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IRI October 24, 2019 0 Comments

A crackdown on the illegal trade in HFC refrigerants by Polish customs netted over 107 tonnes of non-compliant refrigerant in 2018.

Faced with what Poland has described as a “massive inflow of illegal HFCs”,  the Polish National Revenue Administration and Customs Authorities were prompted to take action in the second quarter of 2018. During that time, customs officers intercepted 425 separate shipments that were in contravention of the European F-gas regulations. This included smuggling of HFCs, non-compliant labelling and importation outside of the quota system. In total, this involved 107,456kg of HFCs, equivalent to 238,482 tonnes of CO2.

On the eastern border of the EU, Poland is one of the countries on the frontline of the illegal refrigerant trade which has plagued the European air conditioning and refrigeration market over the last couple of years. It has been estimated that the illegal trade in HFCs could account for as much as 20% of the annual F-gas phase down quota.

Poland’s efforts were acknowledged by this year’s Montreal Protocol Award for customs and enforcement officers. The awards, organised by the UN Environment Programme’s OzonAction programme, the Ozone Secretariat and the World Customs Organisation, recognise the efforts of customs and enforcement officers to combat the illegal trade in ozone-depleting and global warming substances. The awards in November will this year recognise the efforts of 117 individuals and 60 organisations from 24 countries.

Submissions from the eastern EU member states of Poland, Bulgaria, Greece and Croatia give an insight into contraventions of the European F-gas regulations in 2018.


It is unclear how big the black market is in Poland, but the undetected trade is probably far larger. PROZON, an NGO supported by leading Polish refrigerant distributors, estimated last year that as much as 30% of the R134a used by car repair workshops was from questionable or simply illegal sources.

An analysis of internet sales of illegal refrigerants carried out by the National Revenue Administration at the request of the European Commission and the F-gas competent authorities in Poland, confirmed that “a significant amount” of HFCs had been illegally placed on the market.

The reported cases in Poland have involved a number of HFC refrigerants, but mainly R134a and, to a lesser extent, R404A. The origin of the HFC refrigerants was not always confirmed, though China was the country of origin in the majority of cases. The destination was either Poland or other EU countries.

It should be noted that once goods are released for free circulation in one European Union country, they can freely move to other EU countries under the single market agreement.

A raid on a family house in the Croatian village of Cage, close to the border with Bosnia and Herzegovina netted 102 disposable cylinders, containing R134a, R410A, R404A and R407C




Of the 425 cases detected in 2018, 414 cases, involving 10,676kg of refrigerant, were recorded as smuggling attempts. The majority of these – 403 cases, 9,803kg of refrigerant – were in illegal non-refillable cylinders. Smuggling is defined as the non-declaration of the goods to the customs authorities at the time of import.

Reported smuggling attempts have involved refrigerant in large and small containers, by trucks, vans and passenger cars transporting a few containers with the claim that they are for the owner’s own use, but also in LPG tanks installed in private cars imitating LPG installations.

Despite concerns and some evidence that the illegal imports could include flammable and/or toxic gases, Polish customs reports that none of their tests with refrigerant identifiers detected any contamination.

Incorrect labelling of refillables

Poland also reported six cases involving 2,400 refillable cylinders (28,800kg) of R134a and 1,400 refillable cylinders (16,800kg) of R410A that were wrongly labelled. Refrigerant cylinders need to carry a number of stamps and marks including the cylinders’ compliance with the European standards for design and construction, the Transportable Pressure Equipment Directive (TPED), and the dates of production and testing.

In other cases, five importers were found to be importing a total of 51,180kg of HFC refrigerants outside of the F-gas quota system. This included R134a, R410A, R404A and R407C.

According to Polish legislation, HFCs that have been detected at the border, must be re-exported at the cost of the offenders. If they do not cooperate or refuse to re-export, a court case would be initiated. There has been one case of 27kg of refrigerant being destroyed. So far, only administrative fines have been applied to the smuggling cases.

Poland’s seizure figures are likely to be far bigger this year. Two seizures alone, reported on the Cooling Post in April and September 2019, involved over 38 tonnes of refrigerant.


Bulgarian customs reported 78 separate smuggling attempts between April and December in 2018, a total of 2,114.9kg of refrigerant, mainly R134a and R404A.

The shipments, involving 497 cylinders – all of them non-refillable – were detected at the Kapitan Andreevo checkpoint on the border with Turkey.

The goods were transported in trucks or private cars with incorrect shipments papers or without papers. All were presumed to have been loaded in Turkey and destined to the EU. Fines were levied in the range of €220-250 per cylinder.

The contents of the refrigerant cylinders were not analysed and are currently being held in a customs warehouse, awaiting destruction. The destruction costs should be covered by the state budget, but as the quantities seized are substantial and there are no proper destruction facilities in Bulgaria, the destruction will be very costly. If there is a shortage of funding, producers of alternative refrigerants might be requested to co-finance the destruction.


The Greek customs office in Kakavia detected five separate cases of illegal imports from Albania in 2018.

The five cases were discovered in buses and cars during routine controls checks. It involved a total of 432kg of refrigerant (R134a, R404A, R410A and R407C) in illegal non-refillable refrigerant cylinders and without shipment papers and customs declaration.

In all cases, the vehicles were registered in Albania and the drivers were Albanian nationals. Total fines of nearly €6,000 were imposed on the perpetrators. The fine for the largest of the seizures, involving 15 11.3kg cylinders of R410A, is yet to be determined.

Again, the figures for illegal refrigerant seizures this year are likely to be far higher. One single seizure last month involved over 23 tonnes of illegal HFC refrigerant found in a raid on a warehouse near Athens.

Croatian customs found R134a disguised as helium gas in the luggage compartment of a private car


Of 25 seizures conducted by the Croatian Customs Service in 2018, the largest was as a result of a raid in September 2018 on a family house in the village of Cage, close to the border with Bosnia and Herzegovina. A total of 102 disposable cylinders, containing R134a, R410A, R404A and R407C, were found in the backyard. The haul also included two 27.2kg cylinders of banned ozone-depleting HCFC refrigerant R22.

The seized goods were placed in customs storage and the responsible person fined HRK15,000 (€2,000).

In total, Croatia reports 25 seizures involving 1,941.8kg of refrigerant. Most were brought in by road from Bosnia and Herzegovina.

One particular seizure at Slavonski Šamac, on the border with Bosnia and Herzegovina, found two cylinders of R134a disguised as helium gas in the luggage compartment of a private car. Removal of paper labels proclaiming “Balloon time – helium balloon kits” revealed they were actually R134a.

The seizures resulted in fines totalling over €24,000.