Chapter 4
4.2 Illegal Trade Although the F-Gas Regulation requires HFC importers and producers to have quotas before placing HFCs on the EU market, various studies and news reports show that the illegal trade in HFCs is prevalent.12
Figure 4.2.2 Do you support EU-wide minimum penalties for HFC and HFC-equipment smuggling? 78 respondents
An analysis of trade data indicates that HFCs equivalent to 119 million metric tons of CO 2 were imported into the EU in 2018, but only 111.8 of these were reported by companies to the f-gas register, meaning that more than 7% of the imports went unreported. In addition to this, there is smuggling of HFCs into Europe.12 For example, in January 2020, the Bulgarian authorities seized almost 13 metric tons entering the country from Turkey.
9% No
Current penalties for illegal trade offences are set and enforced by individual Member States. When asked whether they support EU-wide minimum penalties for HFC and HFC-equipment smuggling, 91% of survey participants responded that they support this measure. When asked whether they would support the introduction of real time quota tracking being made available for customs officials, 92% indicated their support for this change.
12
91% Yes
Environmental Investigation Agency. 2019. Doors Wide Open. Available online at: https://eia-in-
ternational.org/wp-content/uploads/EIA-report-Doors-wide-open.pdf
Closing the Loopholes
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