The Environmental Investigation Agency (EIA) recently published a report entitled Doors Wide Open - Europe’s flourishing illegal trade in hydrofluorocarbons (HFCs). The report outlines a decline in the supply of HFC products in the EU as a result of the imposition of F-Gas quotas, resulting in a substantial increase in illegal use and trade in HFCs and HFC products.
HFCs were introduced as replacements for Ozone Depleting Substances (ODS), which are being phased out by the Montreal Protocol due to their impact on the ozone layer. Whilst HFCs do not deplete the ozone layer, they are nonetheless potent greenhouse gases, with global warming potentials (GWP). The EU F-Gas Regulation was introduced in 2014 providing for an economy-wide phase-down in HFC supply and a number of bans on HFC use in certain equipment and products.
According to the EIA reports, illegal trade and use of HFCs is prevalent and is undermining the F-gas Regulation, resulting in additional HFC emissions. Continued availability of HFCs outside the HFC phase-down schedule is also hindering the uptake of climate-friendly technologies and may ultimately threaten the success of the F-gas Regulation. There is therefore an urgent need for the EU Commission, and all individual EU Member States, to improve enforcement of the F-gas Regulation and implement additional measures to accelerate the transition to HFC alternatives.
The report makes several recommendations, including:
- Implementation of a fully functional per shipment HFC licensing system which allows customs officials to obtain real-time information to determine if HFC imports are within the specified quota for a particular company
- Improve reporting and monitoring of HFC trade with exporting countries
- Increase transparency of the HFC Registry such that details of new entrants and data on quotas allocated to individual companies are publicly available
- Revise the ban on non-refillable cylinders to prohibit the use of all disposable cylinders
- Remove the exemption from the phase-down under Article 15(2) for producers or importers of less than 100 tCO2 e of HFCs per year.