Key Insights
- Europe is contending with an epidemic of illegal refrigerant-gas sales.
- The sales undercut efforts to switch to gases without global warming potential.
- Campaigners are publicizing the problem and hope to forge a path for other parts of the world.
On paper, Halpha Refrigerant’s business looks innocuous. Yet a company representative boasted to an undercover investigator that it commands half of southern Italy’s trade in a class of chemicals that legally it shouldn’t have imported. The chemicals are not narcotics or explosives, but refrigerant gases: hydrofluorocarbons, or HFCs, a group of climate-warming compounds so potent that the world is urgently phasing them down.
The representative claimed that Halpha’s turnover had been about $18 million over the previous 5 years. But Halpha, which didn’t respond to a request for comment, doesn’t have a quota from the European Union (EU) to import HFCs, meaning selling so much should have been impossible. The representative’s assertions, and those of similarly brazen criminals, appear in new research published in April (PDF) by the nonprofit Environmental Investigation Agency UK (EIA).
“There’s a lot of people who are making a lot of money, and it’s easy money,” says Fin Walravens, a senior climate campaigner at EIA. “They get away with it, and it’s not drugs—they can hide under this veneer of legitimacy.”
Global efforts to rein in HFCs have two levels of ambition. Under the Kigali Amendment to the Montreal Protocol, “old” industrialized countries committed to slash use of these gases 45% by 2024 and 85% by 2036, relative to early-2010s levels. A second group of countries, which includes China, India, and Brazil, is committed to reducing its consumption 80% by 2045.
“You have police, customs, tax authorities all working in silos, and that can make enforcement really challenging.”
European countries have the steepest reduction targets written into their laws, phasing down HFC use faster than the Kigali Amendment requires. Going further still, the EU aims for a complete phaseout by 2050. That aim is pushing some HFC demand underground. Critical industries are clinging to older refrigeration systems that run on HFCs rather than investing in modern alternatives. Phasedown goals are less ambitious in the US, but the same dynamic holds sway there.
As legacy systems hum away, so does the appetite for outlawed coolants. EIA investigators have been tracing suspicious sales of refrigerants that shouldn’t legally exist. In doing so, they’re exposing chemical criminals, pushing for better enforcement, and showing how the rest of the world can learn from Europe.
The risks of using illegal refrigerant gases
Halpha Refrigerant offers HFCs such as R404A, a blend of 1,1,1-trifluoroethane, 1,1,1,2-tetrafluoroethane, and pentafluoroethane widely used in applications like supermarket freezers and refrigerated trucks. The amount of heat that gases trap relative to carbon dioxide is known as their global warming potential (GWP). R404A’s GWP is 3,922, which is why governments want to limit its use.
This illegal trade can also harm people more directly than through its effects on the climate. For example, fake refrigerants can contain unsuitable substances that may cause cooling systems to explode, according to Graeme Fox from the F-Gas Register, which certifies refrigeration and air conditioning installers on behalf of the UK government. In an incident in the early 2010s, refrigerated containers were refilled with reactive chloromethane and killed three technicians (PDF), Fox says.
A short history of refrigerant gases
Chlorofluorocarbons (CFCs): These efficient gases were commercialized starting in 1930 but determined in 1984 to be reacting with atmospheric ozone and creating a hole in the ozone layer. Phased out starting in 1987 under the Montreal Protocol.
Hydrochlorofluorocarbons (HCFCs): These gases were viewed as a temporary, acceptable alternative to CFCs, though they still react with ozone. As such, production was prohibited after 2020 in high-income countries and after 2030 in others.
Hydrofluorocarbons (HFCs): These gases were commercialized in the early 1990s as long-term replacements for CFCs, but their global heating effect came into focus in 2014. In 2016 governments agreed to the Kigali Amendment to the Montreal Protocol, which will phase down all HFCs.
Hydrofluoroolefins (HFOs): These refrigerants with low global warming potential appeared on the market in the early 2010s. They can often be drop-in replacements for HFCs in existing systems, such as supermarket refrigerators.
Nonfluorinated gases: These refrigerants preceded CFCs and are now seeing a comeback. Some, like ammonia and sulfur dioxide, are toxic, but relatively safe gases like carbon dioxide, propane, and isopentane are growing in popularity as alternatives to HFCs.
The illegal trade is also bad for legitimate businesses. “The risks of illegal HFC trade are genuine and seriously undermine core business operations,” says Brad Hooper, global commercial director at Orbia Fluor & Energy Materials. His company manufactures low-GWP hydrofluoroolefin (HFO) refrigerants as drop-in replacements for those being phased down. Criminal trade in banned HFCs raises the risks of investing in developing such products, he says.
Hooper also notes that use of counterfeit refrigerants in cooling systems can void manufacturer warranties, jeopardize insurance claims, and even expose businesses to regulatory penalties under the EU’s F-gas regulation. “Beyond that, illegal trade is a major setback for Europe’s climate goals,” he says.
Countries in Europe are enhancing enforcement of HFCs
The EIA received funding from the EU in 2017 and regularly holds meetings with its officials to discuss environmental issues, but it is otherwise independent of the union. In its new report, the group targets Halpha and three other companies because they were selling HFCs at a far lower price than possible in a quota-limited economy.
“The idea is, you reduce supply, the price goes up, and people move away from that type of gas,” Walravens says. “The thing is, people are quite stubborn, and so there is this latent demand for HFCs.”
Yet Walravens says the situation is changing. In Italy, for example, authorities announced a major cross-agency initiative on illegal refrigerants. “You have police, customs, tax authorities all working in silos, and that can make enforcement really challenging,” she says. “They’ve come together, particularly to coordinate on HFC gases.”
Italian authorities seized 14 metric tons of illicit hydrofluorocarbons, some of which are shown here, in March 2025. Credit:
Guardia di Finanza, Italy
One challenge for European customs authorities trying to enforce HFC regulations is that companies like Halpha can legally possess restricted gases, Walravens notes. They breach regulations if they try to import more than their quota allows, or without one, as in Halpha’s case. China is the world’s largest manufacturer of HFCs, and many illegally traded gases originate there. But in Europe, because of the quota system, the legal status of the gases has largely depended on which company is importing them.
Now authorities in the Netherlands are focusing on rules specifying that HFCs must be returnable at every step in the supply chain, meaning that any product without clear return measures can be confiscated and destroyed. Criminal traders specifically will not take gases back, and so authorities can easily decide to destroy their products. “That’s one of the things of illegal trade—you don’t want traceability,” Walravens says.
Beyond relatively small companies, the EIA is concerned that otherwise-respectable large businesses are enabling the illegal trade. Its investigation found that the company Puglia Oxygen did not hold any quota for HFCs but claimed to sell the gases to the Italian national railway and the truck manufacturer Iveco Group for refrigerated transport.
Illicit hydrofluorocarbons are sometimes smuggled in propane tanks, such as these compressed-gas cylinders photographed by Polish customs workers, according to the Environmental Investigation Agency UK. Credit:
Customs Department of Poland
Another company without HFC quotas, Carma Metal, told undercover investigators that it supplied refrigerants to manufacturers of equipment ultimately used by the supermarket chains Carrefour and Lidl Italia. “For the first time, we’re beginning to connect the dots” from criminals to larger users, Walravens says.
From his industry perspective, Fox sees European supermarkets as leaders in trying to drive change. “It’s obviously better overall, from the finance point of view, to retain the working [HFC] systems and contain the refrigerant,” Fox says. “The cost of refrigerant has gone up so astronomically that it’s helped to focus the supermarket’s attention on making sure that systems are more leakproof and performing better.”
Meanwhile, in Fox’s experience, new or extensively renovated supermarkets typically deploy modern non-HFC coolant gases like carbon dioxide and propane.
A similar challenge with controlling HFC use is emerging in the US
In the US, bipartisan legislation passed in 2020, called the American Innovation and Manufacturing (AIM) Act, mandates the HFC emission cuts specified by the Kigali Amendment. Starting Jan. 1, 2025, AIM’s Technology Transitions Program restricts HFCs in some appliances and for some subsectors.
The food and beverage industry, including grocery stores, has a different view of the US rules than does the heating, ventilation, air conditioning, and refrigeration (HVAC/R) industry, says Vivian Cox, senior associate climate policy analyst at Clasp, an international appliance-efficiency nonprofit.
Cox says that FMI, a US food industry association, now has the most significant among several open petitions against the technology-transition provisions of the AIM Act. The FMI and two other food industry groups are also suing the US Environmental Protection Agency to review parts of the Technology Transitions rule.
In September 2025, the EPA proposed a softening of some of the AIM Act’s technology-transition requirements, and the proposal went to the Office of Management and Budget on April 17. An EPA spokesperson tells C&EN by email that the agency has heard concerns from stakeholders in the supermarket and other industries about the costs associated with transitioning. “EPA proposed to reconsider the Technology Transitions restrictions that apply to supermarket refrigeration systems based in part on new information the Agency received on availability and costs for those systems,” the spokesperson writes.
In contrast to the food and beverage industry, the HVAC/R industry is “by and large” keen for the AIM Act to continue as originally planned, Cox says. She says firms are “generally pragmatic and willing to work collaboratively with regulating entities to achieve balanced and workable outcomes.”
The US also experiences criminal refrigerant trade. In 2024 a Forbes investigation found more than a hundred sellers in just New York and California on Facebook Marketplace illegally offering refrigerants restricted under the AIM Act. In 2025 the EPA concluded six civil cases resolving violations related to the illegal import of HFCs and charged six individuals in criminal cases for alleged smuggling of HFCs. They were all convicted.
Those individuals it took action against included Julio Cesar Mauricio, who pleaded guilty to smuggling seven 24-pound cannisters of HFCs into Texas from Mexico. A court gave him a 48-day sentence, followed by 2 years of supervised release. At the other end of the spectrum, Volkswagen agreed to pay $155,350 (PDF) for manufacturing 1,012 cars that use restricted HFCs in their air conditioning.
These examples represent the two main types of case that the EPA has pursued. The first is against individuals and small organizations importing HFCs. The second is against entities using them. Neither indicates enforcement against the organized illegal supply chain that the EIA’s report says is happening in Europe. “Europe’s bad,” Walravens says, “and the rest of the world’s about to go through this.”
She emphasizes two key actions for thwarting criminals: stopping new HFC systems from being sold and stopping supermarkets and other large users from deploying them. Training enough engineers in the second group of Kigali Amendment countries—those countries that are more recently industrialized—to go straight to non-HFC systems will help the countries improve over the first group. “It’s really about leapfrogging,” Walravens says. “Can developing countries do better than Europe did?”
Andy Extance is a freelance writer based in Totnes, England.
