According to EIA reports, refrigerant smugglers are becoming increasingly inventive in their methods. Here are some of them:
Exploiting loopholes in transit regulations — HFC smugglers frequently exploit European Union transit regulations, which allow goods not covered by quotas to be moved through EU territory. Under transit procedures, goods may be transported through the Union without having to meet HFC quota requirements, provided they are not formally placed on the EU market. Smugglers exploit this procedure by declaring that goods are merely being transported through the EU, while in reality they end up on the internal black market. They often falsify customs documents, claiming that shipments have left the EU when they have in fact remained within member states. Another tactic used is the repeated opening and closing of transit procedures, designed to confuse customs services. Traders redirect transport routes, repeatedly initiating procedures in different countries, which makes tracking goods more difficult and may lead to control deadlines lapsing.
Invoice fraud — HFC smugglers use a variety of invoice fraud techniques to avoid paying taxes and conceal the true nature of the goods. One commonly used method is issuing invoices with incorrect product descriptions, for example as “tools” or “technical parts”, which allows them to bypass customs and tax controls. There are also cases where illegal HFCs are sold without an invoice and payments are made in cash, making such transactions difficult to trace.
Anonymous listings on online marketplaces — Illegal HFC trading relies primarily on the use of online sales platforms such as Facebook Marketplace and OLX, where products are offered and customers are sourced. Traders often operate anonymously, using false identities and not including phone numbers in their listings, which makes it significantly harder for law enforcement agencies to identify them. This type of activity is particularly prevalent in countries such as Bulgaria, Spain, Portugal and Italy, where the HFC black market is well established. Individuals involved in illegal trading frequently post numerous listings on various platforms using different accounts and false details, making it even harder to track their activities.
Small shipments — Road smuggling of HFCs across EU borders often involves splitting larger consignments into smaller batches transported by lorries or vans. Transporting smaller quantities of refrigerants — typically no more than 10 cylinders — raises less suspicion among customs services, thereby reducing the risk of detection.
Transfer of gas from single-use to refillable cylinders — Another method involves pumping HFCs from single-use cylinders into refillable ones after they have been smuggled into the EU. Single-use cylinders are prohibited in the European Union but are widely used in Asian markets, making them cheaper and more readily available. Once in the EU, illegal traders transfer the gas from the prohibited single-use containers into refillable ones, which are harder to identify as illegal during customs inspections. Refillable cylinders are standard in HFC trading and therefore arouse less suspicion.
Concealment — Smugglers frequently use black foil to wrap gas cylinders during transport through the EU in order to avoid detection of the cargo by customs officials. They ship cylinders via courier companies that do not verify what they are transporting, with the cylinders packed in bags together with other goods (“they place them in the middle and fill the remaining space with whatever else is being transported — meat, cabbage…”). Another practice is transporting cylinders on passenger coaches (without the knowledge of the transport company or passengers), hidden in the luggage hold among baggage. This is particularly dangerous, as these substances must be transported using specialised transport.