About Illegal HFCs

The European Union adopted Regulation 2024/573, the F-gas Regulation in 2024 to reduce the emissions of fluorinated greenhouse gases in the EU. This regulation progressively reduces the quantity of hydrofluorocarbons (HFCs*) that can be placed on the EU market using a quota system monitored via the F-gas Portal.

Companies producing or importing HFCs in the EU receive specific HFC quota allocations for any given year. These quota need to be bought and paid for by the companies for an equivalent amount of HFCs to be allowed on the market, however the amount of available quota will gradually decline as part of the phase-down prescribed by the F-gas Regulation.

Production of HFCs in the EU is capped and starting in 2025 producers receive rights equivalent to 60% of their average annual production from 2011 to 2013. This rate will decline to 15% by 2036. More information can be found here.

Smugglers of illegal HFCs do not only circumvent safety standards, but also this quota system. They can therefore offer their product at dumping prices, causing unfair competition to compliant European businesses.

*HFCs are used as refrigerants in air conditioning, heating, cooling and various other applications.

Illegal trade of HFCs

One of the unintended side-effects of imposing this quota system and reducing HFC availability has been the spread of a black-market for HFCs in the EU. Illegal HFC refrigerants are being smuggled into the EU in a variety of ways, in order to:

Circumvent the EU quota system and the tax that comes with it

Sell refrigerants under market prices

Avoid obligations related to the strict safety and environmental standards

There are serious risks associated with the use of illegal HFC refrigerants.

IMPACT OF ILLEGAL TRADE

Industrial and consumer safety

HFCs are liquefied gases under pressure that need to be handled with care. Refrigerants that do not comply with established EU regulatory and safety requirements can pose a serious risk to the health and safety of installers, users and the general public.

Climate action objectives

Illegal trade results in additional HFC emissions that are associated with global warming and ultimately undermines the objectives of the F-gas Regulation and EU’s climate goals.

R&D and innovation

Companies across the whole supply chain have invested significant resources to achieve the objectives of the F-gas Regulation. The uncertainty surrounding the enforcement of the F-gas Regulation, however, may discourage private sector innovation and resources for developing new technologies for new substances with lower Global Warming Potential.

EFCTC is actively collaborating with OLAF and member states’ customs authorities to disrupt illegal imports
into the EU.

Archive of information materials

EFCTC has made a large number of relevant and useful documents and materials over the past years. You may browse previous campaign materials below:

Illegal imports of HFCs into the EU: why now? (2019)
Protect your business: buy refrigerants from safe sources (2019)
The impact of illegal imports (2019)
European Climate Leadership requires strong enforcement (2020)
The Biggest Black Market You’ve Never Heard Of (2020)
The untold story of HFCs & organised crime (2020)
5 Steps EU member states can take to stop illegal HFCs (2020)
The cold, hard truth behind EU refrigerants (2020)
Illegal trade of HFCs hampers climate efforts (2020)
Tool for Customs: Guidance on Confiscated HFCs and EU Waste Regulations (2020)

Disclaimer: while the documents in the archive contain useful information, they might not be up to date with current regulations.