Regulation (EU) 2024/573 on F-gases represents an important step toward reducing emissions of greenhouse gases that have a significant impact on climate change. Its implementation, however, faces numerous risks that may hinder the achievement of the intended environmental goals. The key problems are the smuggling and illegal trade of refrigerants, the counterfeiting of substances, and the use of waste refrigerants instead of refrigerants with a certificate confirming their quality.
Smuggling and illegal trade of F-gases
One of the main threats is the smuggling of refrigerants, which is carried out in several ways. Importers and exporters often present false documents, placing substances on the market outside their quota. Invoice fraud also occurs — for example, declaring the transport of gases as equipment or services in order to avoid taxes.
Illegal trade also includes concealing F-gases within legitimate shipments, using the transit system to circumvent quotas, and the online sale of substances that do not meet EU requirements. Particularly problematic is the use of single-use (disposable) containers, which are not authorized for sale and pose a threat to the environment. Fig. 2. Counterfeit R449A.
Counterfeiting of refrigerants
The second serious threat is the sale of substances other than those declared on the cylinder label, which leads to infringement of patent rights, misleads consumers, and can cause failures in refrigeration installations. Although these refrigerants are offered as genuine, in reality they are often mixtures of gases of unverified composition and significantly higher GWP, which fail to meet quality requirements and are banned from use within the EU.
One example is a case from April 2025, in which a refrigerant delivered to an installation as R449A turned out in fact to be the cheaper R404A, which is prohibited for filling and servicing refrigeration equipment. Fig. 1. A counterfeit refrigerant that cannot be considered reclaimed.
Use of waste instead of refrigerants
Recovered refrigerants are waste, classified as hazardous, and should undergo a process of reclamation, recycling, or disposal. Only the process of reclamation and laboratory certification allows recovered refrigerants to be legally placed on the market and safely used in refrigeration and air-conditioning installations and heat pumps.
Unfortunately, practice shows that recovered refrigerants are often used without checking not only their quality, but even their composition. This dishonest practice leads to poor operation of the installation, rapid wear of components, and, consequently, failures and emissions.
Reusing recovered refrigerants in the same installation from which they were recovered requires at least a recycling process, that is, a rough cleaning. Unfortunately, even this basic operation of ensuring refrigerant quality is often omitted or carried out only to formally satisfy the requirements of the F-gas legislation. The result is similar to the above: difficulties in adjusting the operation of the installation, faster wear of parts, failures, and emissions.
Countering the threats
In order to reduce the risks associated with the illegal trade and counterfeiting of refrigerants, international operations such as Demeter and MARUM are being conducted. Customs authorities and the environmental protection inspectorate are intensifying cross-border checks and monitoring the market for irregularities.
In addition, educational programs are being carried out, such as the Legal HFC 4LIFE project, which aims to combat illegal trade and raise awareness within the HVACR industry and public administration about the risks associated with the illegal trade of F-gases. Anyone who suspects such a case can report it anonymously via the website www.bezpiecznehfc.pl of the Legal HFC 4LIFE project.
In the event of any doubts regarding a refrigerant’s composition, the laboratory of the PROZON Foundation can test it free of charge. And in the event of doubts regarding a refrigerant’s quality (water content, acid content, detailed composition), the laboratory offers testing at an affordable price.
Why is countering illegal practices so important?
The illegal trade and counterfeiting of refrigerants is not merely a violation of the law — it is a real threat to the climate, public health, and fair competition. F-gases have a high global-warming potential, which is why their uncontrolled emission significantly undermines efforts to curb global warming.
Furthermore, the use of counterfeit or untested substances can lead to serious failures of refrigeration installations, creating a risk to the safety of people and property. The presence of illegal, cheaper refrigerants on the market undermines the principles of healthy competition and hampers the operation of companies that act in accordance with the regulations.
That is why the fight against smuggling and counterfeiting is not only about enforcing the law — it is about defending the environment, supporting innovative and responsible companies, and building a future for refrigeration based on sustainable development.
Customs Service foils smuggling of greenhouse gases worth over PLN 4 million
On 5 September, the Mazovian National Revenue Administration (KAS) announced that its officers had foiled an attempt to illegally place on the market more than 4,000 cylinders of fluorinated greenhouse gases (so-called F-gases). The value of the confiscated goods exceeds PLN 4 million. The proceedings are being conducted by the Head of the Mazovian Customs and Tax Office in Warsaw.
The seizure took place during a routine road inspection of a truck in a locality near Warsaw. The vehicle’s trailer contained 1,340 cylinders of refrigerant used to charge air-conditioning systems. Further action led officers to a nearby warehouse from which the vehicle had departed. There, an additional 2,845 cylinders were found, along with pallets of empty and used containers.
In total, more than 42 tonnes of refrigerant gases were secured. The full chemical composition has not been officially disclosed; however, based on photographs published by the customs service, it is known that the confiscated substances included refrigerants such as R134a, R407C, and R32 — all widely used in air-conditioning installations and, at the same time, classified as gases with a high global-warming potential.
The import, production, and trade of such substances are strictly regulated in the European Union. Legally placing F-gases on the market requires the appropriate authorizations and quotas, as well as the payment of customs duties and taxes. Illegal trade can lead to serious environmental and financial consequences, as well as criminal ones — offenders face up to 3 years’ imprisonment.
Fluorinated greenhouse gases have a strong impact on global warming and — although they do not directly destroy the ozone layer — are subject to restrictions under the EU F-gas Regulation and the Kyoto Protocol. KAS reminds the public that their smuggling poses a serious threat both to the environment and to fair economic trade.
Source: KAS, https://www.mazowieckie.kas.gov.pl
Summary
The implementation of Regulation (EU) 2024/573 on F-gases faces numerous challenges related to the smuggling, counterfeiting, and illegal use of refrigerants. To effectively achieve the environmental goals, intensified control measures, international cooperation, and education of the entities operating in the HVACR sector are essential.
Source: “Chłodnictwo & Klimatyzacja” 7–8/2025. chlodnictwoiklimatyzacja.pl
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