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Combating F-Gas Smuggling and Counterfeiting — A Challenge for the HVACR Industry

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Combating F-Gas Smuggling and Counterfeiting — A Challenge for the HVACR Industry

Regulation (EU) 2024/573 on F-gases represents an important step towards reducing greenhouse gas emissions, which have a significant impact on climate change. However, its implementation faces numerous threats that may hinder the achievement of its environmental objectives. The key challenges are the smuggling and illegal trade of refrigerants, the counterfeiting of substances, and the use of waste refrigerants in place of quality-certified ones.

Smuggling and illegal trade in F-gases

One of the main threats is the smuggling of refrigerants, which takes place in several ways. Importers and exporters frequently present false documentation, placing substances on the market without the required quotas. Invoice fraud also occurs — for example, declaring the transport of gases as equipment or services in order to avoid taxes.

Illegal trade also involves concealing F-gases within legitimate shipments, exploiting the transit system to circumvent quotas, and selling online substances that do not meet EU requirements. Particularly problematic is the use of single-use containers, which are not approved for placing on the market and pose a threat to the environment.

Counterfeiting of refrigerants

A second serious threat is the sale of substances other than those declared on the cylinder label, which leads to patent infringement, misleads consumers, and can cause refrigeration system failures. One such case occurred in April 2025, when a delivered refrigerant labelled as R449A turned out to be the cheaper R404A — a substance prohibited for use in topping up and servicing refrigeration equipment.

Use of waste refrigerants in place of certified ones

Recovered refrigerants are classified as hazardous waste and should be subject to reclamation, recycling, or disposal.

Only the process of reclamation and laboratory certification allows recovered refrigerants to be legally placed back on the market and safely used in refrigeration, air conditioning and heat pump systems.

In practice, however, recovered refrigerants are frequently used without checking not only their quality, but even their composition. This dishonest practice leads to poor system performance, accelerated component wear, and ultimately system failures and emissions.

Reusing recovered refrigerants in the same system from which they were recovered requires at least a recycling process — that is, basic purification. Unfortunately, even this fundamental quality step is often skipped or carried out merely as a formality to satisfy F-gas legislative requirements. The result is similar to the above: difficulty in regulating system performance, faster component wear, failures and emissions.

Countering the threats

To reduce the risks associated with illegal trade and refrigerant counterfeiting, international operations such as DEMETER and MARUM are being conducted. Customs authorities and environmental inspectorates are intensifying cross-border controls and monitoring the market for irregularities.

Educational programmes are also being implemented, such as the Legal HFC 4LIFE project, which aims to combat illegal trade and raise awareness among the HVACR industry and public administration about the risks associated with illegal F-gas trading. Anyone who suspects such a case can report it anonymously via the bezpiecznehfc.pl website of the LEGAL HFC4LIFE project.

Should there be any doubt about the composition of a refrigerant, the PROZON Foundation’s laboratory can carry out a free analysis. Where there are concerns about refrigerant quality (water content, acid content, detailed composition), the laboratory also offers testing at an affordable price.

Why is combating illegal practices so important?

The illegal trade and counterfeiting of refrigerants is not merely a legal violation — it is a real threat to the climate, public health and fair competition. F-gases have a high global warming potential, meaning that their uncontrolled release significantly undermines efforts to limit global warming.

Furthermore, the use of counterfeit or untested substances can lead to serious refrigeration system failures, posing risks to the safety of people and property. The presence of illegal, cheaper refrigerants on the market undermines fair competition and makes it harder for law-abiding companies to operate.

Combating smuggling and counterfeiting is therefore not merely a matter of enforcing regulations — it is a defence of the environment, support for innovative and responsible businesses, and the building of a future for refrigeration grounded in sustainable development.

Summary

The implementation of Regulation (EU) 2024/573 on F-gases faces numerous challenges related to the smuggling, counterfeiting and illegal use of refrigerants. To effectively achieve the environmental objectives, intensified enforcement action, international cooperation and education of operators in the HVACR sector are all essential.