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Illegal black market refrigerants flowing into Europe through Spain
Debate between Spanish authorities looks to identify actions to stop the illegal trade of HFC gases

The recent debate organised by the European Fluorocarbons Technical Committee (EFCTC) and the National Confederation of Plumbing and HVAC Trade Associations (CONAIF) addressed the illegal trade of HFC refrigerant gases head on with the aim of identifying solutions to put an end to the current situation.
During the meeting, which saw the participation of the most relevant authorities, it was highlighted that Spain– especially the southern and eastern regions of the country – is becoming Europe’s main entry point for illegal refrigerant gas. The trade is becoming more and more threatening and could come to represent a third of the gas market in Europe.
The goal of the F-GAS regulation, which came into effect in Europe in 2015, was to gradually eliminate HFC gases with a high potential to pollute the air and reach a 79% reduction in use by 2030 in order to combat climate change and speed up the energy transition. To that end, a quota system was introduced to reduce import of these gases.
Yet despite this, a black market has arisen for HFC gases and it is affecting the entire value chain, from fabricators, to small-medium enterprises, installers and end consumers. The illegal imports are entering through Spain.
This illegal activity is continuing to grow and is eluding both European and Spanish laws due to lack of customs controls. Sanctions are still too low and on this issue there is disagreement between the member states, especially on how to fine the criminal organisations involved in this traffic.
Lieutenant Héctor Santed of UCOMA, the central operations unit for the protection of the natural environment, explains how and from where illegal gases are arriving in Spain. “Gases are finding their way into Spain from other parts of Europe, as well. The route goes from China to Russia, from Russia to the eastern European countries that border Russia, and from the eastern European countries to the rest of Europe. The gas is not coming in through our ports alone; it is also being transported via land routes for use in the country. This is the modus operandi that we have identified, based on our observations during the investigations”.
It is likely that the situation will continue, given the new reduced HFC quotas set by the European Union, in effect since 1 January 2021, which could further feed the HFC black market.
To come to a solution, it may be important to increase awareness of the problem among value chain stakeholders, which could play a key role in incentivising the reporting of suspicious activities.
According to lieutenant Santed “it would be extremely useful to receive all possible information on suspicious behaviour, even from industry professionals, in order to improve the effectiveness of our investigations and be more agile in our actions. We need the industry’s help to eradicate the criminal organisations”. Tackling this illegal traffic of HFC gases also requires raising the awareness of and training competent authorities, but also more controls and better tracking of operations, two key factors to promptly identify illegal operations and stop them.
During the meeting, which saw the participation of the most relevant authorities, it was highlighted that Spain– especially the southern and eastern regions of the country – is becoming Europe’s main entry point for illegal refrigerant gas. The trade is becoming more and more threatening and could come to represent a third of the gas market in Europe.
The goal of the F-GAS regulation, which came into effect in Europe in 2015, was to gradually eliminate HFC gases with a high potential to pollute the air and reach a 79% reduction in use by 2030 in order to combat climate change and speed up the energy transition. To that end, a quota system was introduced to reduce import of these gases.
Yet despite this, a black market has arisen for HFC gases and it is affecting the entire value chain, from fabricators, to small-medium enterprises, installers and end consumers. The illegal imports are entering through Spain.
This illegal activity is continuing to grow and is eluding both European and Spanish laws due to lack of customs controls. Sanctions are still too low and on this issue there is disagreement between the member states, especially on how to fine the criminal organisations involved in this traffic.
Lieutenant Héctor Santed of UCOMA, the central operations unit for the protection of the natural environment, explains how and from where illegal gases are arriving in Spain. “Gases are finding their way into Spain from other parts of Europe, as well. The route goes from China to Russia, from Russia to the eastern European countries that border Russia, and from the eastern European countries to the rest of Europe. The gas is not coming in through our ports alone; it is also being transported via land routes for use in the country. This is the modus operandi that we have identified, based on our observations during the investigations”.
It is likely that the situation will continue, given the new reduced HFC quotas set by the European Union, in effect since 1 January 2021, which could further feed the HFC black market.
To come to a solution, it may be important to increase awareness of the problem among value chain stakeholders, which could play a key role in incentivising the reporting of suspicious activities.
According to lieutenant Santed “it would be extremely useful to receive all possible information on suspicious behaviour, even from industry professionals, in order to improve the effectiveness of our investigations and be more agile in our actions. We need the industry’s help to eradicate the criminal organisations”. Tackling this illegal traffic of HFC gases also requires raising the awareness of and training competent authorities, but also more controls and better tracking of operations, two key factors to promptly identify illegal operations and stop them.