11 November 2019

In this round-up, Action Line activities; “so-called returnable cylinders” on sales platforms; F-Gas Roundtable discussions; the EFCTC decision tree for customs and enforcement agencies is available; discussion of illegal trade at the committee established under Article 24 of Regulation 517/2014; 17th AFCE symposium- agreement or disagreement; and a summary of seizures of illegal HFCs and enforcement.

As a result of the EFCTC Action Line and dedicated investigation resource, 17 reports are currently being investigated, already some have been shared with Member State authorities.

One result of the actions of industry and authorities raising the awareness of the use of illegal disposable cylinders for HFCs is the adoption by some illegal traders of “so-called returnable” cylinders on sales platforms. Potential purchasers should not be fooled - to comply with the F-Gas Regulation, according to guidance issued in the UK, containers are only classed as refillable if there is a process for customers to return containers for refilling. In addition, typically these cylinders are not certified for transport in the EU.

EFCTC members participated in the F-gas Roundtable on 14th October in Brussels. Bente Tranholm-Schwarz, Deputy Head of Unit in DG Climate Action, concentrated her comments on illegal trade in HFCs stressing that “every kilogram entering the EU illegally is one kilogram too much.” She detailed the findings from a Commission study of European import/export statistics and noted that these data are consistent with the EU HFC quotas up to 2018, indicating that customs evasion is the main method for illegal HFCs. EFCTC welcomes the extensive list of actions being undertaken by the Commission and Member States to tackle this problem of illegal trade in HFCs. This is extremely positive start. The press release can be read here

EFCTC has produced a decision tree for customs and enforcement agencies. This tool aims to facilitate the identification of HFCs that are subject to the F-Gas quota and suggest appropriate enforcement action. The decision tree is being translated into European languages.

See the EFCTC website dedicated section on illegal trade for the latest information, news and press releases.

At the September 2019 meeting of the committee on fluorinated greenhouse gases established under Article 24 of Regulation 517/2014, the Commission (COM) gave an update and emphasized the need to continue focusing on tackling illegal trade and stressed that MS should reassess that their penalties are “effective, proportionate and dissuasive” on a regular basis. COM also gave a brief update from a Training Workshop under the Customs Project Group for F-gases, which aim at establishing a guide with recommendation for customs on their work on the F-gas Regulation. Member States were reminded to register customs in the F-gas Registry to facilitate their enforcement activities. COM informed that updated CN/TARIC codes are expected to be finalised and adopted by the end of the year. MS discussed and shared their experience related to enforcing the HFC phase-down. The meeting minutes are here.

Illegal trade was a major discussion topic at the 17th AFCE symposium which took place on October 2nd in Paris. While companies have respected their quotas, according to the data submitted, industry pointed out that illegal trade is substantial and that customs evasion and smuggling are occurring. The Commission speaker apparently pointed out that they cannot measure what they cannot see. Further information about the discussion can be found here. All the presentations at the symposium are available at 

KRIMI Sweden's car dealership Association Motorbranschens Riksförbund (MRF) has warned the industry about the unauthorised import, sale and handling of HFCs (see Motor Magasinet).

Seizures of illegal HFCs and enforcement: NETHERLANDS: The government’s human environment and transport inspectorate has pinpointed reducing greenhouse gas emissions and halting the illegal trade in HFCs as key targets in its future plans (see Cooling Post). POLAND: The efforts to detect and stop illegal trade in HFCs by Poland have been acknowledged by this year’s Montreal Protocol Award for customs and enforcement officers. During 2018 Polish customs detected over 107 tonnes of non-compliant HFC refrigerant (see Cooling Post). THE MONTREAL PROTOCOL AWARDS will acknowledge the efforts of enforcement officers in 24 countries who seized over 250 tonnes of illegal refrigerants (see Cooling Post). Poland is the champion with 72 per cent of all seizures under the global customs award (see UNEP news story). SPAIN: The Civil Guard environmental protection service, has won awards presented by United Nations Environment Programme’s OzonAction for its actions against the illegal trade in HCFC and HFC refrigerants (see Cooling Post).

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