Illegal Trade Round-up

In this round-up: Since the last round-up in November 2025, there are new policies and initiatives by member states to deter and detect illegal trade and disrupt the criminal gang networks responsible for much of the imports. Industry trade associations are calling for greater enforcement, and significant quantities of refrigerant have been seized.  

Globally, UNEP-OzonAction organised Montreal Protocol Dialogue on Action against Illegal Trade brought together global and regional enforcement entities working on enforcement. In an article  Enforcement for Climate Action: Why Customs Matters More Than Ever UNEP-OzonAction commented that ‘Yet the enforcement landscape is becoming more complex. Supply chains are evolving with an increasing number of substances controlled under the Montreal Protocol and blends; these substances may be misdeclared, documentation can be falsified, and illegal transboundary movements continue to challenge national authorities.’ The World Customs Organization (WCO) Illicit Trade Report 2024 reported that there were 134 incidents of trafficking ozone-depleting substances (ODS) and hydrofluorocarbons (HFCs) recorded in 2024, marking a 5% increase compared to 2023. The increase in ODS and HFC seizures in 2024 was accompanied by a 96% rise in the total quantity seized compared to 2023. HFCs were the most frequently intercepted substances accounting for 160 tonnes. For 2025, the WCO reported that operation DEMETER XI, the flagship enforcement operation targeting the illicit trade in waste and substances controlled under the Montreal Protocol, has delivered record-breaking results, underscoring Customs’ critical role in protecting society and safeguarding the global supply chain. The operation brought together a record 120 Customs administrations worldwide, resulting in seizures of 168 tonnes of ozone-depleting substances (ODS) and hydrofluorocarbons (HFCs). As part of DEMETER XI, the Bulgarian National Customs Agency seized 4,810.4 kg of illegal refrigerants (Bulgarian News Agency). In 2025, a 12-month worldwide operation Custos Viridis, coordinated by Europol targeted organised crime networks involved in waste and pollution crime uncovered 398 tonnes of fluorinated greenhouse gases (Cooling Post). 

The EU Environmental Crime Directive (ECD) 2024/1203 had a requirement to be transposed into national law by 21 May 2026, although this process was not completed by the deadline (see eur-lex.europa.eu). The Directive establishes minimum rules with regards to the definition of criminal offences and penalties in order to protect the environment more effectively, as well as measures to prevent and combat environmental crime. Article 3 Criminal offences includes ‘the production, placing on the market, import, export, use, or release of fluorinated greenhouse gases, whether alone or as mixtures, as referred to in Article 2, point (a), of Regulation (EU) 2024/573 of the European Parliament and of the Council ( ) or the production, placing on the market, import, export or use of products and equipment, and parts thereof, containing fluorinated greenhouse gases or whose functioning relies upon those gases as referred to in Article 2, point (b), of that Regulation, or the putting into operation of such products and equipment.’  

Member state actions. Italy has strengthened penalties for violating the regulations on fluorinated gases following implementation of Directive 2024/1203 (LaRPF). In Germany the illicit F-gas trade has become the focus of attention amongst German government ministers and authorities in an attempt to disrupt the illegal activities (Cooling Post). Also in Germany, the revision of the German Chemical Act including the transposition of the requirements of the ECD 2024/1203 are currently still in process, but about to be concluded. The Greek police has dismantled a criminal organization that was illegally importing refrigerants from Albania (LaRPF) and in Spain more than 48,000 kilos of illegal fluorinated gases were seized in a joint operation by the Policía Nacional and the Tax Agency’s Customs Surveillance Service, exposing a sophisticated criminal network operating beneath Europe’s climate regulations (inspain.news and Agencia Tributaria). Also in Spain, authorities arrested 10 people after uncovering and dismantling a criminal organisation responsible for the illegal trade of more than 15 tonnes of F-gases (Cooling Post). In Bulgaria, authorities have arrested members of an organised criminal group accused of illegally importing and distributing HFC refrigerants, money laundering and tax crimes (Cooling Post). 

Industry trade association concerns. The Spanish refrigeration association, AEFYT, warned of the continuing illegal trade in refrigerant, particularly selling banned R404A as legal HFC blend substitutes (Cooling Post). AREA, in a position statement, commented that two issues increasingly threaten this transition to low GWP alternatives: the illegal trade of refrigerants and widespread uncertified work (I&F Online). Three German industry organizations—BIV (Federal Guild Association of Refrigeration Air Conditioning Heat Pumps), VDKF (Association of German Refrigeration and Air Conditioning Companies), and the Federal Technical School for Refrigeration and Air Conditioning Technology, in a joint statement, issued in advance of the revision of the German Chemicals Act (ChemG) urged  tougher action against the illegal refrigerant trade (Refindustry). 

Illegal refrigerant seizures (not exhaustive) 

December 2025 to June  2026 Reports of Illegal Refrigerants seized in the EU
December	Poland	36 kg	R-404A  and R-134a seized at border following truck inspections	Cooling Post
	Spain	48 tonnes	4700 cylinders with no traceability	Agencia Tributaria
February	Italy	24 tonnes	1,100 cylinders of R-134A and 300 cylinders of R-410A with no quota,	Cooling Post
April	Poland	54 kg	R-134a seized at the border	Cooling Post
May	Greece	2418 kg	Seized 234 cylinders	Cooling Post
June	Bulgaria	1500 cylinders	HFCs seized in a warehouse	Cooling Post