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Illegal HFC smuggling

Author
Adrien Noiran Bezunartea
Publication Date
May 9, 2025

As Europe accelerates its transition to low GWP refrigeration, criminal networks are threatening progress by illegally importing high impact HFCs. AFS Cooling is here to help you safeguard compliance, protect your operations, and support Europe’s climate goals.

Illegal HFC Smuggling in the EU: A Growing Threat to Climate Goals

Hydrofluorocarbons (HFCs) play a critical role in refrigeration, air conditioning, and heat pump systems. Introduced as safer alternatives to ozone depleting CFCs, many HFCs still have global warming potentials thousands of times greater than CO₂. In response, the EU adopted Regulation EU 2024/573, setting a clear timeline toward a full HFC phase out by 2050.

Despite these rules, a recent Environmental Investigation Agency (EIA) report (April 2024) has uncovered a sophisticated smuggling network moving banned HFCs from Turkey and China into the EU, primarily via Bulgaria. These illicit consignments are distributed across member states - including France, Italy, Spain, Portugal, Greece, and Germany - undermining legal markets and climate objectives.

Smugglers employ several tactics to evade detection:

  • Mislabeling banned HFCs as HFOs: Lower GWP HFOs face lighter regulation, making them the perfect cover for prohibited refrigerants.
  • Use of disposable cylinders: Although banned, these cylinders are easy to conceal, transport, and offload.
  • Online marketplaces: Unregulated e commerce platforms facilitate sales without compliance checks.

These illegal flows have dual impacts:

  1. Environmental setback: Unchecked HFC emissions stall Europe’s greenhouse gas reduction targets and delay adoption of cleaner refrigerants.
  2. Market distortion: Compliant businesses investing in sustainable technologies face unfair competition from cheap, illicit supply chains.

Countries like France and Italy feel this acutely. France has introduced a virgin HFC tax and incentives for low GWP alternatives, while Italy’s refrigerant market is projected to exceed €150 million by the end of 2024 - yet both remain vulnerable to black market imports.

The EIA calls for a multi pronged response:

  • Enhanced border enforcement at key transit points such as Bulgaria.
  • Coordinated EU wide monitoring and intelligence sharing between member states.
  • Centralized digital tracking for all HFC shipments.
  • Stricter penalties for traffickers and better oversight of online sales.

Tackling HFC smuggling is vital not only for regulatory compliance but for the credibility of Europe’s entire environmental strategy.

Get in Touch

AFS Cooling offers tailored compliance audits, digital supply chain tracking solutions, and expert F Gas advisory services -ensuring your refrigerant sourcing is fully legal, transparent, and aligned with climate targets. Contact us today to schedule a risk assessment or learn more about our HFC monitoring tools.