The findings of the latest EIA report demonstrate that illegal HFC trade in the EU is not limited to isolated incidents, but is systemic, coordinated and increasingly professional in nature.
The steps taken by Europe to phase out HFCs show that without robust policy and effective enforcement, space is created for large-scale illegal trade. Driven by high profits and uneven enforcement, organised criminal groups have tightened their links to illegal HFC trading, increasing emissions and undermining the effectiveness of climate policy. In response, the European Union revised its F-gas Regulation, adopted in 2024, and introduced a set of control measures to combat illegal trade. These include real-time quota checks for customs authorities, new cylinder recovery system requirements, expanded bans on the most climate-damaging HFC refrigerants, and new equipment prohibitions aimed at reducing overall demand.
Building on earlier research conducted in 2021 and 2023, the EIA carried out a comprehensive investigation of the Italian refrigerant market in 2025. Italy is one of Europe’s largest refrigerant markets and the member state with the highest number of registered HFC seizures. The investigation identified numerous companies operating at various stages of the supply chain — from importers to regional distributors — that openly admitted to practices such as exceeding quota limits, falsifying invoices, mislabelling virgin refrigerants as recovered, and evading VAT. Some of these companies claimed to supply major manufacturers, transport operators and supermarket chains (including Ferrovie dello Stato, Carrefour and Lidl Italia), raising serious concerns about illegal refrigerants entering mainstream commercial supply chains.
Despite tightened enforcement measures across Europe, the EIA’s findings once again highlight how deeply interconnected illegal HFC trade is across member states. Investigations have documented the continued use of “laundering” techniques, whereby illegal HFCs are first introduced into member states with weaker customs controls — such as Bulgaria and Romania — before being distributed across the rest of the EU. While the revised Regulation is already producing positive effects — in particular, curbing the open sale of gases with very high global warming potential (GWP) — the EIA’s findings reveal new legal loopholes and emerging trends. These include the widespread mislabelling of high-GWP HFCs following recovery, as well as trade in counterfeit lower-GWP fluorinated gas blends. Illegal trade is largely driven by high HFC prices, which have risen tenfold since the beginning of the EU phase-down. Given that the HFC quota will be reduced by almost half by 2027, both price pressure and incentives for illegal trade are likely to intensify. This risk is further compounded by the fact that once HFCs are placed on the European market, there is no obligation to demonstrate throughout the supply chain that they are linked to a quota, making it difficult for end users to be certain of a product’s legality. Better supply chain traceability and greater digitalisation of documentation could help mitigate this problem.
The Environmental Investigation Agency sets out a series of recommendations for improving the F-gas trading system, including:
- ensuring consistent implementation of the F-gas Regulation through coordinated action by customs authorities, environmental inspectorates, market surveillance bodies and financial crime units
- expanding inspections and testing of refrigerant cylinders; confiscating illegal or incorrectly labelled products and enforcing withdrawal from the market
- strengthening cross-border cooperation
- integrating financial investigations with actions against illegal HFC trade
- applying deterrent and criminal sanctions
- connecting all member states to the EU’s fluorinated gas single-window system
- full digitalisation of reporting and licensing systems and the introduction of an HFC tracking system for traded substances
- closing legal loopholes that allow high-GWP virgin HFCs to be incorrectly labelled as recovered
- strengthening enforcement of regulations on illegal online HFC sales, including seller verification, proactive monitoring and penalties for non-compliance by platforms
- establishing and implementing minimum standards for national licensing systems, including unique shipment numbers and mandatory reporting of controlled substances (including recycled and recovered substances)
- banning single-use cylinders and requiring reusable cylinder recovery systems
- establishing an obligation for standardised reporting on illegal trade, including methodology, enforcement actions and sanctions
- improving supply chain transparency through digital quota tracking to ensure that suppliers, products and documentation comply with regulations
- promoting natural refrigerants
- conducting awareness-raising activities to discourage the purchase of refrigerants or equipment from unverified or informal sources
- accelerating the phase-out of HFCs from new and existing equipment to reduce exposure to price fluctuations, supply constraints and the risks of illegal trade.
According to the EIA report, the lessons that can be drawn from the EU’s experience apply far beyond its borders. As global efforts to phase down HFCs under the Kigali Amendment gain momentum, the challenges facing the EU highlight how regulatory gaps and uneven enforcement can be exploited by criminal networks, undermining international climate commitments.
For countries that have yet to strengthen their controls, the EU’s experience shows that delay is not an option — illegal trade flourishes where oversight is weak, and the urgency of action is all the greater given the interconnected and global nature of HFC supply chains.
By closing enforcement gaps, harmonising approaches to licensing, reporting and information sharing, and accelerating the transition to sustainable, non-fluorinated alternatives, countries around the world have the opportunity to get ahead of the challenges they are likely to face and address illegal HFC trade before it becomes entrenched.
The report’s findings also align with the activities undertaken in Poland by the PROZON Climate Protection Foundation, which has for years been drawing attention to the importance of proper refrigerant recovery, management and trade control, as well as the handling of F-gas containers. It is no coincidence that the EIA report references PROZON — both in illustrative material relating to the problem of abandoned cylinders and in expert sources — demonstrating that issues of system integrity, packaging recovery and the elimination of illegal practices are of relevance not only at the EU level, but also from the perspective of national market participants.
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