrigerants are produced in China and imported in bulk to Turkey, where they are then divided into smaller batches to be transported to Romania, probably via Bulgaria. 

EIA investigators could thus have obtained 17.5 tonnes of out-of-quota HFCs, which represents 31,255 tonnes of CO2


The investigation therefore confirms Romania's role as an entry point and transit zone for illegal HFCs destined for countries such as Germany, Spain, Belgium, Italy, France or England. Corruption also seems to play an important role in the passage of goods across the Ukrainian border. Four intermediaries contacted by the EIA reported having paid bribes to customs officials, worth € 20 to € 30 per bottle of refrigerant.  


According to the same sources, R404A is an easily smuggled refrigerant. The report also focuses on figures of illegal refrigerants seized by EU member countries. R404A represents 34% of the refrigerants seized, followed by R134a (19%), and R32 (11%). 


The report also gives figures on legal imports of HFCs in the European Union between 2016 and 2020. These have steadily decreased between 2016 and 2019 and increased slightly in 2020.  


Figures for illegal imports are difficult to obtain, however they can be estimated from figures for exports from China, as the country is not subject to the F-Gas Regulation. The report finds that exports to neighbouring countries of the European Union, such as Turkey, Russia and Ukraine, have increased by 96% since 2014. 


Thus, Turkey reportedly imported an average of 38 tonnes of HFCs between 2007 and 2013. For comparison, this figure would rise to 1,002 tonnes in 2018.  


In that year, the difference between China-reported exports and EU-reported imports was different: the number of exports reported by China was greater than the number of imports reported by the European Union. This difference was smaller in subsequent years (2019 and 2020). 


 According to the EIA, this illegal trafficking poses a threat to the climate objectives of the European Union. Although the scale of illegal HFC trade cannot be accurately estimated, EIA believes that it is significant, probably between 20 and30 per cent of legal trade. 


To view the report, please follow this link.