Illegal trade in refrigerants

The illegal trade in ozone-depleting substances and greenhouse gases used in the cooling sector remains a significant obstacle to international efforts seeking to limit the worst impacts of climate change. We have almost 30 years of experience investigating and exposing this criminal trade and, with a steady increase in hydrofluorocarbon (HFC) smuggling in Europe as a result of an EU phase-down of these chemicals, we will continue monitoring and investigating this illegal trade, pushing for strengthened enforcement, working for better engagement on the issue from customs and campaigning for an effective licensing system for HFCs.

The problem

While the Montreal Protocol has been lauded as the most successful environmental treaty, illicit trade in ozone-depleting substances (ODS) which emerged in the mid-1990s remains a challenge.

Smuggling of chlorofluorocarbons (CFCs), particularly for the refrigerant market, began following the first wave of CFC phase-outs, rapidly growing to a volume of 38,000 tonnes a year at its peak and continuing to this day.

Low risks and high profits make the illegal refrigerant trade attractive to  criminal networks. Yet it is often not a priority for enforcement agencies and penalties are usually minor for a crime that costs governments and legitimate businesses millions in lost revenues and results in significant emissions of ozone-destroying and greenhouse gases.

  • 1990's

    Our undercover investigation exposed the illegal trade of CFCs putting the

    spotlight on Europe and USA to act
  • Training

    We have supported improved enforcement through training workshops

    improving the work of enforcement officers
  • 2018

    Our report exposed the widespread illegal production and use of CFC-11 in China and

    brought the issue of illegal trade back into view

Moving forward

In addition to ongoing illegal trade in ODS we are now seeing hydrofluorocarbon (HFC) smuggling in Europe as a result of the f-gas/">EU wide phase-down of these chemicals. HFCs do not destroy the ozone layer but are powerful greenhouse gases that contribute to global warming.

The EU F-Gas Regulation aims to cut HFC use by 79 per cent by 2030. Since 2017, HFC prices have surged  in Europe, alongside supply cuts.  Poor enforcement and regulatory loopholes have fuelled significant levels of illegal trade, in particular along the porous eastern and southern EU borders.

EIA will continue to monitor, investigate and expose the illegal trade in HFCs, advocating strengthened enforcement, improved customs engagement and an effective HFC licensing system.

Simultaneously, EIA will be working to strengthen the enforcement and compliance regime of the Montreal Protocol. The recent discovery of ongoing large-scale production and use of CFC-11 has brought to light the need to re-examine the policies and institutions of the Montreal Protocol to ensure its compliance and enforcement regime is fit-for-purpose. This is particularly urgent given the entry into force of the Kigali Amendment in 2019, and the new challenges this brings as a global phase-down of HFCs begins.