HFC smuggling is particularly visible in Eastern Europe, including Poland, where a large proportion of these substances are transported across the European Union’s external border from countries such as Turkey, Serbia and Ukraine. In recent years, for example, Polish customs services have seized thousands of illegal cylinders of refrigerants intended for the black market. Illegal HFC trading has serious consequences for both the environment and the economy. HFCs are potent greenhouse gases with a significantly higher global warming potential (GWP) than carbon dioxide. The illegal emission of these gases contributes to climate change and jeopardises the achievement of the European Union’s climate objectives. In addition, illegal HFC trading is frequently linked to tax evasion and organised crime, causing losses to the budgets of member states.

HFC smuggling routes into and within Europe

The scale of illegal refrigerant trading is subject to close monitoring under the Montreal Protocol. An analysis of available data as of 30 April 2024 allows for an assessment of the extent of this activity in various regions of the world, including Poland and, more broadly, Europe. With 42 reported cases of illegal HFC/HCFC trading, Poland ranks among the leading European countries reporting such incidents. Although the scale of smuggling in Poland is not as high as in other countries on the EU’s eastern border, such as Bulgaria (233 cases) or Lithuania (116 cases), it nonetheless remains a significant problem at the local level. Poland ranks third in Europe and fourth globally in terms of the number of reports, reflecting the intensity of illegal activity on Polish territory. This also suggests that Poland, as one of the larger Central and Eastern European countries, may serve both as a destination market and as a transit country for HFC smuggling to other European markets. The number of reports underscores the need for enhanced monitoring and cooperation at both the national and international level to combat the smuggling of controlled substances.

Europe — and Eastern Europe in particular — stands out compared to other regions of the world in terms of the number of reported cases of controlled substance smuggling. Bulgaria and Lithuania, mentioned above, record the highest numbers of reports, pointing to a serious challenge related to illegal refrigerant trading. A total of 420 cases were reported across Eastern Europe (accounting for as much as 59% of all cases), including 47 new cases recorded between May 2023 and April 2024.

The scale of the problem in Eastern Europe is undoubtedly due to the proximity of Asian markets, where the majority of illegal HFC shipments originate and are produced.

Also significant are the well-established smuggling routes leading to Europe from China via Turkey and onwards through Poland, Greece, Bulgaria and Romania. Western European countries and other developed nations reported a combined total of 184 cases (approximately 26% of the overall figure), including 90 new reports from 2023–2024. Such a large number of new cases indicates that illegal HFC trading is a dynamic phenomenon, and that despite advanced enforcement and control mechanisms, Western European countries such as Italy (34 cases), Spain (19 cases) and France (16 cases) continue to grapple with the problem of smuggling. It is also worth noting that the Netherlands, home to some of Europe’s key seaports, recorded 11 smuggling cases, highlighting the significant role of maritime transport in the region as a transit point for smuggling.

An analysis of trade data shows that despite the introduction of HFC regulations, the level of imports of these substances into the European Union has not decreased in recent years. On the contrary, a significant increase in smuggling has been recorded since 2022, suggesting that illegal HFC trading continues to pose a serious challenge. Smugglers are becoming increasingly sophisticated and their methods harder to detect. In the 154 new cases reported in 2023–2024 alone, the total mass of illegal HFC substances seized amounted to 1,200 tonnes.

Quantity of refrigerant seized in individual EU countries, Norway and the UK between 2019 and 2023

At present, smuggling is focused on HFC refrigerants. The most frequently smuggled are R410A (46 cases), R134a (45 new cases), R404A (23 cases) and R407C (13 cases). Among these substances, R134a and R410A have the largest mass shares, reflecting their widespread use in the refrigeration and air conditioning industry despite a range of use restrictions. Of particular concern is the high number of new smuggling cases involving R404A — exemplified by a shipment from China to Italy intercepted in September 2023 containing 20 tonnes of R404A, as well as 78.8 tonnes of R507A — which may be directly linked to recently introduced regulations restricting the use of refrigerants with a GWP of 2,500 or above.