HFCs are widely used in many applications such as refrigerators, air conditioning systems, aerosols and fire extinguishers. Since 2015, Europe has been phasing down their use while suitable alternatives are being developed and deployed. Since 2024, this effort has been increased by the phase-out imposed by the revised F-gas Regulation.
HFCs represent a small percentage of total greenhouse gases, however most countries in the world have committed to reducing the use of high GWP HFCs to minimise their climate impact. The EU has committed to this phase-out through a managed quota system within the F-gas Regulation. By 2050, HFCs will be phased out in the EU.
However, the quota is being undermined by criminal organisations. They illegally import HFCs into many countries in Europe. This means that more HFCs are being used than allowed by law.
Illegal imports of represent a substantial part of the European market of HFCs. In its most recent 2024 report, EIA describes how illegal trade routes have spread across the continent and traders became more and more sophisticated in their smuggling tactics. While seizures have gone down in recent years, EIA does not attribute this to any single cause. Trade data however indicate that imports of HFCs into the EU did not decline during the same period, indicating that lower levels of enforcement might be at play.
In 2020, EFCTC estimated that illegal imports represent around a third of the legal market of HFCs. While EFCTC does not possess more recent data, the EIA report and signals from the value chain do not indicate a strong decrease in this regard.
The phase-out of HFCs, as decided by the F-gas Regulation, risks being undermined by this illegal trade. The foreseen lowering of available quota could further incentivise the illegal market. It also compromises efforts to replace HFCs with better alternatives and undermines the EU’s efforts to become carbon neutral by 2050
To avoid putting our climate goals at risk, we need to eradicate the black market for HFCs.
We achieve this by:
- Identifying where illegal HFCs come from
- Understanding who benefits from these illegal imports
- Upholding the law
- Supporting those who enforce the law