German refrigeration and air-conditioning organisations have supported planned stricter rules for combating and punishing environmental offences, particularly illegal trade in refrigerants, or F-gases.
BIV, BTGA, Bundesfachschule Kälte-Klima-Technik, BVKMW, FGK, the RLT manufacturers’ association and VDKF issued a joint position on the draft law implementing the Environmental Crime Directive. They said illegal F-gas trade undermines the aim of the F-gas Regulation to reduce direct greenhouse gas emissions.
The organisations said illegal refrigerant trade weakens distributors, specialist companies and operators that use legal, and therefore more expensive, refrigerants. They also said refrigerants from illegal sources can endanger service technicians and affect the function and efficiency of refrigeration, air-conditioning and heat pump systems.
The groups called for the offence of a “serious chemical crime” to be expanded. They said it should cover not only gang-related or commercial trade, but also illegal trade in “not insignificant quantities” of F-gases and equipment filled with F-gases, because traded quantities are usually easier to prove in practice.
They also said criminal liability should extend beyond the first illegal placing of refrigerants on the EU market to the entire supply chain in cases of intentional conduct. In addition to telecommunications surveillance, they called for online investigations to be explicitly permitted.
The organisations also supported creating a separate criminal offence in core criminal law for illegal trade in F-gases.
