Raising awareness of illegal trade and how individuals and can work to deal with the issue is an important step to reducing the illegal trade, but industry needs the wholehearted support of compliance enforcement initiatives to help prevent the illegal trade. EFCTC acknowledges the steps are being taken by the European Commission, Member States and their customs officials and is ready to support these efforts. This is an issue that will need continuing and collaborative efforts over a number of years.

EFCTC programme to fight against this illegal trade: One of its features include an “Action Line” that will permit any individual to report (in any language) alleged suspect HFC offerings confidentially to a trusted and independent contractor. The results of this program will create a more detailed picture of the illegal HFCs supply chain, which can be then shared by the independent contractor with the EU/national authorities, for enforcement. Full details of how to access the “Action Line” can be found at:

The EIA report Doors Wide Open: Europe’s flourishing illegal trade in hydrofluorocarbons (HFCs) provides comprehensive research into the illegal HFC trade with non-quota HFCs entering the EU directly from China or via Russia, Ukraine, Turkey and Albania. Key EU entry points and hotspots for illegal trade are thought to be Bulgaria, Croatia, Denmark, Greece, Italy, Latvia, Poland and Malta. EIA’s analysis of European customs data indicates that bulk HFC imports in 2018 were too high for compliance with the 2018 quota at 16.3 MtCO2e above the available quota. In addition, there is clearly some level of cross-border smuggling of HFCs which is under the radar of customs authorities. There are significant discrepancies between Chinese export and European import data that could indicate fraudulent import declarations.
This report complements the work that is being carried out by EFCTC in raising awareness of this issue and its consequences, and the level of illegal trade is consistent with previously reported estimates – see EFCTC March 2019 Newsletter item.

The European Commission informed EFCTC that it is taking the matter of illegal trade very seriously. Amongst other initiatives it indicated that an electronic system is being set up allowing automatic checks of incoming shipments, the identity and registration status of shipping companies as well as their allocated quota. According to the Commission, the system developed under the “Single Window for Customs Initiative” should become available in 2020.
AFCE calls for greater vigilance on the source of HFCs. It warns about the upsurge and risk of HFC-type refrigerant offerings whose sources and quality are unreliable and provides guidance on how to identify illegal refrigerants.
Source: Rpf La revue des professionnels du froid et de la climatisation

In Poland, officers of the Tax Administration Chamber in Lódz discovered the illegal refrigerant during customs clearance of two consignments from Ukraine. The total weight of 25.5 tonnes included R-134a, R-404A and R-410A refrigerants in illegal disposable cylinders and was confirmed as being outside of the European quota system. It may be the largest seizure in Europe.
Source: Cooling Post

In Bulgaria, about 1.1 tonnes of HFCs R-134a and R-404A in disposable cylinders were seized by customs officers in a truck at the border.
Source: Cooling Post 

HCFCs are being illegally imported as well. In February, Bulgarian customs officers seized 13.3 tonnes of HCFC-22 being imported.
Source: Cooling Post

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