Reports to the EFCTC Action Line of illegal HFC trade lead to criminal investigations

EFCTC stima che stima che fino a 73 milioni di tonnellate di CO2eqT potrebbero essere entrate illegalmente nell'UE nel 2018 e 2019 insieme. CREDITS: EFCTC

Illegal trade in hydrofluorocarbons (HFCs) is threatening legitimate small businesses, financing organised crime, and ultimately the climate. The European FluoroCarbons Technical Committee (EFCTC) Action Line in 2020 received 111 anonymous reports of suspicious behaviour, leading directly to criminal investigations.

The F-gas regulation aims to phase down HFCs with high GWP through a quota system. Uneven enforcement by EU member states has created an opportunity for criminals to bypass the quota system and import HFCs into the EU illegally. New data recently showed that in 2019, up to a maximum of 31 million tonnes CO2 equivalent (MtCO2e) could have entered through EU borders illegally.

EFCTC’s Action Line ( is available in 14 languages and has been successful in fighting illegal trade. Of the 111 Action Line reports of possible illegal HFC activities received from across Europe in 2020, 30% originated from Italy. The reports were analysed by the investigation agency contracted by EFCTC, Kroll. In 2020, Kroll prepared 74 evidence packs that have been passed on to EU enforcement authorities and the European Anti-fraud Office, OLAF.

This evidence has helped in some of the 13 seizures of illegal HFCs that have taken place in Europe. The biggest seizure in 2020 was in Romania, with a shipment coming from Turkey, in which customs officials found more than 7,000 cylinders in several trucks1.

2021 has marked a new step in the EU quota system, as the F-gas regulation sets a reduction of the quota from 63% to 45% compared to pre-2015 level. This takes a large amount of HFCs off the legitimate market, creating new opportunities for smugglers to fill the gap. As a result, EFCTC fears an increase in illegal imports of HFCs this year.

Chairman of EFCTC, Dr Nick Campbell, noted, “Illegal HFC imports are a well-known issue in the industry and the EFCTC Action Line is an effective tool to report it. Insights received via the Action Line continue to provide unique intelligence from the market and enable Kroll to rapidly identify potential criminal behaviour. It is a crucial source of evidence for enforcement action by EU member states and OLAF and we hope it can lead to more seizures at EU borders, as well as criminal cases in courts leading to dissuasive penalties.”

He added, “If you have seen any possible instances of illegally-imported HFCs being offered for sale, please contact us at

EFCTC also has a pledge #SayNoToIllegalHFCs for organisations and individuals to commit to doing their part to eradicate the black market for HFCs. To find out more please visit the website: