EFCTC COMMENT ON ILLEGAL IMPORTS AND THE HFC PHASE-DOWN

A recent news feature has raised the issue of illegal imports of HFCs, with such demand attributed to the effects of the HFC cap and phase-down. The news feature noted reports of illegal imports and evidence from online auction sites. We are all aware that apart from being illegal, such imports may not be from reputable sources. Purchasing from reputable source in re-usable containers ensures the integrity of the supply chain and supports safety in use and technical performance. The contamination of refrigerants with methyl chloride, or counterfeit refrigerant such as pure methyl chloride, was highlighted several years ago and we do not want a repeat of such incidents. EFCTC and its member companies had been aware of the possibility of illegal imports and raised the issue with the European Commission, contributing to the instigation of the recent report for the Commission that found little evidence of large scale illegal imports. However, this report is based on an analysis of historical data, whereas the news feature is a view of the current situation.

Another recently reported effect of the cap and phase-down has been the completely unacceptable use of HFC-32 (a flammable A2L refrigerant) to service air-conditioners designed for and containing HFC-410A resulting in safety issues, and non-compliance with applicable standards. Many suppliers of air-conditioners now offer systems designed for use with HFC-32 (GWP about one third of HFC-410A) and this is one of the routes to making sure more tonnes of refrigerant are available under the cap.

EFCTC together with other trade associations supports and encourages the use of lower GWP alternatives to R-404A/ R-507A, for retrofit and new systems, and there are many examples and case studies for alternatives to R-404A as well as the use of a range of lower GWP solutions for applications such heat pumps, chillers, commercial refrigeration, as well as air-conditioning.

We encourage all users and purchasers of refrigerant to purchase from reputable sources to maintain the integrity of the supply chain and support safety in use and technical performance, and adhere to the F-Gas Regulation and maintain the integrity of the cap and phase-down. Enforcement agencies can support the industry by working to prevent illegal imports of HFCs. The whole industry needs to work together by focusing on the appropriate use of lower GWP refrigerants such as HFC-32, HFC/HFO blends and HFOs to maximise the tonnes of HFC based refrigerants available under the cap.