EIA’s 10th Illegal Trade Bulletin covers Montreal Protocol negotiations on illegal refrigerant trade, a U.S. smuggling sentence and industry warnings about suspected counterfeit or non-compliant refrigerants in the U.S. and UK. The developments come as markets transition to lower-GWP alternatives and Parties prepare for MOP38 and the 10th anniversary of the Kigali Amendment.
At OEWG48, held from July 13–17, 2026, in Thailand, Parties broadly agreed that licensing systems are central to preventing illegal trade. Discussions covered import and export controls for used, recycled and reclaimed controlled substances, as well as possible licensing coverage for transhipment, re-export and free trade zones. Parties agreed to carry the agenda item to MOP38 for further discussion and decision.
In a U.S. case, an individual who pleaded guilty to refrigerant smuggling was sentenced on June 17, 2026, to a $1,400 fine and three years of probation. Authorities said the person attempted to bring six 25-pound cylinders (about 11.3 kg each) of R-410A through the Brownsville, Texas port of entry on May 18, 2024. The 150 pounds (about 68 kg) of refrigerant had a stated GWP of 2,088 and represented approximately 131 metric tons (about 144 short tons) of CO2e.
Industry representatives in the U.S. have warned about suspected counterfeit R-454B cylinders and advised distributors and contractors to buy only from authorized suppliers, verify products throughout the supply chain and report suspected counterfeit or mislabeled products to the U.S. EPA. In the UK, an international refrigerant distributor reported illegal and potentially non-compliant R-1234yf cylinders, citing possible issues involving refrigerant origin, stabilizing additives, cylinder compliance and product traceability markings.
The bulletin identifies unusual pricing, sales channels or shipping methods, missing documentation, improper packaging or labeling, cylinder non-compliance and suspicious sourcing as warning signs. It also urges caution with e-commerce and informal online marketplaces, where product origin, compliance and seller legitimacy can be difficult or impossible to verify.
